Justia Iowa Supreme Court Opinion Summaries

In the 1950s, Bert and Donna Miller sought fertility treatment at the University of Iowa Hospitals and Clinics. Dr. John H. Randall, the head of the department, assisted them, resulting in the birth of three children. Decades later, DNA testing revealed that Dr. Randall, not Bert Miller, was the biological father of two of the children. The plaintiffs, Bert Miller and Nancy Duffner, sued the State of Iowa under the Fraud in Assisted Reproduction Act (FARA), alleging that Dr. Randall used his own sperm without their parents' knowledge or consent.The Iowa District Court for Johnson County dismissed the case, ruling that FARA, enacted in 2022, does not apply retroactively to actions taken decades earlier. The court found that FARA lacks any express language indicating legislative intent for retrospective application, and thus, it operates only prospectively. The plaintiffs appealed, arguing that FARA's provision allowing children to sue "at any time" implies retroactive application.The Iowa Supreme Court reviewed the case and affirmed the district court's decision. The court held that FARA does not apply to fertility fraud committed before the statute was enacted. The court emphasized that without an express retroactivity provision, statutes creating new substantive liabilities are presumed to operate only prospectively. The court found no language in FARA that rebuts this presumption and concluded that the statute's provision allowing actions to be brought "at any time" pertains only to future violations. Therefore, the plaintiffs' claims were dismissed with prejudice. View "Miller v. State" on Justia Law

Antoine Smith, a police officer for the City of Cedar Rapids, was ordered to retake his official photo, which he refused. This led to a formal administrative investigation by the Cedar Rapids Police Department. Smith was notified of the investigation and later interviewed, during which he admitted to violating the department's code of conduct. The investigation concluded with a recommendation for a ten-hour suspension without pay and a requirement for Smith to retake his photo. Smith's counsel requested the investigation results and materials, which were denied until after the disciplinary decision was made.The Iowa District Court for Linn County granted summary judgment in favor of the City, concluding that the City did not violate Iowa Code section 80F.1(3) or 80F.1(9) by withholding the investigative materials until after the disciplinary decision. Smith appealed this decision.The Iowa Supreme Court reviewed the case and affirmed the lower court's decision. The court held that under Iowa Code section 80F.1(3), an officer is entitled to the results of an investigation only after the agency has made a final determination, including whether discipline will be imposed. Similarly, under section 80F.1(9), the officer is entitled to investigative materials only after discipline is decided. The court concluded that the City did not violate these provisions by waiting until after the disciplinary decision to provide the requested materials. The court emphasized that the statutory language clearly conditions the rights to these materials on the imposition of discipline. View "Smith v. City of Cedar Rapids" on Justia Law

The defendant entered into a joint plea agreement covering offenses in both Johnson and Linn Counties. He committed a crime in Linn County first, then committed another crime in Johnson County. He pleaded guilty to a felony and a serious misdemeanor in Johnson County before pleading guilty to a felony in Linn County. The State argued that the defendant was ineligible for a deferred judgment in Linn County because of his prior felony conviction in Johnson County. The defendant contended that he was still eligible since the Linn County crime occurred before the Johnson County felony.The Iowa District Court for Linn County ruled in favor of the State, determining that the defendant was ineligible for a deferred judgment due to his prior felony conviction in Johnson County. The court imposed a suspended sentence and placed the defendant on supervised probation for three years. The defendant appealed the decision, arguing that the statutory language was ambiguous and should be interpreted in line with recidivism statutes, which require each offense to be complete as to conviction and sentencing before the commission of the next offense.The Iowa Supreme Court reviewed the case and affirmed the district court's decision. The court held that the language of Iowa Code section 907.3(1)(a)(1) was clear and unambiguous, stating that a defendant is ineligible for a deferred judgment if he has a previous felony conviction. The court found that the statute's text and meaning were clear and did not require further interpretation. Consequently, the court affirmed the district court's ruling that the defendant was ineligible for a deferred judgment in Linn County due to his prior felony conviction in Johnson County. View "State v. Gardner" on Justia Law

