## Facts

- In 1999, a dentist hired Melissa Nelson as a dental assistant; she worked in the practice for over ten years and was regarded as an excellent employee.
- Around 2009, the dentist told Nelson her clothing was sometimes “too tight” or “distracting” and asked her to wear a lab coat; Nelson denied dressing inappropriately.
- During the final months of employment, the dentist and Nelson exchanged personal text messages; some messages from the dentist were sexual in nature.
- The dentist’s wife, who worked in the office, discovered the texts, confronted her husband, and demanded Nelson be terminated because she viewed Nelson as a threat to the marriage.
- The dentist fired Nelson in a meeting attended by a pastor, stating their relationship had become detrimental to their families; Nelson received one month’s severance and stated she loved her job.
- The dentist later told Nelson’s husband (with the pastor present) that Nelson had done nothing wrong, but he feared he might attempt an affair if she remained employed.

## Issues

1. Whether discharging a female employee at the employer’s spouse’s insistence, based on jealousy and concern about the employer-employee relationship, constitutes discharge “because of sex” under the Iowa Civil Rights Act.
2. Whether a termination driven by a specific personal relationship (rather than gender-based animus, stereotypes, or class-wide disparate treatment) can support an ICRA sex-discrimination claim.

## Decision

- The Iowa Supreme Court affirmed summary judgment for the employer and the dental practice.
- The court held the termination was not “because of sex” within the meaning of the Iowa Civil Rights Act.
- The court emphasized the claim was pleaded as discriminatory discharge, not sexual harassment or hostile work environment.
- The court concluded the record showed a relationship-based motive—jealousy and perceived threat to the marriage—rather than a gender-based motive.

## Legal Principles

- The Iowa Civil Rights Act prohibits discharge “because of” sex; the statute is interpreted consistently with Title VII authority absent a relevant textual difference.
- Adverse action violates the statute when motivated by sex as a protected characteristic, including certain gender-based stereotypes or gender-specific traits used as proxies for sex.
- An employer’s decision based on a particular, idiosyncratic personal relationship—such as a spouse’s jealousy or fear of impropriety tied to a specific employee—does not, without more, establish sex discrimination.
- Absent evidence of gender-wide disparate treatment or that a similarly situated male employee would have been treated differently, a relationship-specific discharge generally does not satisfy the “because of sex” requirement.

## Conclusion

The court held that terminating an employee due to the employer’s spouse’s jealousy and concerns about the employer’s relationship with that employee is a personal-relationship decision, not sex discrimination under the Iowa Civil Rights Act, and affirmed summary judgment for the employer.


Nelson v. Knight, 834 N.W.2d 64 (Iowa 2013)