DISCLAIMER: Any unofficial case summaries below are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
212537P.pdf 06/14/2022 Michelle Brandt v. City of Cedar Falls
U.S. Court of Appeals Case No: 21-2537
U.S. District Court for the Northern District of Iowa - Eastern
[PUBLISHED] [Shepherd, Author, with Benton and Stras, Circuit Judges]
Civil case - Employment discrimination. With respect to plaintiff's FMLA
claims, the district court did not err in granting the employer's motion
for summary judgment, as plaintiff failed to demonstrate that she
sustained any recoverable damages, and it is undisputed that she did not
seek any form of equitable relief; nominal damages are not recoverable
under the FMLA as they are not included in the specific, statutorily
prescribed damages; as to plaintiff's retaliation claim, assuming
plaintiff made a prima facie case, she failed to show the legitimate,
non-discriminatory basis for her termination - her myriad performance
deficiencies - was a pretext for her termination; plaintiff's
failure-to-promote claims were untimely; with respect to her age
discrimination claim, defendant's stated a legitimate, non-discriminatory
ground for termination which plaintiff failed to show was a pretext for
discrimination; with respect to plaintiff's hostile work environment
claims under the Iowa Civil Rights Act, the claims were time-barred, and
were not covered by the continuing violation doctrine.