Tracy White v. State of Iowa and Iowa Department of Human Services

Summary

The court reversed a jury judgment awarding emotional-distress damages on an employee's hostile-work-environment claim and remanded for entry of judgment notwithstanding the verdict. It held that the employee's firsthand experiences, viewed without substantial weight given to harassment of which she was unaware or that was directed at others, were not objectively severe or pervasive enough to alter her employment conditions. The court therefore did not reach the evidentiary, jury-instruction, or damages issues raised on appeal.