Justia Iowa Supreme Court Opinion Summaries

Beecher Store, Inc., a retail liquor store in Dubuque, Iowa, was subject to compliance checks by the Dubuque Police Department. On October 15, 2022, officers sent two underage individuals into the store to attempt separate purchases of alcohol, about five minutes apart. Both purchases were made from the same employee, who checked each buyer’s ID but failed to verify their age adequately. The employee received two criminal citations for selling alcohol to minors, and pleaded guilty to both.Following these events, the Iowa Alcoholic Beverages Division (ABD) issued two civil penalty orders to Beecher Store, Inc.: a $500 penalty for the first violation, and a $1,500 penalty plus a thirty-day license suspension for the second violation, as mandated by Iowa Code section 123.50(3). Beecher did not contest the first penalty but challenged the second, arguing before an administrative law judge (ALJ) that the two violations were part of a single series of events and should not trigger the escalated second-violation sanctions. The ALJ rejected this argument, and the ABD affirmed the decision. Beecher then sought judicial review in the Iowa District Court for Dubuque County, which denied Beecher’s petition. Beecher appealed, and the Iowa Supreme Court retained the case.The Iowa Supreme Court held that two separate sales of alcohol to two different minors, even if occurring minutes apart on the same day, constitute a first and second violation “within two years” under Iowa Code section 123.50(3). The court also rejected Beecher’s argument that the statute was unconstitutionally vague, finding the language clear and unambiguous. The court affirmed the district court’s decision, upholding the sanctions imposed by the ABD. View "Beecher Store, Inc., v. Iowa Department of Revenue Alcoholic Beverages Division" on Justia Law

The case involves a fatal shooting in Iowa, where Sherral Tolbert encountered Levonta Baker, a former friend and rival gang member. Tolbert pursued Baker, stopped alongside his car, and fired six shots, killing him. Tolbert admitted to the shooting but asserted that he acted in the heat of passion, claiming Baker had previously provoked him by shooting at Tolbert’s grandmother’s home. Tolbert argued that his emotional state at the time should mitigate the offense to voluntary manslaughter, rather than murder.The Iowa District Court for Scott County presided over Tolbert’s trial. The jury was instructed to consider first-degree murder, then second-degree murder if the higher charge was not proven, and finally voluntary manslaughter if neither murder charge was established. Tolbert objected to the instructions, arguing the jury should have considered voluntary manslaughter even if murder elements were met, based on Iowa’s statutory language. The district court rejected this argument, using standard “acquittal-first” instructions. The jury acquitted Tolbert of first-degree murder but convicted him of second-degree murder. Tolbert also moved for mistrial due to alleged prosecutorial misconduct during voir dire and sought to disqualify a prosecutor for conflict of interest, both motions denied by the district court.The Iowa Supreme Court reviewed Tolbert’s conviction. The Court held that Iowa’s voluntary manslaughter statute does not require the jury to find malice, and passion is incompatible with malice. It upheld the use of acquittal-first instructions, finding no misstatement of law or constitutional violation. The Court also found no abuse of discretion in denying the mistrial or the motion to disqualify the prosecutor, as there was no prejudice or conflict established. Tolbert’s conviction for second-degree murder was affirmed. View "State of Iowa v. Tolbert" on Justia Law

A developer purchased a building for redevelopment and, after refinancing with a new bank, began negotiating a construction loan. The parties executed a document outlining proposed financing, which included an exclusivity clause requiring the developer to work only with the bank while the bank conducted due diligence. The proposal depended on the developer receiving specific tax credits. When those credits were not awarded, the bank proposed new terms or ending negotiations. The developer then sought financing from other lenders, ultimately securing a loan elsewhere, which led the bank to sue for breach of contract (based on the exclusivity clause) and for fraud.The Iowa District Court for Scott County granted summary judgment for the developer on the breach of contract claim, finding the proposal to be an unenforceable agreement to agree or, alternatively, discharged by the failed condition precedent (the tax credits). The court also excluded the financing proposal from trial on the fraud claim, concerned the jury would confuse it with a binding contract. The jury returned a verdict for the developer on the fraud claim. The Iowa Court of Appeals reversed, finding the exclusivity clause enforceable and the exclusion of the proposal at trial improper.The Supreme Court of Iowa granted further review. It held that while the exclusivity clause was severable and otherwise definite enough to be independently enforceable, the developer’s duty under that clause was discharged when the required tax credits were not obtained and the original deal was abandoned. Thus, there was no breach. The Supreme Court also concluded that the district court did not abuse its discretion by excluding the proposal from the fraud trial, as its admission risked unfair prejudice without preventing the bank from presenting its case. The Supreme Court vacated the court of appeals’ decision and affirmed the district court’s judgment. View "Northwest Bank & Trust Company v. Pershing Hill Lofts, LLC" on Justia Law

