Refining Iowa’s “Honest-Belief” Rule and the Disability Threshold under the ICRA:
A Commentary on McClure v. Corteva Agriscience (Supreme Court of Iowa, 2025)

1. Introduction

The Supreme Court of Iowa’s decision in Darrell Jeffrey McClure v. E.I. du Pont de Nemours and Company d/b/a Corteva Agriscience, No. 23-0628 (June 20 2025), represents a significant clarification of two recurring themes in Iowa employment litigation:

• the contours of the “honest-belief” rule when employers defend discharge decisions, and
• the evidentiary threshold an employee must meet to show a qualifying disability—particularly when the only allegedly limited activity is “working”—under the Iowa Civil Rights Act (ICRA), Iowa Code ch. 216.

The litigation arose from the termination of Darrell McClure, a 36-year warehouse veteran who alleged disability and age discrimination after repeated safety violations culminated in his dismissal. The district court granted summary judgment for the employer, Corteva Agriscience. The Court of Appeals revived the age and disability claims, but the Supreme Court reversed, reinstating the district court’s judgment. Justice May authored the unanimous opinion; Justice McDonald concurred separately to question the continued usefulness of the federal McDonnell Douglas burden-shifting framework in Iowa practice.

2. Summary of the Judgment

Key holdings include:

• Disability Claim. McClure failed to raise a genuine issue that his heart-related restrictions “substantially limited” a major life activity. A limitation to day shifts does not, without more, demonstrate substantial limitation in the activity of working across a broad range of jobs. Nor was there evidence Corteva perceived him as disabled based on myths or stereotypes.
• Age Claim. Assuming a prima facie case, Corteva articulated a legitimate non-discriminatory reason—McClure’s safety record—and McClure did not create a jury question that this reason was pretextual. The Court applied the “honest-belief” rule from Feeback v. Swift Pork Co. (2023) and held McClure offered no evidence that Corteva did not honestly believe he was a safety risk.
• Comparator & Atmosphere Evidence. Allegedly more lenient treatment of two younger workers and anecdotal testimony from older employees were insufficient; the proposed comparators were not “similarly situated in all relevant respects,” and the atmosphere evidence lacked temporal, decisional, and factual proximity.
• Procedural Note. The Court left intact the Court of Appeals’ earlier affirmance of summary judgment on retaliation and hostile-work-environment claims, as those issues were not before it on further review.
• Concurring View. Justice McDonald questioned the compatibility of McDonnell Douglas with Iowa’s summary-judgment rule, inviting reconsideration in a future case.

3. Analysis

3.1 Precedents Cited

• Feeback v. Swift Pork Co., 988 N.W.2d 340 (Iowa 2023) – Adopted the “honest-belief” doctrine. McClure is its first major application by the Supreme Court, illustrating how the rule functions where safety infractions are undisputed but their gravity is debated.
• Goodpaster v. Schwan’s Home Service, Inc., 849 N.W.2d 1 (Iowa 2014) – Articulated the definition of “disability” and the standard for “working” as a major life activity; relied on in rejecting McClure’s claim.
• Probasco v. Iowa Civil Rights Comm’n, 420 N.W.2d 432 (Iowa 1988), and Bearshield v. John Morrell & Co., 570 N.W.2d 915 (Iowa 1997) – Earlier Iowa cases defining substantial limitation in working; reaffirmed as still viable post-ADAAA.
• Federal guidance, including Woolf v. Strada, 949 F.3d 89 (2d Cir. 2020) and other post-ADAAA circuit cases, used to show that the ADA Amendments Act did not dilute the “class or broad range of jobs” test for working.
• McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) – The burden-shifting rubric applied by the majority; critiqued by the concurrence.

3.2 Legal Reasoning

3.2.1 Disability Analysis

The Court started (and ended) its disability inquiry with the prima-facie element: existence of a disability.

• Substantial Limitation. Under Iowa Admin. Code r. 161—8.26 and Probasco, an impairment must limit a class or broad range of jobs, not a single job or shift pattern. McClure’s evidence showed only an inability to work consecutive overnight shifts.
• ADAAA Not Controlling. Although federal law broadened coverage, courts nationwide still require evidence that the plaintiff is precluded from a class of jobs. The Iowa statute remains unchanged; thus, federal post-ADAAA cases were instructive rather than limiting.
• Perceived Disability. Vincent v. Four M Paper Corp. restricts “regarded-as” claims to situations involving myths, fears, or stereotypes. Corteva’s insistence on updated doctor’s notes and discipline for safety violations showed individualized assessment, not stereotype-based decisions.

