Police officer brought action against city under Iowa Civil Rights Act (ICRA), alleging disability discrimination based on termination following post-traumatic stress disorder (PTSD) diagnosis and failure to provide reasonable accommodation.
The District Court denied city’s motion for directed verdict, entered judgment on jury verdict finding city liable for both claims and denied city’s motion for judgment notwithstanding the verdict (JNOV) and new trial. City appealed. The Court of Appeals reversed and remanded. Both parties requested further review, which was granted.
The Supreme Court held that:
- City presented legitimate, non-discriminatory reason for police officer’s termination, namely his misconduct in repeatedly misusing his status as police officer to threaten other law enforcement personnel;
- Whether police officer’s PTSD was a motivating factor in city’s termination of his employment was question for jury;
- Officer who engaged in terminable conduct could not avoid the consequences of his actions by then requesting accommodation for his PTSD at pre-disciplinary meeting with police chief; and
- Jury instruction which misstated the law and broadened definition of discrimination tainted jury’s verdict, such that new trial was required.