Godfrey v. StateAnnotate this Case
Plaintiff, the workers’ compensation commissioner, filed an amended petition against the State and individual defendants named in their official and individual capacities. Plaintiff’s claims stemmed from his refusal to resign upon the Governor-elect’s demand for resignation and Plaintiff's subsequent reduction in salary. The attorney general provided a certification certifying that the individual defendants were acting within the scope of their employment at the time of the allegations contained in the amended petition, and therefore, certain immunities applied to various counts of the petition. The district court dismissed those counts alleging that the individual defendants acted outside the scope of their employment, concluding that the attorney general’s certification was applicable to all of Plaintiff’s claims. The Supreme Court reversed, holding (1) the Iowa Tort Claims Act applies only to torts committed by state employees when acting within the scope of their employment; and (2) therefore, the attorney general’s certification was not applicable to Plaintiff’s common law claims alleging that the individual defendants acted outside the scope of their employment. Remanded.