3.2.2 Age Analysis & the Honest-Belief Rule

At the second and third steps of McDonnell Douglas, the Court assumed McClure’s prima facie case but held he failed to rebut Corteva’s legitimate explanation.

• Employer’s Rationale. Documented safety issues: a loading-dock pull-away, a high-impact forklift crash, and a near-miss causing automatic lockout—plus data showing McClure’s forklift had far more “impacts” than peers.
• Honest-Belief Test. Derived from Feeback: the dispositive question is the employer’s good-faith belief, not the objective correctness of the underlying facts. McClure’s disputes about mechanical malfunction, sensor accuracy, or comparators did not undermine Corteva’s belief.
• Comparator Rigor. The Court required proof that proposed comparators shared “all relevant respects,” including similar disciplinary history and range of infractions. Younger co-workers involved in isolated incidents, without extensive safety histories, were not similarly situated.
• Discriminatory Atmosphere. Anecdotal testimony by other older workers lacked proximity to McClure’s decision-makers, time frame, and factual match; portions were speculative and thus inadmissible.

3.2.3 Procedural & Methodological Points

• The Court limited its review to issues raised in Corteva’s application, leaving untouched appellate findings on retaliation and hostile-environment claims.
• Justice McDonald’s concurrence suggests McDonnell Douglas may be incompatible with Iowa R. Civ. P. 1.981(3) and invites future abandonment of the burden-shifting approach at summary judgment.

3.3 Potential Impact

The decision will likely reshape Iowa employment litigation in several ways:

• Honest-Belief Doctrine Entrenchment. Trial courts now have explicit, high-court guidance on applying Feeback. Employees challenging safety-based terminations must produce evidence that an employer did not honestly believe the alleged misconduct, not merely argue the conduct was innocent or excusable.
• Disability Claims Focused on “Working.” Plaintiffs who rely solely on work-schedule restrictions now know they must provide labor-market evidence (e.g., vocational expert testimony or job-class data) showing exclusion from a broad set of jobs, or the claim will fail at prima facie stage.
• Comparator Evidence Stringency. The case underscores that isolated, incident-specific comparisons will rarely suffice without matching disciplinary history and job circumstances.
• Atmosphere/Anecdotal Evidence. Parties should be prepared to show proximity (same managers, temporal closeness) and factual similarity for “pattern or practice” anecdotes to carry weight.
• Doctrinal Crossroads for McDonnell Douglas. The concurrence may spark litigant invitations—and possibly a future majority—to abandon burden shifting in favor of a straightforward summary-judgment inquiry.

4. Complex Concepts Simplified

Honest-Belief Rule

An employer is not liable for discrimination if it fired an employee based on a mistaken but honest belief in the employee’s misconduct. The plaintiff must show dishonesty in the belief, not mere error.

Substantial Limitation in “Working”

To prove disability predicated on working, an employee must show an inability to perform a large class or broad range of jobs compared to similarly trained individuals, not just one job, employer, or shift.

Comparator Evidence

Evidence comparing the plaintiff to other employees to show disparate treatment. Courts require near-identical relevant circumstances: same supervisor, standards, infractions, and disciplinary history.

Discriminatory Atmosphere Evidence

Statements or conduct suggesting bias in the workplace. To be probative, it must be linked to the plaintiff’s decision-makers, time frame, and circumstances.

McDonnell Douglas Framework

A three-step method: (1) employee’s prima facie case; (2) employer’s legitimate reason; (3) employee proves pretext or mixed motive. Justice McDonald’s concurrence questions its necessity in Iowa.

5. Conclusion

McClure v. Corteva Agriscience cements the “honest-belief” rule as a powerful defense when employers act on documented safety concerns and clarifies that schedule-based limitations rarely meet Iowa’s definition of disability absent broader employment restrictions. The Court also tightened the standards for comparator and atmosphere evidence, signaling that speculative or loosely related anecdotes are insufficient to survive summary judgment. Finally, the concurrence foreshadows potential doctrinal change regarding the venerable—but increasingly criticized—McDonnell Douglas test. Practitioners on both sides of the bar should recalibrate their litigation strategies accordingly.

© 2025 – Analytical commentary authored for educational purposes.