Justia Iowa Supreme Court Opinion Summaries

The case involves William and Mary Goche, LLC; Global Assets, LLC; and Joseph Goche (collectively “Goche”), who own land in three different drainage districts in Kossuth County. The Kossuth County Board of Supervisors administers these districts. Goche alleged that the board of supervisors administered the districts in a way that specifically caused him harm. He brought a suit against the board of supervisors, current and former supervisors, and engineering firm Bolton & Menk, Inc., asserting claims for breach of fiduciary duty and seeking punitive damages for the defendants’ alleged breaches.The defendants moved to dismiss the claims, arguing that they owed no fiduciary duty to Goche as an individual landowner within the drainage districts. The district court granted the motions, leading to Goche's appeal. However, in the appeal, Goche abandoned his breach of fiduciary duty claims and instead contended that he is entitled to proceed against the defendants on a standalone cause of action for punitive damages.The Supreme Court of Iowa disagreed with Goche's argument. The court clarified that punitive damages are a form of damages available to a plaintiff incidental to a recognized cause of action and not a freestanding cause of action. The court also noted that Goche conceded that the defendants owed him no fiduciary duty in the administration of the drainage districts or in providing engineering services to the districts. Therefore, the court affirmed the judgment of the district court, dismissing Goche's claims. View "William and Mary Goche, LLC v. Kossuth County Board of Supervisors in their capacity as Trustees of Drainage Districts 4, 18, and 80" on Justia Law

Jesse McCollaugh was found guilty of child exploitation after his wife discovered videos on his phone of her 15-year-old sister using the bathroom, which McCollaugh had secretly recorded. The videos showed the minor partially nude, unaware she was being filmed. McCollaugh admitted to recording the videos and having a sexual problem. He was charged with one count of sexual exploitation of a minor, to which he pleaded not guilty. After a bench trial, the district court found McCollaugh guilty and sentenced him to a prison term not exceeding two years, and required him to register as a sex offender.Before the Supreme Court of Iowa, McCollaugh appealed his conviction, arguing that the evidence was insufficient to support his conviction because it failed to establish that the minor had the purpose of engaging in nudity to arouse or satisfy the sexual desires of a person who may view the visual depiction. The Supreme Court disagreed with McCollaugh's interpretation of the statute, stating that the relevant "purpose" that the State must prove is identified after the word "purpose" in the definition, not before. The court held that the State must prove the purpose of purchasing or possessing a visual depiction of the nude minor—not the minor’s purpose in being nude. The court found sufficient evidence to prove McCollaugh’s purpose for taking the videos was for his sexual gratification and affirmed his conviction. McCollaugh also argued that the district court relied on an improper factor in its sentencing order, but the Supreme Court found no evidence that the district court relied on the improper factor and affirmed the sentence. View "State v. McCollaugh" on Justia Law

The defendant, Christopher James Wilson, was charged with two counts of indecent exposure after he was seen masturbating in public by two women, E.H. and T.A., at a gas station. Wilson followed the women to another location where he continued his actions. He was subsequently arrested and charged. After a jury trial, he was convicted on both counts and sentenced to an enhanced sentence under Iowa Code section 901A.2(1) to an indeterminate prison term of two years for the first count and an indeterminate prison term of two years for the second count. The sentence for count one was ordered to run consecutively to the sentence for count two.Wilson appealed his conviction and sentence, arguing that the unit of prosecution for indecent exposure is per exposure, not per viewer. Therefore, he contended that there was insufficient evidence to convict him on two separate counts of indecent exposure. He also argued that the district court did not provide sufficient reasons for imposing a consecutive sentence under Iowa Rule of Criminal Procedure 2.23(3)(d).The Supreme Court of Iowa affirmed the lower court's decision. The court held that the unit of prosecution for indecent exposure is one count per viewer, not one count per exposure. Therefore, there was sufficient evidence to support a conviction on two counts of indecent exposure. The court also found that the district court provided sufficient reasoning for imposing a consecutive sentence. The court noted that the district court's reasoning for imposing consecutive sentences may be the same reasons the court relied on for the imposition of incarceration. The court concluded that the district court's statement that the only appropriate sentence was to send Wilson to prison for as long of a period of time as possible implied that the sentences should run consecutively. View "State v. Wilson" on Justia Law

