Female police department employee brought action against police chief, deputy chief, and her superior, alleging she experienced sexual harassment and retaliation in violation of the Iowa Civil Rights Act (ICRA).
The District Court denied defendants’ motions for summary judgment. Defendants sought interlocutory review, which was granted.
The Supreme Court held that:
- Deputy chief’s alleged conduct was not actionable sexual harassment;
- Chief’s memorandum directive to employee and deputy chief did not amount to an “adverse action” that would support a retaliation claim; and
- Superior’s alleged actions did not constitute a “materially adverse action.”