Iowa Supreme Court sides with Iowa State employee in wage discrimination suit

Upending a Polk County District Court ruling and reinforcing precedent for wage discrimination cases in Iowa, the state Supreme Court has found a former and longtime Iowa State University professor could recover damages going back more than a decade for being paid less than her male colleagues.

“The statute providing the remedies for violations of (Iowa’s wage discrimination code) is unambiguous,” according to the high court’s ruling Friday. “The statute authorizes a claimant to recover ‘for the period of time for which the complainant has been discriminated against.’

“It does not mean recovery is limited to two years prior to filing. It does not mean recovery is limited to 300 days prior to filing,” according to the order, addressing the university’s arguments. “It means exactly what it says: the claimant can recover ‘for the period of time for which the complainant has been discriminated against’.”

In reversing and remanding the lower court’s August 2023 ruling that ISU Professor Emeritus Silvia Cianzio could not recover damages for her wage claims beyond a two-year statute of limitations, the high court declined ISU’s “invitation to graft a temporal limitation into the damages statute where none exists.”

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And it rejected the District Court’s decision-making process — which justices said involved arguments neither the plaintiff nor defendant raised or addressed themselves: that allowing an employee to recover for a “relatively unlimited time frame — perhaps limited only by a person’s work life span — would produce impractical or absurd results.”

Although Cianzio’s tenure as an ISU employee spanned more than 40 years — beginning with her hire in 1979 as an assistant professor in the Department of Agronomy, where she earned a master’s and doctorate — she’s arguing for recourse dating only to 2009, when the state’s wage-discrimination damages provision became law.

“Cianzio argues that Iowa Code … permits damages for the entire time she was discriminated against dating back to the statute’s effective date on July 1, 2009,” according to the Iowa Supreme Court. “The university argues that Cianzio can seek damages only for each paycheck issued during the 300-day period prior to the date Cianzio filed her complaint with the Iowa Civil Rights Commission.”

The university, alternatively, backed the two-year statute of limitations that the District Court landed on — a decision the Supreme Court reversed with its opinion.

‘The salary differences were insignificant’

Cianzio in her January 2022 lawsuit reported being unaware of any alleged gender-pay gap in her department until being asked in 2020 to lead a diversity, equity and inclusion committee — through which she reviewed salary data.

“The survey revealed that, on average, the male professors in the department were paid more than the female professors,” according to the Supreme Court opinion. Regarding her pay, Cianzio discovered she was earning $11,276 to $46,049 less than male professors in her specialty.

“Cianzio reported her findings to the department chair, the dean, and associate dean of the college, and the Iowa State University human resources department,” according to the opinion. “These officials countered that the salary differences were insignificant and that there was no need for further action.”

After serving on the committee, Cianzio retired from ISU — receiving her final paycheck Dec. 31, 2020. She filed a complaint with the Iowa Civil Rights Commission on Aug. 12, 2021, received a right-to-sue notice in November and filed her lawsuit in January 2022.

The university argued Cianzio could seek only damages through a 300-day statute of limitations period; Cianzio argued the statute related only to her filing a complaint in time, “which no one disputed.”

The high court agreed with Cianzio: “With that clarification regarding the distinction between statutes of limitations and statutes governing damages, the answer to the question presented becomes clear.”

In Cianzio’s lawsuit, she reporting learning that her department in 2019 had 22 full professors — 19 men and three women — and the women made substantially less. Her attorney has reported Cianzio was shorted $530,000 between 2009 and 2020.

“That also represents the amount of money that Iowa State has saved over that time,” Cianzio’s attorney, Ann Brown, said during oral arguments in October — pushing for the need to penalize employers or risk continued discrimination.

“The damage provision has to overcome the financial benefit that the employer obtains by paying women less, or it doesn't work.”

Vanessa Miller covers higher education for The Gazette.

Comments: (319) 339-3158; vanessa.miller@thegazette.com