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The case concerns the firing of Melissa Nelson, a former employee of James Knight, a dentist. Nelson was hired by Dr. Knight as a dental assistant about 10 years before the events took place and Knight admitted that she was a good dental assistant. A year and a half before Nelson was terminated, Knight began complaining to Nelson that her clothes were too tight and revealing. Around six months before her termination, Nelson and Knight began texting each other, concerning both personal and work related matters. Some texts between the two were suggestive and sexual but Nelson claims she saw Knight as a father figure/friend and didn’t take the texts seriously. Jeanne Knight (Dr. Knight’s wife) was also an employee of Dr. Knight’s practice and found out about the texting and confronted Knight, telling him to terminate Nelson.
The Knight’s consulted a pastor at their church who agreed with the decision to fire Nelson. On January 4, 2010, Knight called Nelson into his office after work and in the presence of a pastor, read from a prepared statement saying that their relationship had become bad for his family, and that it was in both of their best interests for them to stop working together. He then gave her a month’s severance pay and Nelson started crying. Knight met with Nelson’s husband later that evening to let him know that nothing was going on between them but he believed that an affair would result if he hadn’t fired Nelson. Knight replaced Nelson with another female dental assistant.
Nelson brought action against Dr. Knight in the Webster County District Court (Iowa) on the basis that Knight discriminated against her on the basis of sex (he wouldn’t have fired her if she was a male) but did not sexually harass her. Knight moved for summary judgment and the District Court sustained the motion in favor of Nelson’s employer, James Knight and she appealed to the Supreme Court of Iowa. The Supreme Court of Iowa affirmed the motion for summary judgment, as Knight’s actions did not amount to unlawful discrimination.
Melissa Nelson claimed that Knight unlawfully discriminated against her by terminating her employment because she was a woman and that he wouldn’t have fired her if she was a man. The issue is whether or not Knight unlawfully discriminated against Nelson. Looking at other cases and the case facts will help to understand the Supreme Court of Iowa’s ruling.
Unlawful discrimination is the main focus of the case as this is what Nelson specifically alleged that Knight did. Civil rights laws aim to have employees treated the same regardless of gender. The concurring opinion also addresses Employment at Will in that it can conflict with a sharper definition of discrimination because the ability for an employee to be terminated at any time without the employer having to prove a cause is still supported in our society.
Many of the cases mentioned help to differ Nelson’s situation as being completely lawful. Nelson’s responses to Knight’s position are that any discrimination because of the employer’s interest in the employee is discrimination, that there was no employee misconduct requirement, and that Knight shouldn’t be allowed to terminate an employee just because he thought he would sexually harass have an affair with her. Cases such as Bender v. Bellows & Bellows and Blackshear v. Interstate Brands Corp went against Nelson’s view that any termination based on a relationship would be unlawful because termination wouldn’t have happened if the employee was a different gender. Nelson also couldn’t prove unlawful discrimination because there was no pattern of this activity by Knight. Essentially, if Knight had fired multiple women before, it could be argued that he had something against women, but his wife’s objection to Nelson and Knight’s relationship made it clear that it was their relationship and not her gender that motivated the firing. Gender stereotypes are important and were a key factor in Lewis v. Heartland Inns of America where Lewis was fired from her motel desk job for not looking like a Midwestern girl. This case is based solely on stereotypes, which are not conducive to equal employment, and not a relationship between employer and employee. There is no stereotyping in Nelson v. Knight and the termination is based on the two’s relationship. Nelson’s third point is that Knight can’t fire her because he thought he might harass her in the future but her termination did not bring any of the hostility associated with sexual harassment and would not be considered unlawful even if it was unfair.
Nelson was in the wrong in this case because she couldn’t prove any of the normal features of unlawful discrimination. Even though her termination may have been unfair, it is still legal because Knight didn’t have any reason to fire her based on her gender. The termination was brought about by his wife’s objection to the relationship, not to Nelson’s gender. Nelson’s three responses to Knight’s position have many flaws demonstrated through other cases.
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