Justia Iowa Supreme Court Opinion Summaries

A Florida resident who worked as an independent contractor driver for an Indiana-based transportation company initiated a lawsuit in the United States District Court for the Northern District of Iowa, alleging violations of Iowa’s business opportunity promotions statutes. The Indiana company, registered to do business in Iowa as a foreign corporation and having appointed an agent for service of process as required by Iowa law, argued that it had no substantial presence or employees in Iowa. The plaintiff asserted that the company’s registration and agent appointment constituted consent to personal jurisdiction, among other arguments.The United States District Court for the Northern District of Iowa denied the Indiana company’s motion to dismiss for lack of personal jurisdiction. It concluded that, under Iowa law, a foreign corporation consents to personal jurisdiction by registering to do business in Iowa and designating an agent for service. However, recognizing the absence of controlling Iowa precedent on this issue, the federal court certified a question of state law to the Iowa Supreme Court for resolution.The Iowa Supreme Court answered the certified question and held that, under Iowa law, a foreign corporation does not consent to personal jurisdiction merely by registering to do business in Iowa, appointing an agent for service of process, or receiving service through that agent. The court determined that Iowa Code chapter 490 does not require foreign corporations to consent to personal jurisdiction as a condition of registration or agent appointment, and declined to interpret the statute as implicitly imposing such consent. The Iowa Supreme Court’s answer was in the negative, clarifying that registration and agent appointment do not constitute consent to personal jurisdiction in Iowa. View "Kelchner v. CRST Expedited, Inc." on Justia Law

A joint drainage district, managed by the boards of supervisors for Floyd and Cerro Gordo Counties, sought to require a railroad company to install a new, larger drainage culvert through a railroad embankment to improve water flow and address aging infrastructure. The existing culvert, over a century old, was deteriorating and positioned too high to drain water effectively. The proposed construction involved a trenchless “jack and bore” method designed to avoid any interruption to rail service. The railroad company objected, arguing that federal law preempted state drainage law and that the construction would jeopardize railroad operations.After a remand from the Surface Transportation Board, the Iowa District Court for Floyd County conducted a bench trial and concluded that federal law—the Interstate Commerce Commission Termination Act—preempted the drainage district’s authority. The district court found that the proposed installation posed risks to rail operations and issued a writ of mandamus preventing the project. The Iowa Court of Appeals affirmed this decision.On further review, the Iowa Supreme Court held that the federal statute did not categorically preempt state drainage law in this context and that preemption would only apply if the project imposed more than incidental interference with rail operations. After a de novo review of the evidence, the court determined that the proposed culvert installation would have only incidental effects on rail transportation and that the railroad had not met its burden of showing unreasonable interference. The Iowa Supreme Court vacated the Court of Appeals’ decision, reversed the district court’s judgment, and remanded the case for entry of judgment in favor of the drainage district, dissolving the writ of mandamus. View "Iowa Northern Railway Company v. Floyd County Board of Supervisors" on Justia Law

A married couple accumulated significant assets during a nineteen-year marriage, including a successful business started by the husband prior to the marriage. The wife, an accountant, worked for the business during the marriage but let her CPA license lapse. Upon dissolution of the marriage, the husband retained ownership of the business, and the wife received a large cash equalization payment to offset the division of assets. The wife’s request for substantial monthly spousal support was based on the disparity between her potential income and the husband’s anticipated future income from the business.The Iowa District Court for Audubon County presided over the dissolution trial. After valuing the assets, it awarded the husband the business and other properties, and the wife the lake house and a cash equalization payment exceeding $3 million. The court concluded the wife’s ability to earn investment income from the equalization payment, combined with her earning capacity as an accountant, was sufficient for her to maintain her marital standard of living. It denied her request for traditional spousal support. On appeal, the Iowa Court of Appeals affirmed the property division but modified the decree to award the wife $3,500 per month in spousal support, reasoning that the income gap and business growth potential justified support.The Supreme Court of Iowa reviewed both parties’ challenges. It adopted the Court of Appeals’ analysis on property valuation but vacated the appellate court’s award of spousal support. The Supreme Court held that when a property division provides the spouse seeking support with sufficient assets and income to maintain her predivorce lifestyle, an additional award of traditional spousal support is not warranted. The focus is on need, not income equalization or duplicating business value already considered in property division. The district court’s denial of spousal support was affirmed. View "In re the Marriage of Owen and Brinker" on Justia Law