A citizen sought access to police use of force reports under the Iowa Open Records Act. The Des Moines Police Department requires officers to complete a report whenever force is used, detailing the incident's specifics. The reports are reviewed by supervisors and used for accountability, training, and identifying trends. In 2020, 387 use of force reports were filed, with only a few resulting in disciplinary action.The Iowa District Court for Polk County granted summary judgment in favor of the citizen, ordering the City of Des Moines to disclose the use of force reports. The court found that the reports were factual accounts of incidents and not evaluative or performance records, thus not exempt from disclosure under Iowa Code section 22.7(11). The court allowed redaction of information about officer injuries or medical treatment.The Iowa Supreme Court reviewed the case and affirmed the district court's decision. The court held that the use of force reports are not exempt from disclosure under section 22.7(11) as they are factual reports, not confidential personnel records. The court also rejected the City's argument that the reports were protected under Iowa Code section 80F.1(20), as this section pertains to statements and interviews in response to complaints, not routine use of force reports. The court noted that any specific redactions could be justified on other legal grounds if necessary. View "Harrison v. Mickey" on Justia Law

Brandon Ruiz was convicted of second-degree sexual abuse in 2018. He was acquitted of six other counts but sentenced to a term not exceeding twenty-five years. Ruiz's conviction was affirmed on direct appeal. He then filed his first postconviction relief (PCR) application, which was denied on the merits by the district court, and this denial was affirmed by the Iowa Court of Appeals. Procedendo was issued on December 10, 2019.Ruiz filed a second PCR application on September 5, 2023, claiming actual innocence and ineffective assistance of both trial and appellate counsel. The State moved to dismiss this application as untimely, and the district court granted the motion, noting that the application was filed after the three-year statute of limitations had expired. Ruiz's appointed counsel did not file any briefs or additional pleadings on his behalf, and the district court dismissed the application without addressing its merits.The Iowa Court of Appeals affirmed the district court's dismissal, with one judge dissenting, arguing that Ruiz was denied effective assistance of PCR counsel. The Iowa Supreme Court reviewed the case and also affirmed the dismissal. The court held that Ruiz failed to preserve his equitable tolling argument and did not present any specific ways that PCR counsel could have prevented the dismissal of his action as time-barred. The court also found that Ruiz's claim of ineffective assistance of PCR counsel did not constitute structural error, as his first PCR application had been reviewed on the merits. Consequently, the court declined to remand the case for further proceedings. View "Ruiz v. State" on Justia Law

Marlene Banwart and her husband Richard filed a medical malpractice lawsuit in 2020 against Neurosurgery of North Iowa, P.C., Dr. David Beck, and Dr. Thomas Getta. Marlene had undergone a lumbar laminectomy performed by Dr. Beck in July 2018, followed by severe postoperative pain and complications, including an epidural hematoma that required emergency surgery. The plaintiffs alleged negligence in the surgery and postoperative care by Dr. Beck and Dr. Getta.The Iowa District Court for Cerro Gordo County ruled on cross-motions for summary judgment. The court dismissed the plaintiffs' action as time-barred, concluding that the Iowa Supreme Court's emergency supervisory orders tolling the statute of limitations during the COVID-19 pandemic were invalid. However, the court found that the plaintiffs had substantially complied with Iowa's certificate of merit affidavit statute, despite the certificates not being signed under oath or penalty of perjury. Both parties appealed these rulings.The Iowa Supreme Court reviewed the case and bypassed the statute of limitations issue, focusing on the cross-appeal regarding the certificate of merit. The court held that the plaintiffs' certificates did not substantially comply with Iowa Code section 147.140 because they were not signed under oath or penalty of perjury. The court also rejected the plaintiffs' claims that the statute was void for vagueness and that the defendants had waived their rights by delaying their challenge. Consequently, the court reversed the district court's ruling on the certificates of merit and remanded the case for entry of summary judgment in favor of the defendants. View "Banwart v. Neurosurgery of North Iowa, P.C." on Justia Law

In this case, an individual sought certiorari review of a district court order that declined to expunge two parole violation reports from 2006 and 2007. These reports were based on an arrest for driving while barred, a charge that was later dismissed and expunged. The individual argued that the parole violation reports should also be expunged under Iowa Code section 901C.2(1) because they were related to the dismissed charge.The Iowa District Court for Polk County denied the application for expungement, reasoning that the parole violation reports were administrative matters, not criminal cases, and thus not eligible for expungement under Chapter 901C. The court also denied the individual's alternative request to reclassify the case numbers to avoid the appearance of additional felony charges, stating that the FECR designation had no independent meaning and that reclassification would be a cosmetic remedy.The Iowa Supreme Court reviewed the case and concluded that the individual was not entitled to expungement under section 901C.2(1) because the parole violation reports were administrative proceedings, not criminal cases, and were not dismissed. The court also found that the reports were more logically tied to the original criminal case that resulted in the individual's incarceration and parole, which had not been expunged. Additionally, the court declined to order a reclassification of the case numbers, noting that certiorari relief was not available as the district court had not acted illegally or exceeded its jurisdiction.The Iowa Supreme Court annulled the writ, affirming the district court's decision to deny expungement and reclassification of the parole violation reports. View "Doe v. Iowa District Court For Polk County" on Justia Law