The case involves Clayton Curtis Brown, who was convicted of possession of a firearm as a felon, aggravated eluding, and driving while barred. The charges stemmed from an incident where Brown eluded a police officer's attempt to initiate a traffic stop. The officer later found the car abandoned and discovered a loaded handgun under the driver's seat and ammunition in the center console and under the front passenger seat. Brown's personal items were also found in the car.The Iowa Court of Appeals reversed Brown's convictions for possession of a firearm as a felon and aggravated eluding, concluding there was insufficient evidence to show that Brown knowingly possessed the handgun. Brown also contested the sufficiency of the evidence to support his convictions, arguing that the State failed to prove his identity as the driver of the car that eluded the officer.The Supreme Court of Iowa disagreed with the lower court's decision. The court held that the State's evidence, including the officer's testimony, the location of the firearm, and the presence of Brown's personal effects in the car, was sufficient to support the jury's conclusion that Brown had constructive possession of the firearm. The court also found that there was sufficient evidence to support the jury's determination that Brown was driving the car when it eluded the officer. Therefore, the Supreme Court of Iowa vacated the portion of the court of appeals decision reversing those convictions and affirmed the district court judgment in full. View "State of Iowa v. Brown" on Justia Law

This case involves a dispute within the Hora family over the operation of their family farm, Hora Farms, Inc. (HFI). Two brothers, Brian and Gregg Hora, brought a derivative action as minority shareholders against their father, Keith Hora, and brother, Kurt Hora, alleging breach of fiduciary duties based on their management of the farming operation. The brothers claimed that Keith and Kurt mismanaged the farm's operations, resulting in financial losses and unaccounted-for corn inventory. They also alleged that Keith used HFI's credit card for personal expenses.The case was initially heard in the Iowa District Court, where it was determined that neither Keith nor Kurt breached fiduciary duties owed to the corporation. The court found that the brothers' concerns were primarily related to poor recordkeeping and longstanding business practices, rather than intentional wrongdoing. The court also concluded that Keith's use of the corporate credit card for personal expenses was part of his compensation and was fair to HFI.The brothers appealed the decision to the Iowa Court of Appeals, which reversed the district court's decision on two specific issues. The appellate court concluded that Keith engaged in self-dealing by using HFI's credit card for personal expenses and that he enabled Kurt to misappropriate corn from the farm. The court also found that Kurt breached his duty to HFI by misappropriating corn for his personal use.The case was then reviewed by the Supreme Court of Iowa. The court vacated the decision of the Court of Appeals and affirmed the judgment of the District Court. The Supreme Court found that Kurt, as an employee and not an officer or director of HFI, did not owe fiduciary duties to the corporation. The court also concluded that Keith did not violate any fiduciary duties owed to HFI in his oversight of Kurt. The court determined that the brothers failed to prove that Keith or Kurt violated fiduciary duties owed to HFI. View "Hora v. Hora" on Justia Law

The case involves Tracy White, an employee of the Iowa Department of Human Services (DHS), who filed a lawsuit against the State of Iowa and DHS under the Iowa Civil Rights Act (ICRA) alleging a hostile work environment. White's complaints about her supervisor led to his termination, but she remained employed at the agency. The jury awarded her $260,000 for past emotional distress and $530,000 for future emotional distress. The State appealed, arguing that the evidence was insufficient to prove White's hostile work environment claim, that the district court erred by admitting certain evidence and incorrectly instructing the jury, and that the future emotional distress damages were excessive.The district court had denied the State's pretrial motion to exclude certain evidence, referred to as "me too" evidence, as unduly prejudicial. This evidence consisted of reports of alleged discrimination experienced by other employees, which White, as a supervisor, had received and relied on to support her own hostile work environment claim. The State argued that such evidence, of which White was unaware, could not prove that she personally experienced a hostile work environment.The Supreme Court of Iowa agreed with the State, concluding that the harassment White personally experienced was not objectively severe or pervasive enough to alter the terms or conditions of her employment. The court held that the district court erred by denying the State's motion for judgment notwithstanding the verdict (JNOV). The court reversed the judgment for White and remanded the case for entry of an order granting the State's motion for JNOV. View "White v. State" on Justia Law

