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Red Deer v. Cherokee County, Iowa

United States District Court for the Northern District of Iowa
183 F.R.D. 642 (N.D. Iowa 1999)


Red Deer (plaintiff) was a female Native American applicant for a deputy sheriff position. Red Deer was not hired, and she sued Cherokee County, Iowa (the County) (defendant) for discrimination based on age, sex, and race, as well as retaliation. Subsequently, the County acquired evidence that Red Deer had made misrepresentations about her reasons for leaving two earlier jobs in her application. Red Deer filed a motion in limine to exclude the after-acquired evidence, arguing that the County could not have relied on that evidence in making its decision not to hire her. The County objected, arguing the misrepresentations constituted dishonest conduct that would be a reason to terminate a deputy sheriff or refuse to hire Red Deer in the first place. The United States District Court for the Northern District of Iowa considered the motion.

Rule of Law


Holding and Reasoning (Bennett, J.)

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