Supreme Court of Iowa

Ashley Lynn Koester v. Eyerly-Ball Community Mental Health Services, Rebecca Parker, and Monica Van Horn

December 13, 2024

Summary

The court held that Koester failed to state either a statutory wage-retaliation claim or a common-law wrongful-discharge claim because she alleged that she was paid all wages she claimed and was terminated over a dispute about future compensation rates. Chapter 91A protects employees who pursue unpaid wages or engage in other conduct expressly covered by its retaliation provision; it does not protect an employee merely for submitting approved timesheets, receiving overtime payments, or discussing wages with coworkers. The court therefore vacated the court of appeals decision and affirmed dismissal by the district court.