Justia Iowa Supreme Court Opinion Summaries

Michael Stoltze initiated a quiet-title action in November 2022 concerning a strip of land between his driveway and that of his neighbors, Grace and Macauley Stokes. The Stokeses filed a competing action, and both cases were consolidated. On February 24, 2024, the Iowa District Court for Polk County entered judgment quieting title in favor of the Stokeses. Although the Stokeses had requested attorney fees in their petition, the district court’s judgment did not address this issue. Thirty-one days after judgment—one day after the deadline to appeal—the Stokeses filed an application for statutory attorney fees.Stoltze opposed the application, arguing it was untimely and that the district court lacked jurisdiction to award attorney fees after the appeal period had expired. He also claimed he was prejudiced because he decided not to appeal, believing the Stokeses were no longer seeking attorney fees. After a contested hearing, the district court found that Iowa law does not impose a specific deadline for filing an application for statutory attorney fees and that the Stokeses had not unduly delayed their request. The court awarded the Stokeses $33,600 in attorney fees with interest.The Iowa Supreme Court reviewed the district court’s decision for correction of errors at law. It held that the district court retained jurisdiction to consider the application for attorney fees because such fees are a collateral matter, not subject to the same deadlines as motions to amend judgment. The Supreme Court found no error or abuse of discretion in the district court’s determination that the application was timely and that Stoltze’s claim of prejudice was unreasonable. The judgment of the district court was affirmed. View "Stoltze v. Maher" on Justia Law

In May 2023, a partial collapse of the Davenport Hotel apartment building resulted in three deaths and multiple injuries to individuals and property. Numerous lawsuits were filed against various parties, including the building’s owners, engineers, and the City of Davenport, as well as two city employees. These cases were consolidated in the Iowa District Court for Scott County. The City defendants sought dismissal of the claims against them, arguing that the Iowa Municipal Tort Claims Act’s qualified immunity provisions shielded them from liability and that the plaintiffs’ petition did not meet the Act’s heightened pleading requirements. They also asserted that the public-duty doctrine barred the claims, as any duty owed was to the public at large rather than to the individual plaintiffs.The Iowa District Court for Scott County denied the City defendants’ motion to dismiss. The court determined that the qualified immunity provisions of Iowa Code § 670.4A applied to common law tort claims but found that the plaintiffs’ petition satisfied the heightened pleading requirements. The court also rejected the City defendants’ argument that the public-duty doctrine barred the suit. The City defendants appealed the denial of qualified immunity under the immediate appeal provision in § 670.4A and separately sought interlocutory review of the public-duty doctrine issue, which was denied.The Iowa Supreme Court reviewed only the qualified immunity issue, concluding that the protections of Iowa Code § 670.4A do not apply to common law tort claims such as negligence and nuisance. The court held that the statute’s language, borrowed from federal law, was intended to apply only to constitutional or statutory claims, not to common law torts. As a result, the appeal was dismissed because the qualified immunity provisions did not apply to the claims asserted. View "In re Davenport Hotel Building Collapse" on Justia Law

In 2013, the plaintiff was charged in a single criminal case with two counts: domestic abuse assault and child endangerment. Pursuant to a plea agreement, the domestic abuse assault charge was amended to disorderly conduct, a simple misdemeanor, to which the plaintiff pleaded guilty. The child endangerment charge was dismissed as part of the agreement. Ten years later, the plaintiff sought expungement of the misdemeanor conviction under Iowa Code section 901C.3, which allows expungement of certain misdemeanor convictions if specific requirements are met.The Iowa District Court for Polk County granted expungement only for the disorderly conduct conviction, restricting access and redacting documents related to that count but leaving the remainder of the case file, including information about the dismissed charge, accessible to the public. The district court did not specify which documents should be restricted or redacted. When the plaintiff realized that the criminal case file was still publicly accessible, he filed a motion for implementation of expungement, arguing that the statute required expungement of the entire criminal case file, not just the conviction-related documents. The district court denied the motion, interpreting the statute to allow expungement only of documents related to the misdemeanor conviction.The Iowa Supreme Court reviewed the case on a writ of certiorari. The court held that Iowa Code section 901C.3 requires expungement of the entire criminal case file when the prerequisites for expungement are met, not just the portions related to the misdemeanor conviction. The court reasoned that the statute’s language and legislative history support a whole-file approach, and that partial expungement could still allow the public to infer the existence of expunged charges, undermining the statute’s purpose. The Supreme Court sustained the writ, vacated the district court’s order, and remanded the case for further proceedings consistent with its opinion. View "J. Doe v. Iowa District Court for Polk County" on Justia Law

