Miss a notice step? An arbitrator might reverse your termination – here's what Iowa said
On December 3, 2025, the Iowa Court of Appeals upheld an arbitration award reinstating a Colfax officer, spotlighting collective bargaining agreement (CBA) and pre-termination notice.
The Court of Appeals of Iowa affirmed a district court ruling that kept in place an arbitrator’s award reinstating Police Officer Andrea Clark after the City of Colfax fired her. The case turned on the basics: what the collective bargaining agreement requires before severe discipline, and how much leeway arbitrators have when they apply those rules.
Here’s what happened. In April 2023, Colfax’s police chief recommended terminating Clark, and the city council agreed. Teamsters Local Union 238 grieved the decision and took the matter to binding arbitration, as the contract allowed. In January 2024, the arbitrator sided with the union, concluding termination was too harsh for the alleged rule violations and that Clark wasn’t given a meaningful chance to respond before she was shown the door. The arbitrator also read the agreement as setting out a step-by-step discipline structure – oral warning, written reprimand, suspension, demotion, discharge – with room to skip steps only if the offense was truly serious.
The city moved to vacate the award. The district court refused, granting summary judgment to the union. On appeal, the Court of Appeals affirmed. The court didn’t relitigate the facts; instead, it stressed the narrow role courts play in reviewing arbitration awards. Iowa law favors arbitration and limits second-guessing. If the arbitrator stays within the four corners of the contract and the state’s arbitration statute, the award stands – even if a court might have reached a different result.
The court also addressed the city’s argument that the arbitrator imported sweeping “just cause” or due process standards not found in the agreement. The opinion made a simpler point: the agreement itself required that employees be told promptly and specifically about alleged rule violations and, where appropriate, given a chance to correct deficiencies before moving to harsher penalties. On this record, the arbitrator found that didn’t happen and that termination overshot what the contract allowed. That was within her authority.
For HR leaders, especially in unionized and public-sector workplaces, the message is practical. The progressive discipline ladder in a collective bargaining agreement isn’t window dressing. If you plan to skip steps, be prepared to show why the conduct meets the contract’s seriousness exception. Before moving to termination, make sure the employee received specific notice of the issues and a real opportunity to respond. Document the discussion, the expectations, and any chance to improve. If your process is thin, an arbitrator can unwind a discharge – and courts are unlikely to save it later.
It’s also a reminder to front-load your case. Arbitration is often the final word. Iowa’s courts reiterated they won’t reweigh evidence or fix process problems after the fact. Your best shot is at the arbitration hearing, backed by a clean, contract-faithful process.
The bottom line: the award reinstating Clark stands. The city’s termination didn’t clear the contractual bar, and the arbitrator’s call controls. For HR teams managing CBAs, that’s a clear signal to align discipline decisions tightly with the agreement and to treat pre-termination notice and an opportunity to be heard as nonnegotiable steps.
