Justia Iowa Supreme Court Opinion Summaries

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

The Supreme Court of Iowa affirmed the decision of the Court of Appeals and the District Court in favor of the City of Des Moines, in a case brought by Lime Lounge, LLC. Lime Lounge, a bar, challenged a city ordinance requiring it to obtain a conditional use permit (CUP) to operate. After receiving noise complaints, the City revoked Lime Lounge's CUP, which was upheld in a prior appeal. Lime Lounge then challenged the ordinance arguing it was preempted by Iowa Code, violated equal protection and spot zoning prohibitions. The trial court dismissed Lime Lounge's claims and this decision was affirmed by the Court of Appeals.The Supreme Court of Iowa found that the city's ordinance was not preempted by state law. Rather, it was a proper exercise of the city's zoning authority and did not create a separate local alcohol license. The Court also rejected Lime Lounge's equal protection claim, holding that the city had a legitimate purpose in imposing a CUP on specific businesses selling alcohol. Finally, the Court dismissed the claim of illegal spot zoning, as Lime Lounge failed to prove that the city had engaged in such activity. The Court thus affirmed the dismissal of Lime Lounge's challenge to the ordinance. View "Lime Lounge, Inc. v. City of Des Moines, Iowa" on Justia Law

The appellant, Lawrence George Canady III, had been charged with voluntary manslaughter, willful injury causing bodily injury, and assault causing bodily injury due to his involvement in a fatal nighttime shooting incident. He was not the shooter, but the State alleged that he was beating the victim while another person shot the victim. The appellant challenged the admission of a cell phone video recorded prior to the shooting where he and the shooter were seen singing a rap song containing lyrics that seemed to reference the victim. The district court allowed the video, but the court of appeals reversed the decision, remanding for a new trial.Upon further review by the Supreme Court of Iowa, the court found that the district court did not abuse its discretion in admitting the video. It was relevant to the case as it showed the appellant and the shooter jointly voicing a threat, which could counter the appellant's claim that he was unaware of the shooter's intention. The court also found no error in the admission of a Snapchat photo, as it was relevant to showing that the appellant may have been aware that the shooter had a gun and was willing to use it. The court further held that the evidence was sufficient to support the appellant's voluntary manslaughter conviction.The appellant's argument that his sentences for voluntary manslaughter and willful injury causing bodily injury should be merged was rejected as the offenses did not overlap in elements. Moreover, the court found no error in the sentencing court's consideration of the minutes of testimony or in its imposition of consecutive sentences. The Supreme Court of Iowa vacated the decision of the court of appeals and affirmed the appellant's convictions and sentence. View "State of Iowa v. Canady" on Justia Law

In the Supreme Court of Iowa, the case involved David Jackson, who was involved in a car accident that resulted in the death of another motorist. Jackson was convicted of vehicular homicide by operating while intoxicated, reckless driving, leaving the scene of an accident resulting in death, and operating a motor vehicle without the owner’s consent. Jackson appealed on the basis that the court allowed rebuttal evidence of his medical condition, which he claimed caused him to black out and lose control of the vehicle, over his objections that the evidence was hearsay.The Court concluded that the district court had erred in admitting the testimony of an employee of a healthcare vendor who had reviewed some of Jackson’s post-accident medical records. The court found that the testimony was hearsay and did not fall into the business records exception to the hearsay rule because the testimony was about the records, not the records themselves.The Court affirmed Jackson’s conviction for operating a motor vehicle without the owner’s consent, but vacated his convictions for vehicular homicide (OWI), reckless driving, and leaving the scene of an accident resulting in death, and remanded the case for further proceedings. View "State of Iowa v. Jackson" on Justia Law

In this case, the Iowa Supreme Court reviewed a dispute involving property owners David and Jeanie Vaudt and Wells Fargo Bank, which held the mortgage on neighboring property owned by Fredesvindo Enamorado Diaz and Denice Enamorado. The Vaudts had installed a landscaping barrier that encroached on the Enamorado's property. When the Enamorados disputed the boundary, the Vaudts filed a petition to quiet title, claiming boundary by acquiescence and adverse possession. Wells Fargo moved to dismiss the claims, arguing they were time-barred by a one-year statute of limitations related to property transfers by trustees. The district court agreed with Wells Fargo, citing a previous Iowa Supreme Court ruling (Heer v. Thola).The Vaudts appealed, asking the Supreme Court to overrule Heer. They argued their claims arose from the conduct of the Enamorados' predecessors in interest, not the transfer of property by the trustee's deed. The Supreme Court agreed with the Vaudts, stating that Heer incorrectly interpreted the statute of limitations, which applies specifically to claims arising from transfers by trustees, not to all adverse claims. The court overruled Heer, rejecting its broad application of the one-year statute of limitations to boundary-by-acquiescence claims.The court reversed the district court's dismissal of the Vaudts' claims, remanding the case for further proceedings. View "Vaudt v. Wells Fargo Bank, N.A." on Justia Law

A case was brought before the Supreme Court of Iowa involving Kadin Miller, who was convicted of harassment after he posted a video of himself and his ex-girlfriend engaged in consensual sexual intercourse on a pornography website without her consent. This act was done to "annoy" and "get back at" his ex-girlfriend after their relationship ended on bad terms. As a result of his conviction, Miller was sentenced to two years in prison and was required to register as a sex offender. The main issue in the appeal was whether the State proved beyond a reasonable doubt that Miller was required to register as a sex offender pursuant to Iowa Code chapter 692A.Under Iowa law, individuals convicted of any sex offense are required to register as a sex offender if they reside, are employed, or attend school in the state. The law sets forth a comprehensive list of sex offenses that require an offender to register as a sex offender. However, the crime Miller was convicted of, harassment in the first degree, is not a per se sex offense. For non-per se sex offenses, an offender is required to register only if the state proves “beyond a reasonable doubt” to “a judge or jury” that the offense was “sexually motivated.”In this case, the Supreme Court of Iowa concluded that the State did not prove beyond a reasonable doubt that Miller's crime was sexually motivated. The court found that the district court's reasoning did not focus on the relevant statutory inquiry—whether the crime was sexually motivated—and instead focused on whether Miller had a sexual interest in the video. The court also noted that there was no evidence to support the district court's finding that Miller's commission of the crime of harassment was done for the purpose of his own sexual gratification. As such, the Supreme Court of Iowa reversed the district court's finding that Miller's crime was sexually motivated, and therefore, Miller was not required to register as a sex offender. View "State of Iowa v. Miller" on Justia Law