A child, Trinity, was removed from her mother’s custody shortly after birth and placed with the Iowa Department of Health and Human Services (HHS) for foster care. Trinity was placed in a different foster home from her siblings, who were also in state custody. As the case progressed, HHS sought to move Trinity to a new foster home with her siblings, but the guardian ad litem (GAL) objected, citing concerns about Trinity’s well-being and requested an evidentiary hearing before any move. The juvenile court ordered HHS not to move Trinity until such a hearing could be held, prioritizing the child’s best interests.HHS challenged the juvenile court’s order, arguing that it exceeded its statutory authority by interfering with HHS’s placement decisions. The Iowa District Court for Polk County maintained its position, requiring an evidentiary hearing before any change in placement. HHS then filed a petition for writ of certiorari, which was granted and transferred to the Iowa Court of Appeals. The court of appeals, in a split decision, sustained the writ, concluding that the juvenile court had acted beyond its authority by suspending HHS’s placement decision without making the findings required by statute.On further review, the Iowa Supreme Court vacated the decision of the court of appeals and annulled the writ. The Supreme Court held that the juvenile court did not exceed its authority by temporarily staying HHS’s planned move of the child pending an evidentiary hearing. The Court clarified that Iowa Code chapter 232 allows for judicial review of HHS’s placement decisions before a move occurs, especially when necessary to protect the child’s best interests. The Supreme Court’s disposition vacated the appellate decision and annulled the writ. View "Iowa Department of Health and Human Services v. Iowa District Court for Polk County" on Justia Law

Two Washington County deputies went to a residence to investigate a report of illegal fireworks. The resident, Matthew Meisheid, emerged from his home, angrily confronted the deputies, and demanded they leave his property. During the encounter, Meisheid pulled a handgun from his waist, pointed it straight up, and declared, “I’ll show you a firework: Boom, boom, boom, boom!” The deputies, visibly shaken, retreated and Meisheid was later arrested. He was charged with two counts of assault for displaying a dangerous weapon in a threatening manner toward peace officers, with a felony enhancement for use of a weapon against peace officers.A jury in the Iowa District Court for Washington County found Meisheid guilty on both counts. The district judge sentenced him to prison with a five-year mandatory minimum. On appeal, Meisheid argued that there was insufficient evidence to show he displayed the weapon “toward” the deputies or in a threatening manner, and also challenged his sentence. The Iowa Court of Appeals affirmed both his conviction and sentence.The Supreme Court of Iowa granted further review, focusing solely on whether there was sufficient evidence that Meisheid displayed a dangerous weapon “toward” the deputies. The court held that, under the jury instructions given (to which Meisheid did not object), the jury could reasonably find that Meisheid’s act of showing the gun so the deputies would be aware of it constituted displaying the weapon “toward” them, even though he did not point it directly at them. The court affirmed the decisions of the Iowa Court of Appeals and the Iowa District Court for Washington County. View "State of Iowa v. Meisheid" on Justia Law

An employee suffered a back injury while working as a loader and material handler, which required him to lift heavy objects. After the injury, he received medical treatment and was placed on a weight restriction but continued working for the same employer at a slightly higher wage. Later, he voluntarily left that job for personal reasons and obtained new employment at higher wages. The employee eventually filed a claim for workers’ compensation benefits, and medical evaluations determined he had a permanent impairment to his back.A deputy workers’ compensation commissioner found that the employee had an 8% functional impairment and, applying the “industrial method,” determined the employee had a 15% loss of earning capacity, awarding permanent partial disability benefits accordingly. The workers’ compensation commissioner affirmed this decision. The employer and its insurance carrier sought judicial review, arguing that the benefits should have been calculated based on functional impairment rather than loss of earning capacity. The Iowa District Court for Polk County denied the petition for judicial review, agreeing with the commissioner’s use of the industrial method. On appeal, the Iowa Court of Appeals affirmed the district court’s judgment, holding that the industrial method was appropriate and that substantial evidence supported the finding of a 15% loss of earning capacity.The Supreme Court of Iowa reviewed the case and held that, under Iowa Code section 85.34(2)(v), when an employee with a nonscheduled injury returns to work or is offered work at the same or greater earnings as at the time of injury, compensation must be based solely on the employee’s functional impairment, not on loss of earning capacity. The court vacated the decision of the Court of Appeals, reversed the district court’s judgment, and remanded the case for calculation of benefits based on functional impairment. View "Den Hartog Industries v. Dungan" on Justia Law

After a physical altercation in a gas station parking lot, the defendant was charged with willful injury causing serious injury. The incident began when the defendant, after an argument with his girlfriend, was being driven home by her mother and her mother’s fiancé. An argument in the car led to a confrontation in the parking lot, during which the defendant punched, kicked, and threatened the fiancé, resulting in significant injuries including lost teeth and facial fractures. The police responded, and one officer viewed the store’s surveillance video on a monitor, recording it with his body camera. Due to errors by law enforcement and the store, the original surveillance video was not preserved, leaving only the bodycam recording as evidence.The Iowa District Court for Polk County admitted the bodycam recording into evidence over the defendant’s objections regarding authentication and the best evidence rule. The defendant was convicted by a jury and sentenced to prison. On appeal, the Iowa Court of Appeals reversed the conviction, finding that the bodycam recording was improperly admitted because it was not properly authenticated by the officer or other witnesses, and remanded for a new trial.The Iowa Supreme Court granted further review. It held that while the officer’s testimony alone was insufficient to authenticate the recording, subsequent testimony from the victim properly authenticated the video up to the point of the second hit to the ground. The court also found that the district court did not abuse its discretion in admitting the video under the best evidence rule, as the content was not seriously disputed and the absence of the original was adequately explained. The court concluded that there was sufficient evidence to support the conviction. The Iowa Supreme Court vacated the court of appeals’ decision and affirmed the district court’s judgment and sentence. View "State of Iowa v. Manning" on Justia Law

