Differences Between the ICRA and Federal Civil Rights Statutes. As pointed out in Pippen, there is also an important structural difference between the ICRA and various civil rights statutes. See 854 N.W.2d at 28. The ICRA is a unified statute. In contrast,'the federal civil rights regime is more fragmented. See Age Discrimination in Employment Act of 1967, 29 U.S.C. § 623; Civil Rights Act of 1964, 42 U.S.C. § 2000e-2 (Title VII); American with Disabilities Act of 1990, 42 U.S.C. § 12112. Thus, while the federal courts have developed different tests for different causes of action under different statutes, the Iowa statute generally calls out for a singular, unified approach. See, e.g., Gross v. FBL Fin. Servs., Inc., 557 U.S. 167, 176-78, 129 S.Ct. 2343, 2350-51, 174 L.Ed.2d 119 (2009) (<HOLDING>). It would be very difficult to come to the
recognizing that standards of liability under title vi are different from traditional agency principles or the general standards of liability under title vii recognizing ageplusgender discrimination claim when complaint brought claims under adea and title vii holding the title vii mixedmotive theory does not apply to adea claims holding that title vii and adea causation standards are different holding that individual employees are not liable under title vii