context: Rather, in DeBoom, we were careful to note the difference between the discriminatory discharge causa tion standard and the "higher" causation standard of claims such as tortious discharge. We have frequently compared tortious discharge under common law and retaliatory discharge under the ICRA, as the two have traditionally possessed similar elements and causation standards.
citation_a.signal: see
citation_a.identifier: 584 N.W.2d 301, 301-02
citation_a.parenthetical: stating high causation standard for tortious discharge and comparing to Hulme, a retaliatory discharge case under the ICRA
citation_a.sentence: See Teachout, 584 N.W.2d at 301-02 (stating high causation standard for tortious discharge and comparing to Hulme, a retaliatory discharge case under the ICRA); see also Brown v. Farmland Foods, Inc., 178 F.Supp.2d 961, 979 (N.D. Iowa 2001) (“[T]he Iowa Supreme Court has consistently sought guidance in its common-law retaliatory discharge cases from its decisions involving claims of statutory retaliation, which further demonstrates that the Iowa Supreme Court would analyze these distinct causes of action in a similar manner.”); cf. Scott Rosenberg & Jeffrey Lipman, Developing a Consistent Standard for Evaluating a Retaliation Case Under Federal and State Civil Rights Statutes and State Common Law Claims: An Iowa Model for the Nation, 53 Drake L. Rev. 359, 414-15 (2005) (“The federal courts have used the same approach in defining actionable employment conduct in both statutory and common law cases.”).
citation_b.signal: see also
citation_b.identifier: 178 F.Supp.2d 961, 979
citation_b.parenthetical: "[T]he Iowa Supreme Court has consistently sought guidance in its common-law retaliatory discharge cases from its decisions involving claims of statutory retaliation, which further demonstrates that the Iowa Supreme Court would analyze these distinct causes of action in a similar manner."
citation_b.sentence: See Teachout, 584 N.W.2d at 301-02 (stating high causation standard for tortious discharge and comparing to Hulme, a retaliatory discharge case under the ICRA); see also Brown v. Farmland Foods, Inc., 178 F.Supp.2d 961, 979 (N.D. Iowa 2001) (“[T]he Iowa Supreme Court has consistently sought guidance in its common-law retaliatory discharge cases from its decisions involving claims of statutory retaliation, which further demonstrates that the Iowa Supreme Court would analyze these distinct causes of action in a similar manner.”); cf. Scott Rosenberg & Jeffrey Lipman, Developing a Consistent Standard for Evaluating a Retaliation Case Under Federal and State Civil Rights Statutes and State Common Law Claims: An Iowa Model for the Nation, 53 Drake L. Rev. 359, 414-15 (2005) (“The federal courts have used the same approach in defining actionable employment conduct in both statutory and common law cases.”).