A divorced couple with two children entered into a stipulation to resolve their dissolution proceeding, agreeing to joint legal custody, physical care with the mother, and visitation for the father. The stipulation also detailed the children’s school arrangements. Shortly after the decree was entered, the father expressed regret about its terms and, just fifty-one days later, filed a petition to modify the custody, care, visitation, and support arrangements. During discovery, the father admitted there had been no material change in circumstances since the decree, conceding the petition was motivated by dissatisfaction with the decree’s terms rather than new facts.The Iowa District Court for Delaware County found that the petition was filed in violation of Iowa Rule of Civil Procedure 1.413, which requires pleadings to be well-grounded in fact and not filed for improper purposes. The court found the father’s claims of changed circumstances not credible and concluded the petition was an improper attempt to relitigate the decree. As sanctions, the district court dismissed the petition and ordered the father to pay the mother’s attorney fees. On appeal, the Iowa Court of Appeals affirmed the finding that the rule was violated and upheld the monetary sanction but reversed the dismissal sanction, holding that dismissal was not an appropriate remedy under rule 1.413.On further review, the Supreme Court of Iowa addressed only whether rule 1.413 authorizes dismissal as a sanction. The court held that, while the rule allows for various sanctions, including attorney fees, it does not itself provide an independent basis for dismissal of a petition. The court affirmed the imposition of attorney fees but reversed the district court’s dismissal, remanding the case for further proceedings consistent with its opinion. View "In re the Marriage Kraus" on Justia Law

The case centers on a dispute involving the Iowa Auditor of State’s authority to subpoena records from the City of Davenport, including documents claimed to be protected by the attorney–client privilege, in connection with a reaudit of city settlement payments. The city provided some documents but refused to produce others, asserting privilege. The Auditor sought enforcement of the subpoena, while the city moved to modify it. The controversy escalated due to public interest in the timing and propriety of the city’s settlements and the Auditor’s investigation into their legality.The Iowa District Court for Scott County ruled in favor of the Auditor, holding that Iowa law gave the Auditor broad access to city records, including attorney–client privileged materials, except for attorney work product, and ordered an in camera review of the contested documents. The city appealed, arguing the Auditor did not have authority to access attorney–client communications. During the appeal, the Auditor and the Iowa Attorney General disagreed fundamentally about the scope of the Auditor’s subpoena power and whether to defend the district court’s ruling. The Attorney General declined to make arguments supporting the Auditor’s position, citing broader state interests and a perceived conflict of interest.The Supreme Court of Iowa determined that, due to this conflict of interest, the Auditor may be represented by his own general counsel, rather than the Attorney General. The court reasoned that the Attorney General’s duties are materially limited by her responsibilities to other state agencies, constituting a conflict under Iowa’s professional conduct rules. The court further held that the Auditor does not need executive council approval to be represented by in-house counsel, as statutory provisions requiring such approval apply only to hiring outside counsel at state expense. The Attorney General was permitted to participate as amicus curiae. View "City of Davenport v. Office of the Auditor of the State of Iowa" on Justia Law

A Texas truck driver was injured while making roadside repairs in Iowa when his parked semi was struck by another vehicle. After the accident, the driver retained a Texas attorney to pursue his personal injury claim. That attorney negotiated with the insurer for the other driver, ultimately agreeing to a settlement of $125,000 and requesting a release. However, the client did not sign the release and later replaced his attorney, claiming he had not authorized the settlement. The client then filed a lawsuit in Iowa, seeking additional compensation and naming the driver, the driver’s employer, and others as defendants.The defendants responded by moving to enforce the settlement agreement in the Iowa District Court for Warren County. The district court, acting as factfinder with no objection from either party, held a hearing, accepted evidence, and considered the client’s affidavit. The court found that the attorney was presumed to have settlement authority and that the client had not rebutted this presumption with clear and convincing evidence. The court enforced the settlement and dismissed the case upon payment of the agreed sum. The client’s motion to reconsider was denied, and he appealed.The Iowa Court of Appeals affirmed, finding the district court’s factual findings were supported by substantial evidence. The Iowa Supreme Court granted further review. The Supreme Court held that, because the client did not object to the district court’s procedure, the court properly acted as factfinder. The Supreme Court further held that the district court’s finding—that the attorney had authority to settle—was supported by substantial evidence, and thus the settlement agreement was enforceable. The court affirmed the decisions of the lower courts. View "Recio v. Fridley" on Justia Law

An elderly man with three children experienced a decline in health and mental capacity in his later years. After years of being cared for by one daughter, another daughter moved in, leading to significant family conflict. Shortly before his death, the man executed a new will, with the assistance of his attorney and after a medical evaluation confirmed his competency. This new will greatly favored one daughter over the others, and included a no-contest clause that would disinherit any beneficiary who challenged the will.After the man's death, the favored daughter, named as executor, admitted the will to probate. The other two children, feeling aggrieved by the changes, filed a lawsuit to set aside the will, alleging lack of testamentary capacity and undue influence by the favored daughter. A jury rejected their claims. When the executor filed the estate’s final report, the disfavored daughter objected, arguing that the no-contest clause should not apply because her challenge was made in good faith and with probable cause. The Iowa District Court for Clinton County overruled her objections, finding a lack of good faith and probable cause.On appeal, the Iowa Supreme Court clarified Iowa’s standards for avoiding enforcement of a no-contest clause: the challenger bears the burden to prove, under a totality-of-the-circumstances test, both subjective good faith and objective probable cause, as defined by the Restatement (Third) of Property. The court applied these standards de novo, giving deference to the district court’s factual findings, and concluded the appellant failed to meet her burden. Thus, the Supreme Court affirmed the district court’s enforcement of the no-contest clause and denial of the appellant’s objections to the final report. View "Felten v. Hoffman" on Justia Law

