Valdez v. West Des Moines Community Schools
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The Supreme Court affirmed the judgment of the district court concluding that Desira Johnson, a teacher at the West Des Moines Community Schools (the District), was not subject to individual liability under the Iowa Civil Rights Act (ICRA) on Plaintiff's claim of constructive discharge, holding that there was no error.
Plaintiff, a teacher's associate who worked with special education students in the District, sued the District and Johnson, alleging that Johnson engaged in racial discrimination, leading to Plaintiff's constructive discharge in violation of the ICRA. The jury returned a defense verdict in favor of the District. The Supreme Court affirmed, holding (1) the district did not err in overruling Plaintiff's Batson challenge to Defendants' peremptory strike of the only Black potential juror; (2) the district court did not err in granting Johnson's motion for directed verdict for correction of errors at law; and (3) Plaintiff was not entitled to relief on her allegations of error in the district court's evidentiary rulings.
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