# Northrup v. Farmland Industries, Inc.

> Supreme Court of Iowa · July 31, 1985 · 372 N.W.2d 193

URL: https://www.frixlaw.com/law-library/cases/9664972

## Case

- **Full name:** Steve NORTHRUP, Appellant, v. FARMLAND INDUSTRIES, INC., Appellee
- **Court:** Supreme Court of Iowa
- **Decided:** July 31, 1985
- **Citations:** 372 N.W.2d 193; 55 Fair Empl. Prac. Cas. (BNA) 1756; 7 I.E.R. Cas. (BNA) 1778; 1985 Iowa Sup. LEXIS 1087
- **Precedential status:** Published
- **Opinion:** Concurrence by Reynoldson
- **Judges:** Larson, Reynoldson, Reynold-Son
- **Cited by:** 83 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/9664972

## How later opinions describe it (automated extraction)

- noting that while Iowa cases refer to this claim as an “intentional infliction of emotional distress,” neither the Restatement nor Iowa case law requires proof of an intentional act; a “reckless disregard of the probability of causing” emotional distress is enough
- stating that “the procedure under the civil rights act is exclusive, and a claimant asserting a discriminatory practice must pursue the remedy provided by the act”
- finding sole remedies for discharge from employment based on disabilities was under the ICRA and any common law action for wrongful discharge could not be recognized
- holding remedy provided under Iowa Civil Rights Act “is exclusive”

## Opinion text

REYNOLDSON, Chief Justice
(concurring specially).
I concur specially because I still am not convinced the legislature intended that alcoholism should immunize an at-will employee from discharge, as this decision implies.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9664972. Public record. Not legal advice.