Clarifying Iowa’s Workers’ Compensation Exclusivity: Gross Negligence Exception and Limits on Intentional Tort Claims Against Employers

Introduction

This commentary examines the Iowa Supreme Court’s May 23, 2025 decision in Mehmedovic v. Tyson Foods, Inc., which addressed whether estates of four workers who died after allegedly contracting COVID-19 at Tyson’s Waterloo plant could pursue common-law tort claims alongside—and outside—the exclusive remedy of Iowa’s Workers’ Compensation Act (IWCA). The plaintiffs sued Tyson Foods, corporate executives, plant supervisors and occupational‐health staff for gross negligence, fraudulent misrepresentation, breach of duty and sought punitive damages. The district court dismissed all claims for lack of subject matter jurisdiction under the IWCA; the Supreme Court affirmed dismissal of claims against Tyson Foods entities and certain employees, reversed dismissal of gross negligence claims against executives and supervisors, and remanded. The decision (1) clarifies pleading standards for gross negligence under Iowa Code § 85.20(2), (2) holds that intentional tort claims against employers remain preempted, and (3) addresses Iowa’s COVID-19 liability shield (Back-to-Business Act).

Summary of the Judgment

The Supreme Court’s unanimous opinion by Justice McDermott:

Affirmed that the IWCA provides the exclusive remedy for work-related injuries against employers, including intentional tort claims, and thus dismissed claims against the corporate defendants (Tyson Foods Inc. & Tyson Fresh Meats Inc.).
Held the district court incorrectly dismissed gross negligence claims against executive and supervisor defendants; the estates adequately pleaded the three elements of coemployee gross negligence (actual knowledge of peril, knowledge that injury was probable, and conscious failure to avoid the peril).
Rejected the petition’s breach-of-duty claims against two occupational‐health staff defendants (Adams and Jones) as unchallenged on appeal.
Concluded the fraudulent-misrepresentation claims against coemployees could proceed (intentional torts fall outside IWCA exclusivity for coemployees) but not against employers.
Declined to affirm dismissal under Iowa’s Back-to-Business Act shield because plaintiffs had plausibly pleaded the “reckless disregard” exception.
Recanted prior dicta in Nelson v. Winnebago suggesting intentional-tort claims against employers survive IWCA exclusivity, reaffirming the statute’s plain text.

Analysis

1. Precedents Cited

Meade v. Christie (2022): Accept factual allegations as true in reviewing motions to dismiss.
Loew v. Menard (2024) & Tripp v. Scott Emergency Comm’n Ctr. (2022): Core policy of no-fault compensation in Iowa’s IWCA and exclusivity of remedies.
Walker v. Mlakar (1992) & Thompson v. Bohlkem (1981): Elements of coemployee gross negligence—actual knowledge of hazard, probable harm, and conscious indifference.
Johnson v. Interstate Power (1992): Gross negligence under § 85.20(2) demands a high evidentiary showing but is subject to ordinary notice-pleading.
Nelson v. Winnebago (2000): Previous discussion of intentional torts against employers—recanted here for conflicting with statutory text.
Wilson v. IBP, Inc. (1996) & Smith v. Iowa State Univ. (2014): Intentional torts by coemployees remain actionable despite IWCA’s exclusivity.
Beard v. Flying J (8th Cir. 2001): Battery claim by coemployee not preempted by Iowa law.

2. Legal Reasoning

The court parsed two distinct inquiries:

Pleading Sufficiency & Fair Notice
Under Iowa R. Civ. P. 1.421, a petition survives dismissal if it supplies factual allegations giving each defendant fair notice of the claims. Grouping defendants as “executive” or “supervisory” did not negate notice when the petition described each group’s alleged actions and duties.
Subject Matter Jurisdiction & IWCA Exclusivity
Iowa Code § 85.20(1)–(2) channels all employer–employee injury claims (fault or no-fault) into the workers’ compensation system, except for coemployee injuries caused by gross negligence. The court confirmed:
- Claims against employers (Tyson Foods entities) are exclusive to IWCA—no carve-out for intentional torts.
- Claims against coemployees can proceed if they plausibly allege gross negligence (§ 85.20(2)).

