Iowa Professor May Pursue Pay Discrimination Damages

The Iowa Supreme Court has remanded a wage claim of a college professor

Taken as true, the petition establishes the following. Cianzio earned her Ph.D. from Iowa State University in 1978 and obtained a postdoctoral position with the school. In 1979, she was hired as an assistant professor by the Department of Agronomy. In 1984, Cianzio was promoted to associate professor. In 1995, she was promoted to professor. She held this position until she retired in December 2020. Throughout her career, Cianzio maintained a specialty in plant breeding with a focus on soybean genetics.

In 2020, prior to her retirement, Cianzio was selected to serve as the chairperson of the department’s committee on diversity, inclusion, and equity. The dean of the College of Agriculture and Life Sciences tasked the committee with conducting an employee survey on the “climate” of the department. As part of the survey, the committee reviewed the salaries of the department’s professors. The survey revealed that, on average, the male professors in the department were paid more than the female professors. As it related to Cianzio specifically, the survey showed her annual pay was $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. These officials countered that the salary differences were insignificant and that there was no need for further action.

She filed a wage discrimination claim.

Holding

we hold the district court erred in concluding that Cianzio’s damages for any alleged violations of section 216.6A are limited by section 614.1(8) to the two-year period preceding the filing of her complaint. The question presented is not whether Cianzio timely filed her claim, the question presented is to what damages she might be entitled upon proving her claim. While a plaintiff asserting a violation of Iowa Code section 216.6A must file his or her complaint within 300 days of one of the discriminatory practices set forth in section 216.6A(2)(b), the plaintiff’s potential recovery is governed by Iowa Code section 216.15(9)(a)(9), which permits damages “for the period of time for which the complainant has been discriminated against” even if such discrimination occurred more than 300 days prior to filing a complaint. This is limited only by the prospective nature of Iowa Code section 216.6A. See Dindinger, 860 N.W.2d at 566.

For these reasons, we reverse the district court’s order granting the University’s motion to dismiss in part and remand this matter for further proceedings consistent with this opinion.

(mike Frisch)