Jahnke v. Deere & Co.

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The Supreme Court reversed the decision of the district court denying Employer’s motion for summary judgment on Employee’s lawsuit filed under the Iowa Civil Rights Act (ICRA) alleging that Employer discriminated against him based on his age, sex, and national origin.Matthew Jahnke, an employee of Deere & Co., worked as a factor manager at Harbin Works in Harbin, China under a contract with a Deere Chinese subsidiary. As discipline for Jahnke engaging in sexual relationships with two Chinese employees, Jahnke was ultimately removed as the factor manager, repatriated back to the United States, and assigned to a position of lesser authority and lower pay in Waterloo, Iowa. Jahnke filed suit under the ICRA. In its motion for summary judgment, Deere claimed that the ICRA did not apply extraterritorially and that Jahnke based his claims on allegations of discriminatory acts that occurred outside of Iowa. The district court denied the motion. The Supreme Court reversed, holding (1) the ICRA does not apply extraterritorially; and (2) because Jahnke failed to show that either he or Deere was located within Iowa for purposes of the alleged discriminatory act, Jahnke had no claim under the ICRA. View "Jahnke v. Deere & Co." on Justia Law