COTE v. DERBY INS. AGENCY, INC.

No. 16-0558.

908 N.W.2d 861 (2018)

Joanne COTE, Appellee, v. DERBY INSURANCE AGENCY, INC., an Iowa Corporation, and Kevin Dorn, Individually, Appellants.

Supreme Court of Iowa.

Filed March 9, 2018.


Attorney(s) appearing for the Case

Edward F. Pohren and Aaron F. Smeall of Smith, Slusky, Pohren & Rogers, LLP, Omaha, Nebraska, for appellants.

Jay E. Denne and Stanley E. Munger of Munger, Reinschmidt & Denne, LLP, Sioux City, for appellee.


In this appeal, we must decide whether a small business that incorporates thereby loses the family-member exception to the employee-numerosity requirement in the Iowa Civil Rights Act (ICRA). The ICRA does not apply to "[a]ny employer who regularly employs less than four individuals.... [I]ndividuals who are members of the employer...

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