Smith v. Iowa State Univ. of Sci. & Tech.
Annotate this CaseDennis Smith was formerly employed by the College of Engineering at Iowa State University (ISU), where he was “subjected to wrongful conduct for an extended period of time in a job he had held for nearly a decade.” Smith filed suit against ISU and the State, alleging, inter alia, that he suffered retaliation for reporting managerial misconduct to ISU’s president. After a jury trial, Smith recovered $500,000 for intentional infliction of emotional distress and $784,027 under a whistleblowing statute. The court of appeals affirmed the intentional infliction of emotional distress award but set aside the statutory whistleblowing award, finding that Smith had failed to prove a causal relationship between his disclosures to the president and any actions of reprisal taken against him. The Supreme Court (1) affirmed the jury’s emotional distress award, holding that Defendants’ conduct toward Smith was outrageous and that the verdict was not excessive; and (2) reduced, but did not set aside, the district court’s award of damages under the whistleblowing statute, where the evidence supported the finding that Smith suffered retaliation for reporting managerial misconduct but where Smith’s loss of his job was not causally linked to his discussion with ISU’s president.
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