Iowa legislature, however, did not expressly include a hostile-work-environment provision in the ICRA. See Iowa Code § 216.6(1). Rather, the claim has been developed through our caselaw, beginning in 1990, based expressly on Title VII precedent. We first recognized a hostile-work-environment claim for sex discrimination in Lynch v. City of Des Moines, 454 N.W.2d 827, 833 (Iowa 1990), relying on Chauffeurs, Teamsters & Helpers, Local Union No. 238 v. Iowa Civil Rights Commission, 394 N.W.2d 375, 378 (Iowa 1986). Chauffeurs, in turn, delineated the elements of a racial hostile-work-environment harassment claim, relying on Henson v. City of Dundee, 682 F.2d 897, 909 (11th Cir. 1982), a Federal Title VII case, for the appropriate framework under the ICRA. Chauffeurs, 394 N.W.2d at 378, 381 (<HOLDING>). In Meritor Savings Bank, FSB v. Vinson, the
holding union members state law claims for defamation against union preempted holding union liable when members harassed africanamerican man with racial epithets and threatening actions recognizing that union members interests are adequately represented by the union recognizing union members vital concern in preserving jobs for union members holding that a rico action by union members was properly dismissed where any financial improprieties occurred with union funds and directly injured solely the union