Ashley Koester was employed as a mobile crisis counselor for Eyerly-Ball Health Services (“Eyerly-Ball”). She was an hourly employee and would work intermittent shifts as needed. Koester was classified as a nonexempt employee and was eligible to receive overtime pay. See 29 U.S.C.A. § 213; id. § 207(a)(1). The rate she received varied depending on the type of work that she performed. After speaking with a coworker, Koester determined that she was receiving overtime pay, while her other coworkers were not. According to Koester, she was then terminated from Eyerly-Ball for receiving overtime and discussing her wages with her coworkers. Koester sued for common law wrongful discharge. Later, Koester amended her petition to assert a statutory claim for wrongful discharge and retaliation in violation of Iowa Code section 91A.10 (2022).
Eyerly-Ball filed a motion to dismiss both claims, arguing that Koester’s claims failed because she had been paid in full. In addition, Eyerly-Ball argued that Koester’s 91A.10 claim was time-barred due to the two-year statute of limitations for actions “founded on claims for wages or for a liability or penalty for failure to pay wages.” The district court granted the motion to dismiss as to both counts.
On appeal, the court of appeals affirmed the district court’s ruling that the statutory claim was time-barred. However, they reversed the dismissal of the public policy claim, holding that the public policy behind 91A.10 was broad enough to encompass Koester’s claim.
The Iowa Supreme Court found that Koester did not have a claim under Chapter 91A directly or indirectly through the common law tort of wrongful discharge in violation of public policy. The Court noted that Chapter 91A is not a generalized fair practice law; it is a wage collection law. Being that Koester never had a claim for unpaid wages, she was not entitled to relief. The Court affirmed the district court’s order of dismissal and vacated the decision of the court of appeals.