Joanne Cote v. Derby Insurance Agency, Inc., an Iowa Corporation, and Kevin Dorn, Individually

WATERMAN, Justice.

In this appeal, we must decide whether a small business that incorporates thereby loses the family-member exception to the employee-numerosity requirement in the Iowa Civil Rights Act (ICRA). The ICRA does not apply to "[a]ny employer who regularly employs less than four individuals. ... [I]ndividuals who are members of the employer's family shall not be counted as employees." Iowa Code § 216.6 (6)( a ) (2011). The plaintiff worked at a small insurance agency and alleges she was sexually harassed by her supervisor, the sole owner's husband. The defendant insurance agency, a…