A five-month-old child died from an anoxic brain injury after being found with her face against a blanket while in the care of Amanda Cooke, a state-registered childcare provider. Cooke had placed the child for a nap in the basement, an area not approved for sleeping, without a baby monitor or the ability to observe the child by sight or sound. Contrary to safe sleep regulations, a blanket was left in the sleeping area. After the incident, the Iowa Department of Health and Human Services (HHS) found that Cooke denied the child critical care by failing to provide proper supervision and issued a founded child abuse assessment, which resulted in her placement on the central child abuse registry and revocation of her childcare registration.An administrative law judge initially reversed the agency’s determination regarding denial of critical care, reasoning that Cooke’s conduct should be measured against a generic reasonable and prudent person, not a childcare provider with specialized training. The Director of HHS rejected this and affirmed the agency’s original finding, concluding that the “facts and circumstances” of Cooke being a trained, state-registered provider must be considered. The Iowa District Court for Polk County reversed the agency’s decision, holding that the standard for proper supervision was an objective one and should not account for Cooke’s training or professional status, and remanded the case for reconsideration.The Iowa Supreme Court reviewed the case and held that the proper legal standard for adequate supervision under Iowa Code section 232.68(2)(a)(4)(b) includes consideration of the objective circumstances, such as Cooke’s status as a state-registered childcare provider and her duty to follow safe sleep regulations. The Court found that Cooke failed to provide the supervision that a reasonable and prudent person would exercise under similar facts and circumstances, reversed the district court’s order, and reinstated the founded child abuse assessment. View "Cooke v. Iowa Department of Health and Human Services" on Justia Law

A man required to register as a sex offender in Iowa was charged with violating a statutory provision that requires notification to the county sheriff if a registered sex offender stays away from his principal residence for more than five days. The issue arose after local authorities were unable to find him at his registered address in Pilot Mound, and after his eviction from that residence, he registered a new address in Boone. The prosecution alleged that he failed to properly notify the sheriff of his change in location within the statutory timeframe, basing its case on the assertion that he failed to register his change of residence.The Iowa District Court for Boone County denied the defendant’s motions for acquittal and accepted the jury’s guilty verdict under Iowa Code section 692A.105, which concerns temporary lodging away from a principal residence. The court imposed a suspended sentence with probation. On appeal, the Iowa Court of Appeals affirmed the conviction, holding that the defendant’s eviction constituted a change requiring notification under section 692A.105, and that he failed to comply with the five-day reporting requirement.The Supreme Court of Iowa reviewed the sufficiency of the evidence and the proper interpretation of the statute. The court held that section 692A.105 applies only when a sex offender stays away from his principal residence for more than five days, not merely upon a change in residence. The State had not presented evidence that the defendant was away from his principal residence for more than five days to trigger the statutory requirement. Consequently, the Supreme Court vacated the decision of the court of appeals, reversed the district court’s judgment, and remanded for entry of a judgment of acquittal. View "State of Iowa v. Uranga" on Justia Law

A woman died after a rapid health decline while receiving emergency and critical care at a West Des Moines hospital. Her husband, who was appointed as the administrator of her estate, filed a wrongful-death medical malpractice lawsuit against various medical providers. He brought the suit both on behalf of the estate and in his individual capacity, alleging multiple claims including negligence and seeking damages for emotional and financial loss. The husband, a nonlawyer, filed the petition without legal counsel and argued that, as the sole beneficiary, he should be allowed to proceed pro se or, alternatively, be given time to retain an attorney if one was required.The Iowa District Court for Polk County dismissed the lawsuit, ruling that the petition was a legal nullity because a nonlawyer cannot represent an estate or other parties in court, and denied the husband’s request for more time to secure counsel. The court also denied his motion to amend the petition. On appeal, the Iowa Court of Appeals affirmed the dismissal, agreeing that the wrongful-death action could not proceed without a lawyer and finding that the request for additional time had not been properly preserved for appeal. Two appellate judges dissented, concluding the husband was entitled to a warning and additional time to obtain counsel.The Supreme Court of Iowa granted further review. The court held that a nonlawyer cannot represent an estate or other persons in a wrongful-death action in district court. However, it found that the district court abused its discretion by not granting the husband reasonable time to retain counsel before dismissing the case. The Supreme Court vacated the court of appeals’ decision, reversed the district court’s judgment, and remanded the case with instructions to allow at least thirty days for the husband to secure trial counsel. View "Estate of Tornell v. Trinity Health Corporation" on Justia Law

An employee at a quarry died after falling through an unsecured catwalk gate into dangerous machinery. The machinery, used for processing lime, was typically secured by metal linchpins, but at the time of the accident, the gate was fastened only with a metal wire instead of the pins. The worker’s family brought suit against two of his co-employees, a supervisor and a safety director, alleging gross negligence for failing to prevent the accident. Both defendants testified that they did not know the securing pins were missing, and there had been no prior similar accidents since safety rails were installed decades earlier.After a jury trial in the Iowa District Court for Benton County, the plaintiffs were awarded damages totaling approximately $2.84 million. The district court denied the defendants’ post-trial motions. On appeal, the Iowa Court of Appeals affirmed, reasoning that the evidence supported the conclusion that injury was probable under the circumstances, and relied in part on what the defendants should have known.The Supreme Court of Iowa reviewed the case and determined that, under Iowa law, recovery for co-employee gross negligence requires proof that the defendants had actual knowledge of the specific peril—the missing pins that left the gate unsecured. The court found that there was no evidence either defendant actually knew about the missing pins or unsecured gate. As a result, the legal standard for gross negligence was not met. The Supreme Court of Iowa vacated the decision of the court of appeals, reversed the judgment of the district court, and remanded the case for dismissal, holding that the plaintiffs’ exclusive remedy was under the state’s workers’ compensation statute. View "Griffith v. Kulper" on Justia Law