The Supreme Court of Iowa ruled in a case involving an individual, Faron Alan Starr, who was arrested and denied his request to call a family member to get an attorney. Starr was suspected of an assault and stealing two firearms. After his arrest, he was taken to a police station where he initially equivocated about speaking to the police without an attorney. However, he later requested to call his father to obtain a lawyer, which was refused by the police officer. The officer proceeded to question Starr about his actions and whereabouts of the stolen firearms.Starr was charged with multiple offenses, and he subsequently filed a motion to suppress his statements and any evidence derived from them, asserting violations of his constitutional and statutory rights. The district court granted the motion, finding a violation of Starr's rights under Iowa Code section 804.20, which mandates that an arrested person be allowed to call and consult a family member or an attorney without unnecessary delay upon arrival at the place of detention.The Supreme Court of Iowa affirmed the lower court's decision, holding that while public safety concerns could potentially justify a delay in honoring an arrested person's rights under Iowa Code section 804.20, the circumstances of this case did not warrant such a delay. The court noted that the police did not address the issue of the missing firearms until nearly two hours after Starr was taken into custody for questioning at the police station. Therefore, the delay in permitting Starr to call a family member was deemed unnecessary. View "State of Iowa v. Starr" on Justia Law

The Supreme Court of Iowa upheld the decision of the Iowa Court of Appeals and the district court that sentenced a recidivist drug offender, Jacob Lee Goble, to an indeterminate prison sentence of up to five years. Goble, who had pleaded guilty to a class "D" felony, appealed on the grounds that the sentencing court improperly considered parole as a factor in determining his sentence. The court mentioned parole once in the context of Goble's need for a structured setting for his rehabilitation and protection of the community.The Supreme Court of Iowa, however, found that the mention of parole in this context was not inappropriate. The court stated that the district court did nothing to circumvent the parole board’s discretion in determining the release date, and its reference to parole is authorized by statute. Goble’s sentence was therefore affirmed, and his claim that the sentencing court relied on an improper factor by mentioning parole was rejected.The court also differentiated this case from precedent where it was held impermissible for the district court to impose a longer prison sentence for the purpose of delaying the defendant’s release on parole. In this case, the district court’s choice was limited to imposing a five-year indeterminate sentence with immediate parole eligibility or suspending that sentence and placing Goble on probation. The court concluded that the district court did not impose a longer sentence to circumvent the parole board’s discretion. View "State of Iowa v. Goble" on Justia Law

In the Supreme Court of Iowa, a case involved Bridgestone Americas, Inc., and Old Republic Insurance Company, appellants, against Charles Anderson, appellee. Anderson, an employee of Bridgestone, reported a right shoulder injury and a right arm injury after decades of manual labor. He pursued a workers’ compensation action, which was awarded by the deputy workers’ compensation commissioner and affirmed by the workers’ compensation commissioner. The employer sought judicial review, and the district court affirmed the commissioner’s decision.The employer appealed, posing three questions: whether the injuries were compensable, whether they should be compensated as unscheduled injuries under Iowa Code section 85.34(2)(v), and whether the compensation was calculated correctly. The court concluded that the injuries were compensable but should be classified as scheduled injuries under Iowa Code section 85.34(2), paragraphs (m) and (n), not unscheduled injuries.The court affirmed the district court’s decision in part, reversed in part, and remanded the case for determination of compensation for the employee's scheduled injuries, meaning compensation should be based on the extent to which a body part's function has been impaired, not the employee's loss of earning capacity. View "Bridgestone Americas, Inc. v. Anderson" on Justia Law

The case at hand arose from the appeal by Scott Randolph Luke, who was convicted of domestic abuse assault while on probation for two previous domestic abuse assaults. The district court sentenced him to two years in prison for the latter offense, revoked his probation, and ordered his sentences to be served consecutively. Luke challenged the sentence, contending that the district court abused its discretion and failed to provide reasons for the consecutive sentences.The Court of Appeals affirmed the decision. It concluded that the district court did not abuse its discretion in imposing a prison term for the latest offense. It also determined, though narrowly, that the district court's explanation for the consecutive sentences was sufficient.Upon further review, the Supreme Court of Iowa also affirmed the decisions of the lower courts. The Supreme Court held that the district court had given a detailed and personalized explanation for why it was sending Luke to prison. Although the district court did not explicitly discuss reasons for running that sentence consecutively to the sentence imposed on the probation revocation, it addressed that omission in the written sentencing order. The Supreme Court found no error in Luke's sentence. View "State of Iowa v. Luke" on Justia Law