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Clay v. State6/19/2002
Helen Clay appeals from a district court order entering judgment in favor of the State of Iowa on her claim of disability discrimination in violation of the Iowa Civil Rights Act. AFFIRMED.
Helen Clay appeals from a district court order entering judgment in favor of the State of Iowa on her claim of disability discrimination in violation of the Iowa Civil Rights Act. Clay contends the district court erred in applying the law to the facts of her case.
I. Background Facts and Proceedings.
Helen Clay was employed by the Iowa Department of Education (Department) from 1982 until she resigned in 1998. Clay was initially hired as a Clerk/Typist before becoming a Secretary I and, ultimately, an Administrative Assistant I.
In 1990, Clay suffered an injured back after slipping and falling on a wet floor in the Grimes State Office Building. Clay claimed and was awarded worker's compensation benefits. Clay's subsequent claim for additional worker's compensation benefits for knee and hip problems she alleged were caused by the back injury was denied. In 1997, Clay filed a claim for carpal tunnel syndrome in both hands and wrists, which the State settled.
After the 1990 back injury , it became more difficult for Clay to perform routine tasks at work and home. In an attempt to accommodate Clay, her employer provided her a lumbar support chair. She was also allowed to arrange her work schedule as needed to accommodate her medical condition, including leaving the office. However, Clay maintains she was doing duties beyond those listed in the job requirements of an Administrative Assistant I. She contends she was given many duties of an Administrative Assistant II. She complained to her supervisor regarding the discrepancy in work load and pay, but the department would not promote her to Administrative Assistant II. Clay argues the additional job duties she was required to perform were too difficult given her medical condition.
On January 16, 1998, Clay resigned her position at the Department of Education, citing the difficulties with her back and hands/wrists. At that time, Clay's duties were reallocated to other secretaries in the Department, or to other departments. On December 16, 1998, Clay filed an action against the State alleging she was discriminated against in her employment with the Department on the basis of her disability. She claimed she was discriminated against in her exercise of her worker's compensation benefits. She also alleged the State created a hostile work environment, leading to her constructive discharge.
After trial, the district court concluded Clay had not proved the State discriminated against her in its handling of her worker's compensation claims. It also denied Clay's wrongful discharge claim, finding Clay did not meet the prima facie requirement because she was not a qualified person with a disability.
Clay appeals, contending she met the prima facie requirement of being a qualified person with a disability. She argues the district court erred in failing to recognize she was required to perform additional duties outside her job description and these additional tasks caused her to resign. She also claims the court erred in failing to consider that an employer can make accommodation by adjusting its worker's compensation claim processing policies.
II. Scope of Review.
We review disability discrimination claims tried to the court for errors at law. Schlitzer v. University of Iowa Hospitals & Clinics, 641 N.W.2d 525, 529 (Iowa 2002). We are bound by the trial court's findings of fact if supported by substantial evidence. Id. Evidence is substantial when a reasonabl
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