Court of Appeals Issues Decision on Exclusion of Evidentiary Items

In Hyten v. HNI Corporation, No. 16-1454 (Iowa App. Jan. 10, 2018), the Court of Appeals addressed the exclusion of evidence concerning the delay in receipt of workers' compensation benefits, the safety of plaintiff's work assignment and the company's waiver of notice defense.  The court affirms the exclusion of evidence on all accounts.

Plaintiff suffered a carpal tunnel injury.  Partially as a result of that injury, claimant had unexcused absences which ultimately led to her dismissal from employment.  Claimant filed suit against the employer, alleging she had been terminated in violation of public policy for seeking workers' compensation benefits.  After trial, the jury returned a verdict in favor of the employer.

Plaintiff alleged on appeal that the court erred in excluding evidence.  The court notes that relevant evidence may be excluded if its probative value is substantially outweighed by the danger of unfair prejudice, confusion of the issues or misleading the jury.  A great deal of leeway if provided the trial court in making this judgment call.  The court found that plaintiff failed to demonstrate that her substantial rights were affected by the exclusion of any evidence.  The court goes on to conclude that the evidentiary issues were a "mere subterfuge" and that the defect in the case was the lack of any evidence casting doubt on the employer's legitimate reason for the termination of employment.  The judgment of the district court was affirmed.