Supreme Court of Iowa

Jena McCoy v. Thomas L. Cardella & Associates

June 16, 2023

Summary

The court held that McCoy's common-law negligent supervision claim was barred by the Iowa Workers' Compensation Act because the claim, as tried, sought emotional-distress damages for mental-health injuries caused by workplace assault and battery. The workers' compensation exclusivity rule turns on the injuries and damages actually presented, rather than the label or shifting characterization of the tort claim. The court therefore reversed the denial of judgment notwithstanding the verdict and remanded for entry of judgment for Cardella.