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Supervisors Individually Liable Under The Iowa Civil Rights Act, Tory L. Lucas

Faculty Publications and Presentations

Using federal law, Title VII of the Civil Rights Act of 1964, as a model, the State of Iowa enacted the Iowa Civil Rights Act of 1965 (ICRA) to strengthen anti-discrimination laws on a state level. But the ICRA was not simply a carbon copy of Title VII; instead, the ICRA contained its own unique language, which provided state-specific distinctions to further the interests of Iowans. For thirty-four years, it was an open question as to whether the ICRA authorized individual liability against supervisory employees — as opposed to only employers — for unlawful discrimination. In Vivian v. Madison, 601 …