Linda Jones v. Larry Lindell, MD, individually, Broadlawns Medical Center Foundation d/b/a Broadlawns Medical Center, Does II-V and Roes Corporations VI-X, inclusive
Headline: Iowa Supreme Court Reverses Assault and Battery Verdict Against Doctor and Hospital, Upholds Dismissal of Individual Discrimination Claims
Case Summary
This case involves Linda Jones, a former employee of Broadlawns Medical Center, who sued her supervisor, Dr. Larry Lindell, and Broadlawns for various claims including discrimination, harassment, and retaliation under the Iowa Civil Rights Act (ICRA), as well as common law claims like assault and battery. Jones alleged that Dr. Lindell subjected her to a hostile work environment, made inappropriate comments, and physically assaulted her. The district court initially granted summary judgment in favor of the defendants on most claims, dismissing the ICRA claims against Dr. Lindell in his individual capacity and some common law claims. However, the court allowed the assault and battery claims against Dr. Lindell and Broadlawns to proceed to trial. After a jury trial, Jones was awarded $150,000 in damages for assault and battery against Dr. Lindell and Broadlawns. Both parties appealed. Jones appealed the dismissal of her ICRA claims against Dr. Lindell and the summary judgment on her retaliation claim. Broadlawns and Dr. Lindell appealed the jury's verdict on the assault and battery claims. The Iowa Supreme Court affirmed the district court's decision to dismiss the ICRA claims against Dr. Lindell in his individual capacity, clarifying that the ICRA does not permit individual liability for supervisors. The Court also affirmed the summary judgment on the retaliation claim. However, the Supreme Court reversed the jury's verdict on the assault and battery claims, finding that the district court erred in instructing the jury on the definition of 'assault' and that the evidence did not support a finding of assault under the correct legal standard. The case was remanded for further proceedings consistent with the opinion.
AI-generated summary for informational purposes only. Not legal advice. May contain errors. Consult a licensed attorney for legal advice.
Key Holdings
The court established the following key holdings in this case:
- The Iowa Civil Rights Act (ICRA) does not provide for individual liability against supervisors for discriminatory practices.
- For an assault claim, the plaintiff must prove that the defendant acted with the intent to cause a harmful or offensive contact or the apprehension thereof, and that the plaintiff was put in imminent apprehension of such contact.
- Mere offensive touching, without the intent to cause apprehension of harmful or offensive contact, does not constitute assault.
- A claim for retaliation under the ICRA requires proof of a protected activity, an adverse employment action, and a causal link between the two.
Entities and Participants
Parties
- Linda Jones (party)
- Larry Lindell, MD (party)
- Broadlawns Medical Center Foundation d/b/a Broadlawns Medical Center (company)
- Iowa Supreme Court (party)
Frequently Asked Questions (5)
Comprehensive Q&A covering every aspect of this court opinion.
Basic Questions (5)
Q: What was this case about?
This case was about a former employee, Linda Jones, suing her supervisor and employer for discrimination, harassment, retaliation under the Iowa Civil Rights Act, and common law claims of assault and battery.
Q: Can a supervisor be sued individually under the Iowa Civil Rights Act?
No, the Iowa Supreme Court clarified that the Iowa Civil Rights Act does not allow for individual liability against supervisors for discriminatory practices.
Q: What was the outcome of the assault and battery claims?
The jury initially awarded Jones $150,000 for assault and battery, but the Iowa Supreme Court reversed this verdict, finding that the jury was improperly instructed on the definition of assault and that the evidence did not meet the correct legal standard for assault.
Q: What is required to prove an assault?
To prove an assault, the plaintiff must show that the defendant intended to cause a harmful or offensive contact or the apprehension of such contact, and that the plaintiff was put in imminent apprehension of such contact. Mere offensive touching without this intent is not enough.
Q: Did Linda Jones win her retaliation claim?
No, the district court's summary judgment dismissing her retaliation claim was affirmed by the Iowa Supreme Court.
Case Details
| Case Name | Linda Jones v. Larry Lindell, MD, individually, Broadlawns Medical Center Foundation d/b/a Broadlawns Medical Center, Does II-V and Roes Corporations VI-X, inclusive |
| Court | iowa |
| Date Filed | 2026-03-06 |
| Docket Number | 25-0287 |
| Outcome | Mixed Outcome |
| Impact Score | 75 / 100 |
| Legal Topics | employment-discrimination, assault-and-battery, retaliation, hostile-work-environment, summary-judgment, jury-instructions, individual-liability |
| Jurisdiction | ia |
About This Analysis
This AI-generated analysis of Linda Jones v. Larry Lindell, MD, individually, Broadlawns Medical Center Foundation d/b/a Broadlawns Medical Center, Does II-V and Roes Corporations VI-X, inclusive was produced by CaseLawBrief to help legal professionals, researchers, students, and the general public understand this court opinion in plain English.
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AI-generated summary for informational purposes only. Not legal advice. May contain errors. Consult a licensed attorney for legal advice.