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Dyer v. National By-Products Inc.

Supreme Court of Iowa
380 N.W.2d 732 (Iowa 1986)


Facts

Dale Dyer (plaintiff) worked for National By-Products Inc. (National) (defendant) as a foreman. In 1981, Dyer lost a foot in a workplace accident. Dyer was given a leave of absence with pay until he returned to work in August 1982. Dyer was laid off the following March. Dyer sued for breach of an oral contract, claiming that National had promised him lifetime employment in exchange for his agreement not to litigate his claim for personal injury. National denied the agreement. After discovery, National moved for summary judgment. The trial court granted the motion, holding that (1) Dyer made no reciprocal promise to work for National for life and (2) Dyer did not forbear from bringing a legitimate claim because workers’ compensation was his sole remedy for the injury. Dyer appealed to the Iowa Supreme Court, arguing that his forbearance from bringing what he reasonably and in good faith believed to be a valid claim was sufficient consideration for National’s promise of lifetime employment.

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Issue

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Holding and Reasoning (Schultz, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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