Six unrelated criminal defendants in Scott County, Iowa, were each charged with serious misdemeanors in late 2024 and requested court-appointed counsel due to indigency. The Iowa District Court for Scott County initially appointed the Davenport local public defender’s office to represent each defendant. Shortly after these appointments, the Davenport Public Defender, citing a temporary overload of cases as specified in Iowa Code section 13B.9(4)(a), filed motions to withdraw from representing these defendants. The office asserted it was ethically unable to handle the additional cases after considering all relevant factors, including attorney staffing and caseloads.The district associate judge denied these withdrawal motions, stating the Davenport office was fully staffed and that insufficient information had been provided about its workload. The court also noted the lack of available contract or noncontract attorneys to appoint in place of the public defender. Despite repeated filings by the Davenport PD asserting the overload, the district court continued to deny withdrawal, eventually ordering the chief public defender to appear in each case. The State Public Defender then filed a petition for a writ of certiorari with the Iowa Supreme Court, challenging the district court’s refusal to allow the Davenport PD to withdraw.The Supreme Court of Iowa held that while district courts have a limited role in ensuring the statutory precondition of a temporary overload is met, they must be highly deferential to a local public defender’s professional representation regarding such overload. The court concluded that the Davenport PD’s representations satisfied its burden to establish a temporary overload. The district court exceeded its authority by refusing to accept these representations and denying withdrawal. The Supreme Court sustained the writ of certiorari and vacated the district court’s orders attaching the Davenport PD to the six cases. View "State Public Defender v. Iowa District Court For Scott County" on Justia Law

The defendant, a former employee of a tattoo studio, embezzled approximately $120,000 from her employer over a nine-month period. After being charged with first-degree theft, she pleaded guilty under a plea agreement in which both she and the State recommended a deferred judgment, with restitution payments as a condition of probation. Prior to sentencing, a presentence investigation report (PSI) was submitted, but it did not include any victim-impact statements. At the sentencing hearing, the business owner delivered an oral victim-impact statement detailing the emotional and financial harm caused by the theft. The district court declined to follow the parties’ joint recommendation and instead imposed the statutory maximum prison sentence of up to ten years.The defendant appealed to the Iowa Court of Appeals, arguing that the district court abused its discretion by sentencing her to prison and by allegedly relying on improper factors contained in the victim-impact statement, which she claimed included unproven allegations. The Court of Appeals affirmed the district court’s judgment, holding that the defendant had not preserved error regarding the victim-impact statement because she failed to object at the sentencing hearing. The appellate court also found no indication that the district court had relied on improper factors.Upon further review, the Supreme Court of Iowa vacated the Court of Appeals’ decision. The Supreme Court clarified that, with respect to previously unseen oral victim-impact statements delivered at sentencing, defendants are not required to object contemporaneously in order to raise claims on direct appeal about improper sentencing considerations. However, the Supreme Court concluded that the victim-impact statement in this case was largely appropriate and that the record did not indicate the district court relied on any improper factors. The Supreme Court affirmed the district court’s judgment and sentence. View "State of Iowa v. Hallock" on Justia Law

The defendant was charged with multiple sexual offenses arising from alleged abuse of his grandchild in Worth County, Iowa, and a separate set of charges in another county. Pursuant to a plea agreement, he entered a guilty plea to lascivious acts with a child, and the remaining charges in both counties were dismissed. At sentencing, the presentence investigation report recommended incarceration, and the defendant, along with supportive family members, argued for probation. No victim impact statement was presented at the sentencing hearing, and the defendant did not object to its absence. The district court imposed a ten-year sentence and lifetime supervision.Shortly after sentencing, the defendant moved for resentencing, claiming that a newly obtained written statement from the victim, advocating for probation, should be considered. The district court denied the motion, finding no error in the sentencing process and noting that the victim impact statement appeared to have been generated after sentencing. The defendant filed a notice of appeal challenging both the sentence itself and the denial of his motion for resentencing. The Iowa Court of Appeals rejected the sentencing challenge and held it lacked jurisdiction to consider the resentencing issue, reasoning that the notice of appeal did not specifically reference the post-sentencing order.On further review, the Supreme Court of Iowa held that once good cause to appeal is established, appellate jurisdiction extends to all issues raised in the appeal, including those connected to the sentencing hearing and its aftermath. The court concluded that the notice of appeal was sufficient to encompass the denial of the resentencing motion. Nevertheless, the court found no abuse of discretion by the district court in denying resentencing, holding that the defendant has no general right to a second sentencing nor a right to insist that a victim’s statement be considered in mitigation. The judgment of the district court was affirmed. View "State of Iowa v. Warburton" on Justia Law