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 apply retroactively to the common-law wrongful-discharge claim because the claim accrued before the statute took effect, and the statute's heightened pleading requirements did not require amendment of the already-pleaded claim. The court recognized that an employee's discharge for performing a statutory duty to produce public records may support a public-policy wrongful-discharge claim, but held that the Governor and her communications director could not be liable because they lacked statutory authority to discharge the employee. The court likewise held that the statutory whistleblower claim requires the defendant to have discharged the employee, so the Governor and communications director were dismissed from that claim, while the claims against the State remained.