Polly Carver-Kimm v. Kim Reynolds, Pat Garrett, and State of Iowa and Gerd Clabaugh, Sarah Reisetter, and Susan Dixon

Summary

The court held that the qualified-immunity statute did not retroactively bar the plaintiff’s common-law wrongful-discharge claim and that her amended pleading was not subject to the statute’s heightened pleading requirements. It further held that compliance with a statutory duty to produce public records can support a public-policy wrongful-discharge claim, but dismissed the claims against the Governor and communications director because they lacked statutory authority to discharge the plaintiff. The court also dismissed the statutory whistleblower claims against those defendants because the statute requires the defendant to have discharged the employee. Claims against the State remained pending, and the case was remanded.