Rick Carter v. Lee County, Iowa

CourtCourt of Appeals of Iowa
DecidedJanuary 14, 2015
Docket13-1196
StatusPublished

This text of Rick Carter v. Lee County, Iowa (Rick Carter v. Lee County, Iowa) is published on Counsel Stack Legal Research, covering Court of Appeals of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rick Carter v. Lee County, Iowa, (iowactapp 2015).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 13-1196 Filed January 14, 2015

RICK CARTER, Plaintiff-Appellant,

vs.

LEE COUNTY, IOWA, Defendant-Appellee. ________________________________________________________________

Appeal from the Iowa District Court for Lee County (South), Mary Ann

Brown, Judge.

A fired employee appeals the district court’s grant of Lee County’s motion

for judgment notwithstanding the verdict. AFFIRMED.

Curtis Dial of Law Office of Curtis Dial, Keokuk, for appellant.

Steven E. Ort of Bell, Ort & Liechty, New London, for appellee.

Heard by Danilson, C.J., and Doyle and Tabor, JJ. 2

TABOR, J.

Rick Carter envisioned himself a whistleblower, revealing to the public

what he believed to be Lee County’s “troubling pattern of irresponsible money

management” and health and safety violations. The Lee County supervisors

viewed Carter as an insubordinate employee who demonstrated “a proclivity to

ad hominem attacks on any one disagreeing with him.” The supervisors fired

Carter and Carter sued the county under Iowa Code section 70A.29 (2011), a

statute prohibiting reprisals against employees of political subdivisions who

disclose negative information.

The suit went to trial and a jury awarded Carter a total of $186,000 in

damages. The county filed motions for a judgment notwithstanding the verdict

(JNOV) and a new trial, alleging Carter failed to present sufficient evidence to

support the jury’s finding he engaged in protected activity that triggered the

termination of his employment. The district court granted the county’s JNOV

motion.

On appeal, Carter urges us to overturn the JNOV because the district

court erroneously interpreted the whistleblower statute and wrongly viewed the

evidence in the light most favorable to the county. Carter contends we should

reinstate the verdict because it was supported by substantial evidence.

We conclude the district court properly interpreted the whistleblower

statute and viewed the evidence in the light most favorable to Carter. Applying

those legal standards, the district court correctly determined no reasonable jury

could have found Carter engaged in protected activity. Accordingly, we affirm the

district court’s grant of JNOV. 3

I. Standard of Review

A motion for JNOV provides the district court with a second chance to

correct any error in its earlier decision to deny a motion for directed verdict. See

Iowa R. Civ. P. 1.1003(2); Van Sickle Constr. Co. v. Wachovia Commercial

Mortg., Inc., 783 N.W.2d 684, 687 (Iowa 2010). “When the district court

considers a motion for JNOV, it must view the evidence in the light most

favorable to the party against whom the motion is made.” Schlegel v. Ottumwa

Courier, 585 N.W.2d 217, 221 (Iowa 1998).

We review a JNOV ruling for legal error. Iowa R. App. P. 6.907; Smith v.

Iowa State Univ. of Sci. & Tech., 851 N.W.2d 1, 18 (Iowa 2014). We consider

the evidence in the same manner as the district court did, asking whether the

plaintiff offered sufficient evidence to generate a jury question. Schlegel, 585

N.W.2d at 221. “To justify submitting the case to the jury, substantial evidence

must support each element of the plaintiff’s claim.” Smith, 851 N.W.2d at 18.

“Substantial evidence” exists if “reasonable minds would accept the evidence as

adequate to reach the same findings.” Id.; Schlegel, 585 N.W.2d at 221. We

take “into consideration every legitimate inference that may fairly and reasonably

be made.” Seastrom v. Farm Bureau Life Ins. Co., 601 N.W.2d 339, 347 (Iowa

1999).

II. Background Facts and Proceedings

Viewing the evidence in the light most favorable to Carter, including all

reasonable inferences, the jury could have found the following facts based upon

Carter’s own testimony. 4

Carter began his employment as maintenance director for Lee County in

2007. He reported to Larry Kruse, a member of the county’s board of

supervisors and its liaison to the maintenance department. If Carter had

concerns regarding the maintenance department, he “would question Kruse and,

usually, [Kruse] would have [him] take it to the Board.”

In 2008, the county began the project of building a new jail, and Kruse

“brought in” Carter to oversee the contractors and “make sure they’re doing their

job right and not . . . taking advantage of the county.” Carter also testified his

role included overseeing outside bids for the jail project such as electrical, air

conditioning, and plumbing contractors. The county hired John Hansen, owner of

the construction management firm Midwest Construction Consultants, to consult

on the jail project. Carter testified Hansen and Kruse showed him diagrams and

blueprints created for constructing the jail and asked for his input.

At some point, Carter learned the jail plans called for a certain-sized pipe

for the plumbing, and Carter was concerned the specified size was too narrow.

Carter spoke with a master plumber who recommended a larger pipe be used,

and Carter ultimately took his concerns regarding the pipe size to Kruse. Kruse

told him his concerns were “ridiculous,” and Carter asked him if he could present

the issue at the supervisors’ public meeting. Kruse told him he “better not”

because “it would interfere with the jail.”

Carter presented his concerns at the public meeting anyway, in

approximately January 2008. Carter testified he told Kruse “it was something I

felt the public should know.” Present at the meeting were the board members,

the county sheriff, the county engineer, and other county department heads. 5

Carter recalled that some county supervisors were supportive of Carter’s

concerns, but Kruse “was mad” and “didn’t want anything to do with it.”

Ultimately, the board agreed with Carter and chose a larger-sized pipe for the

project.

During the jail’s construction process, Carter voiced additional concerns to

Kruse and other board members. Because Kruse and others continued to

disregard Carter’s concerns, Carter continued to air them at public board

meetings. Several concerns he raised at meetings were addressed by the board

and ultimately changed, including how water would be supplied to the jail and the

need for a new leach field for the sewer system. Carter testified other concerns

he voiced were not resolved as he would have liked or not addressed at all, such

as concerns regarding the workmanship by certain contractors in the jail

construction. Carter also expressed concerns the county was hiring contractors

to do work his department could do for no extra cost.

Carter, as the head of the maintenance department, was in charge of the

department’s funds. He believed some money from his budget was being put

toward construction of the jail because Kruse would ask him “to sign off on a

hundred twenty or a hundred sixty thousand dollars’ worth of receipts.” Carter

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