The court applied the gross-negligence elements from Walker and Thompson. Accepting plaintiffs’ factual allegations as true, it held they had alleged:

Actual knowledge of peril: Executives and supervisors tracked and were briefed on COVID-19 cases, knew plant conditions, misled workers with false statements, and isolated themselves off the plant floor.
Knowledge that injury was probable: Logs showed exponential absenteeism; masks and temperature checks were ineffective; supervisors disparaged COVID-19 yet maintained full capacity.
Conscious failure to avoid peril: Cancellation of safety meetings, misclassification of illnesses, continued operations despite health-department warnings, and delaying adoption of CDC guidance.

3. Impact on Future Cases

This decision will shape Iowa tort and workers’ compensation practice in several ways:

Plaintiffs may more confidently plead gross-negligence carve-out claims under § 85.20(2), even against high-level managers and supervisors, so long as they allege the three Walker elements.
Employers gain clarity that intentional tort and misrepresentation claims against them remain preempted—no judicially created exception outside the IWCA.
Future disputes will hone the line between employer liability (exclusive to IWCA) and coemployee tort liability.
The recantation of Nelson emphasizes strict textual statutory interpretation; courts will be reluctant to import exceptions not in the legislature’s text.
The decision also illustrates how COVID-19 liability-shield statutes (like Iowa Code § 686D.4) interact with general tort exceptions (reckless disregard under Restatement § 500), signaling robust judicial scrutiny of “pandemic immunity” provisions’ exceptions.

Complex Concepts Simplified

Workers’ Compensation Exclusivity: Iowa’s no-fault system bars most lawsuits by employees injured on the job. Instead, they collect fixed benefits from employers’ insurance.
Gross Negligence Exception (Iowa Code § 85.20(2)): A narrow carve-out allowing a worker—or heir—to sue a coemployee for “gross negligence”—defined as (1) knowing of the hazard, (2) knowing injury was probable, and (3) consciously ignoring it.
Subject Matter Jurisdiction vs. Pleading Sufficiency: Subject Matter Jurisdiction: The court’s legal power to hear a category of cases. If the IWCA says “only the workers’ compensation commissioner” can handle employer tort claims, district courts lack jurisdiction.
Pleading Sufficiency: Under notice-pleading, a petition must outline enough facts to inform each defendant of what happened and the nature of the claim.
Intentional Tort Claims Against Employers: Despite past dicta suggesting otherwise, this decision holds that Iowa statutes give employees injured at work no right to sue their own employer for intentional wrongdoing.
Back-to-Business Act (Iowa Code § 686D.4): Liability Shield: Premises owners (including workplaces) generally immune from COVID-19 exposure suits.
Exceptions: No shield if the owner (1) recklessly disregards a substantial & unnecessary risk (Restatement § 500), (2) harbors actual malice, or (3) intentionally exposes someone.

Conclusion

Key takeaways:

Iowa’s IWCA blocks direct tort suits against employers for workplace injuries—gross negligence or intentional—unless the legislature amends the statute.
Claims against coemployees for gross negligence survive if plaintiffs allege actual knowledge of the hazard, probable injury, and conscious indifference.
Intentional torts and fraudulent misrepresentation by coemployees likewise escape IWCA exclusivity; but those same claims against employers do not.
Pleading standards remain liberal: factual detail must supply fair notice, but group labels (e.g., “executive defendants”) do not doom a complaint.
The decision tightens Iowa’s COVID-19 immunity law, confirming that “reckless disregard” (per Restatement § 500) will be a threshold for liability.

Overall, Mehmedovic v. Tyson Foods establishes a precise roadmap for litigants navigating the interplay between workers’ compensation exclusivity, coemployee tort liability, and employer immunity in Iowa—reinforcing textual fidelity and careful factual pleading.