Godfrey v. StateAnnotate this Case
This case involved claims brought against various state officials for damages related to public employment. Plaintiff was an Iowa Workers’ Compensation Commissioner. At issue in this interlocutory appeal were four counts alleging violation of due process and equal protection provisions of the Iowa Constitution. The district court granted summary judgment for Defendants on those claims, concluding that there are no private causes of action for violations of the Iowa Constitution. The Supreme Court reversed in part and affirmed in part, holding that Defendants were not entitled to summary judgment on two of those counts where (1) the equal protection clause of the Iowa Constitution is self-executing; (2) classic preempt doctrine does not apply to the question of whether a Bivens-type damage remedy is available through the Iowa Constitution; and (3) the different nature of the interests protected weighs in favor of allowing a Bivens-type claim to go forward against Defendants.