A candidate for city clerk with over ten years of experience working for the city requested her hiring interview with the Cedar Rapids City Council be conducted in a closed session, citing concerns about potential harm to her reputation if the interview were public and livestreamed. The council unanimously voted to honor her request and held the interview in closed session pursuant to Iowa Code § 21.5(1)(i), which allows closed sessions to protect an individual’s reputation when the individual requests it. The interview proceeded positively, and the candidate was later hired at a subsequent open meeting.A resident challenged the closed session, arguing that the council had violated the Iowa Open Meetings Act by not making an evidence-based determination of reputational harm before closing the interview. After a bench trial, the Iowa District Court for Linn County held that the council had not violated the statute, finding that a specific reputational threat need not be identified prior to closure if the interviewee requests it and the nature of the interview is unpredictable. The district court dismissed the case with prejudice.The Iowa Court of Appeals reversed, ruling that the city council should have conducted further inquiry into the necessity of closing the session and that a candidate’s request alone was insufficient without evidence of reputational harm. Upon further review, the Supreme Court of Iowa vacated the decision of the court of appeals and affirmed the district court’s judgment. The Supreme Court held that under Iowa Code § 21.5(1)(i), a governmental body may close a hiring interview at the candidate’s request as a precaution to protect reputation, without needing evidence of specific harm. The court also upheld the confidentiality of closed session records and found no error regarding courtroom access during trial. View "Teig v. Loeffler" on Justia Law

A high-speed police pursuit in Iowa ended with a motorcycle crash that left the rider, Augustin G. Mormann, paralyzed and ultimately led to his death after life support was withdrawn. The chase began when an Iowa State Trooper attempted to stop Mormann for speeding, but he fled, weaving through traffic and entering residential neighborhoods. The trooper disengaged due to safety concerns, but Manchester police officer James Wessels continued the pursuit at speeds exceeding 100 miles per hour. During the chase on a county road, Wessels’s police cruiser struck Mormann's motorcycle, leading to a crash that caused catastrophic injuries. Mormann was hospitalized, tested positive for methamphetamine, and died after choosing to discontinue life support. His family subsequently filed a civil suit against Wessels and the City of Manchester.In the Iowa District Court for Delaware County, the plaintiffs asserted claims including constitutional violations and, ultimately, common law assault and battery. The district court dismissed the constitutional claims after a change in Iowa law but allowed the assault and battery claims to proceed to trial. The jury found Wessels liable for both torts, awarding $4.25 million in compensatory damages and $10,000 in punitive damages. The court denied post-trial motions for judgment notwithstanding the verdict and for a new trial.The Iowa Supreme Court reviewed the case and affirmed the district court’s judgment. The court held that emergency response immunity under Iowa law does not shield a municipality or its officer from liability when the officer acts with reckless disregard for safety, as found by the jury. The court also concluded that the assault and battery claims were sufficiently pleaded under Iowa’s notice pleading standard, that there was substantial evidence to support the jury’s verdicts, and that the admission of the decedent’s dying declaration and evidence regarding police recording policies was proper. The punitive damages award was also upheld. View "Mormann v. City of Manchester, Iowa" on Justia Law

The case involves claims brought by the parents of a minor child, P.F., who was allegedly bullied, harassed, and assaulted by another student at Clay Elementary School during the 2022–2023 school year due to his sexual orientation. The parents assert that the school district and three employees were aware of these incidents but failed to protect P.F. or notify his parents, instead blaming P.F. or dismissing the other student’s conduct. After removing P.F. from the school and filing reports with authorities, the parents pursued legal action, first filing a complaint with the Iowa Civil Rights Commission (ICRC), which issued a right-to-sue letter. The parents then filed an amended petition in the Iowa District Court for Polk County, asserting three claims under the Iowa Civil Rights Act (ICRA) and three common law tort claims.The defendants moved to dismiss all claims, arguing that the heightened pleading requirements and qualified immunity provisions of the Iowa Municipal Tort Claims Act (IMTCA), as amended by Iowa Code section 670.4A, applied. The Iowa District Court for Polk County denied the motion, finding that the ICRA claims were not torts subject to the IMTCA and that the common law claims met the IMTCA’s pleading standard. The defendants appealed, asserting a right to immediate appeal under section 670.4A(4).The Iowa Supreme Court reviewed the appeal and held that the IMTCA’s qualified immunity and heightened pleading requirements do not apply to claims brought under the ICRA or to common law tort claims, as clarified in Doe v. Western Dubuque Community School District. Because section 670.4A did not apply to any of the claims, the defendants were not entitled to an appeal as of right. The court dismissed the appeal for lack of appellate jurisdiction and remanded the case. View "Fogle v. Clay Elementary School-Southeast Polk Community School District" on Justia Law