A defendant was convicted of third-degree theft after being caught on a store's video footage placing a bottle of liquor under his shirt and leaving without paying. He appealed his conviction and sentence, raising multiple challenges, including the denial of his motion to recuse the judge, the admission of hearsay testimony, the denial of his motion for a new trial, the remote nature of his sentencing hearing, and the imposition of consecutive sentences.The Iowa District Court for Greene County denied the defendant's motion to recuse, finding no evidence of bias or prejudice from the judge's previous representation of the defendant. The court also admitted a police officer's testimony about the defendant's friends' consistent version of events, which differed from the defendant's account, despite the defendant's hearsay objection. The court denied the defendant's motion for a new trial, as he failed to raise the issue of a missing witness until after the jury's verdict. The sentencing hearing was conducted remotely due to the judge testing positive for COVID-19, and the defendant did not object to this at the time.The Iowa Court of Appeals affirmed the conviction and sentence, rejecting the defendant's arguments. The defendant then sought further review from the Iowa Supreme Court.The Iowa Supreme Court affirmed the decisions of the lower courts. It held that the defendant did not demonstrate any bias or prejudice from the judge's previous representation. The court found that the hearsay testimony was cumulative and not prejudicial due to overwhelming evidence of the defendant's guilt. The court also ruled that the defendant failed to preserve error on his challenge to the remote sentencing hearing by not objecting at the time. Finally, the court found no abuse of discretion in the imposition of consecutive sentences, given the defendant's extensive criminal history and the need for rehabilitation and community protection. View "State of Iowa v. Pirie" on Justia Law

A school district insured its buildings through a policy that covered abrupt collapses caused by perils, including the weight of snow and ice. After a heavy snowstorm, part of the roof of an aged elementary school building collapsed into a second-floor classroom. The collapse and subsequent investigations revealed that load-bearing walls throughout the building had deteriorated, and the entire building was declared unsafe for occupancy. The school district demanded that the insurer pay to restore the load-bearing walls for the entire building, but the insurer agreed to pay only for the area of the collapse. The school district sued for the larger amount.The Iowa District Court for Polk County granted summary judgment for the insurer. The court concluded that the school district could only recover for the damage physically caused by the collapse. It also applied the policy’s “ordinance and law” provision exception for pre-existing code violations, finding that the deterioration within the load-bearing walls pre-dated the partial roof collapse and violated local building codes. The school district appealed the decision.The Iowa Supreme Court reviewed the case and affirmed the district court’s judgment. The court held that the insurer must only pay to repair the damage from the partial roof collapse but not the cost to remedy the longstanding deterioration in other areas of the building unaffected by the collapse. The court found that the policy’s exception for pre-existing code violations was unambiguous and applied regardless of whether the insured was aware of the deterioration before the collapse. The court emphasized that a contrary holding would convert the insurance policy into a general maintenance contract. View "Waterloo Community School District v. Employers Mutual Casualty Company" on Justia Law

Marleny Rivas filed a lawsuit against Derek Brownell and Lindsey Wessel to recover damages for injuries she sustained in a car accident on August 4, 2018. Rivas filed her lawsuit on October 16, 2020, beyond the two-year statute of limitations but within a seventy-six-day tolling period established by a supreme court supervisory order due to the COVID-19 pandemic.The defendants filed motions for summary judgment, arguing that the lawsuit was time-barred as it was filed beyond the two-year statute of limitations and that the supreme court's tolling provision violated the separation of powers and their due process rights. The Iowa District Court for Polk County granted the summary judgment, concluding that the supreme court lacked the authority to toll the statute of limitations, and thus Rivas's lawsuit was untimely. Rivas appealed the decision.The Iowa Supreme Court reviewed the case and addressed whether the supreme court had the emergency powers to toll the statute of limitations during the pandemic. The court held that the tolling provision in the supervisory order was within the court's constitutional authority to exercise supervisory and administrative control over the court system. The court found that the tolling provision was a valid response to the unprecedented public health emergency and did not violate the separation of powers or due process rights of the defendants. Consequently, the court reversed the district court's order of dismissal and remanded the case for further proceedings. View "Rivas v. Brownell" on Justia Law