During a traffic stop, Kevin Woods was found in possession of drugs, a scale, a loaded semiautomatic pistol, and additional high-capacity firearm magazines. He was charged with possession of a controlled substance and carrying a dangerous weapon while in the illegal possession of a controlled substance or while committing an indictable offense. Woods pleaded guilty to both charges but challenged the latter conviction, arguing it violated his Second Amendment rights and article I, section 1A of the Iowa Constitution.The Iowa District Court for Polk County denied Woods's motion to dismiss the dangerous weapon charge, reasoning that the legislature could impose reasonable time, place, and manner restrictions on the right to keep and bear arms. The court concluded that the prohibition on carrying firearms while illegally possessing a controlled substance or committing an indictable offense was a reasonable regulation supported by historical analogues. Woods entered a conditional guilty plea, preserving his right to appeal the constitutionality of his conviction.The Iowa Supreme Court reviewed the case and affirmed the lower court's decision. The court held that the Second Amendment does not cover the right to carry a firearm while illegally possessing a controlled substance or committing an indictable offense. The court reasoned that the federal constitutional right to keep and bear arms is limited to responsible, law-abiding citizens engaged in lawful conduct. Additionally, the court found that even if the conduct were covered by the Second Amendment, the regulation was consistent with the nation's historical tradition of firearm regulation. The court also concluded that Woods's conviction did not violate article I, section 1A of the Iowa Constitution, as the state has a compelling interest in public safety, and the statute was narrowly tailored to serve that interest. View "State of Iowa v. Woods" on Justia Law

Eugene Sikora, a former prisoner, claims that the State of Iowa failed to release him from prison when his sentence was over. He was convicted of three felonies in 2016 and sentenced to concurrent five-year terms, which were suspended for probation. In 2017, his probation was revoked, and he was imprisoned until March 2019. Sikora alleges that due to a miscalculation, he was imprisoned for nearly five months longer than allowed, as the defendants did not credit him for 292 days served in county jails and a custodial residential center.Sikora filed a suit over three years after his release, seeking money damages for wrongful imprisonment. He named the State of Iowa and the director of the Iowa Department of Corrections as defendants, asserting five tort claims, including violations of his constitutional rights and negligence. The defendants moved to dismiss the suit, arguing sovereign immunity and other defenses. The district court dismissed some of Sikora’s claims but allowed others to proceed. However, after the Iowa Supreme Court's decision in Burnett v. Smith, which overruled the precedent allowing constitutional tort claims, the district court dismissed Sikora’s remaining claims and denied his motion to amend his petition to add new defendants and claims.The Iowa Supreme Court affirmed the district court’s dismissal, holding that sovereign immunity barred Sikora’s claims. The court concluded that all of Sikora’s claims were essentially false imprisonment claims, which are barred by sovereign immunity under Iowa Code section 669.14(4). The court also rejected Sikora’s arguments that constitutional torts and claims against individual state employees could proceed, emphasizing that the Iowa Tort Claims Act (ITCA) provides the exclusive mechanism for such claims and explicitly prohibits claims based on false imprisonment. View "Sikora v. State of Iowa" on Justia Law

Jordan Cole consented to a one-year protective order in a domestic abuse case, which prohibited him from possessing firearms under Iowa Code section 724.26(2)(a). Despite this, Cole pawned stolen firearms while the order was in effect. He was charged with theft and violations of section 724.26(2)(a). The theft charge was dropped, and Cole was convicted of two violations of section 724.26(2)(a). He was sentenced to concurrent prison sentences, which were suspended with probation.Cole appealed his convictions, arguing that section 724.26(2)(a) violated the Second Amendment and article I, section 1A of the Iowa Constitution. He also claimed an error in his sentencing order. The Iowa District Court for Story County had denied his motion to dismiss the charges based on these constitutional claims. Cole and the State agreed to dismiss two charges, and Cole waived his jury rights, leading to a trial on the minutes of testimony. The district court found Cole guilty and sentenced him to concurrent terms, suspended with probation, but stated that if probation was revoked, the sentences could be served consecutively.The Iowa Supreme Court reviewed the case and held that Cole waived his Second Amendment and article I, section 1A rights by consenting to the protective order, which explicitly prohibited firearm possession. The court affirmed his convictions but agreed with Cole that the sentencing order's provision for consecutive sentences upon probation revocation was unlawful. The court remanded the case for entry of a corrected sentencing order, ensuring that any revocation of probation would not result in consecutive sentences. View "State of Iowa v. Cole" on Justia Law