Justia Iowa Supreme Court Opinion Summaries

An information security executive was hired by a financial institution to improve its internal controls but was later terminated. During her tenure, a subordinate raised concerns about compliance, which led to an internal audit and ultimately contributed to the decision to fire her. She believed her firing was motivated by sex discrimination and defamatory statements made by colleagues regarding her job performance. She first filed a complaint with the Iowa Civil Rights Commission, then a federal lawsuit against her employer and several individuals, alleging discrimination, defamation, and other claims. Most of her claims, including defamation, were dismissed by the United States District Court for the Southern District of Iowa for failure to state a claim, and summary judgment was granted to the defendants on the remaining claims. She did not appeal.Several months after her federal lawsuit concluded, she filed a new defamation action in the Iowa District Court for Polk County against a different set of coworkers, based on statements and internal reports from more than three years prior. The defendants moved to dismiss, arguing that the claims were barred by Iowa’s two-year statute of limitations for injuries to reputation. The district court granted the motion to dismiss, finding that the limitations period began at publication or, alternatively, that she was on inquiry notice of the claims by the time she filed her first lawsuit.On appeal, the Iowa Court of Appeals reversed, holding that the discovery rule might apply to defamation claims and that factual issues about notice precluded dismissal. Upon further review, the Iowa Supreme Court vacated the appellate decision and affirmed the district court’s dismissal, holding that the plaintiff was on inquiry notice of her defamation claims more than two years before filing suit, so the claims were time-barred regardless of the discovery rule’s application. View "Betz v. Mathisen" on Justia Law

A corrections officer at the Anamosa State Penitentiary was killed during a prison escape attempt in March 2021, along with a nurse, when two inmates armed themselves with tools from the prison’s machine shop and attacked staff in the infirmary. The inmates were apprehended and convicted of first-degree murder. The officer’s surviving spouse filed compensation claims with the state appeal board against co-employees of the Iowa Department of Corrections, alleging gross negligence contributed to the security lapses that enabled the attack. The claims identified several co-employees by name as potential parties at fault.After the claims were withdrawn due to lack of resolution, the surviving spouse filed suit in the Iowa District Court for Jones County against twenty-six co-employees, including some not previously named in the administrative process. The defendants moved to dismiss, arguing that Iowa’s workers’ compensation law precluded gross negligence claims against state or local government co-employees, that the spouse failed to comply with administrative requirements under the Iowa Tort Claims Act (ITCA), and that the pleading was insufficient under qualified immunity standards. The district court denied the motion on all grounds.The Iowa Supreme Court reviewed the case after treating the appeal as an interlocutory application. The court held that Iowa Code section 85.2 does not bar gross negligence claims against state co-employees; such claims are permissible under section 85.20(2). The court also found that, while the administrative claims process under the ITCA was satisfied as to those co-employees named in the initial claims, it was not satisfied for those not identified. Therefore, the motion to dismiss was properly denied for co-employees named in the administrative claims and should have been granted for those who were not. The denial was affirmed in part, reversed in part, and the case remanded. View "Montague v. Skinner" on Justia Law

The defendant faced four criminal charges in separate cases—three for theft (shoplifting) and one for interference with official acts following an arrest. As part of a single plea agreement, he pled guilty to two theft charges; in return, the State dismissed the remaining two cases, with the defendant agreeing to pay costs in the dismissed cases. The Iowa District Court for Polk County sentenced the defendant in the two theft cases, dismissed the other two, and ordered him to pay costs for the dismissed cases, including indigent defense recoupment and filing fees.After the district court’s dispositional orders, the defendant appealed, challenging the court’s authority to assess costs in the dismissed cases. The Iowa Supreme Court granted discretionary review to address this issue. The State conceded that no statute authorized the district court to impose costs in dismissed criminal cases. The Supreme Court examined relevant statutory provisions, noting that neither Chapter 815 nor Chapter 910 of the Iowa Code allows for assessment of costs against a defendant when a case is dismissed, as such authority was repealed in 2012.The Iowa Supreme Court held that parties cannot confer statutory authority on the court through a plea agreement for a disposition not authorized by statute. Accordingly, the district court’s orders assessing costs in the dismissed cases were ultra vires and invalid. The Supreme Court vacated the convictions, sentences, and dispositional orders, and remanded the cases. On remand, the State may elect either to vacate only the unauthorized cost orders while enforcing the remainder of the plea bargain, or to vacate the entire plea agreement and all resulting orders, with the option to reinstate any dismissed charges. View "State of Iowa v. Pagliai" on Justia Law

This case concerns a dispute over waterfront access involving two neighboring parties. Donald and Linda Lawson purchased Lot 21, which was situated near the Maquoketa River, in 2002. Their decision to buy the property was influenced by a well-cleared path leading to the water, which they believed was covered by an easement. The easement deed they received purported to grant them access across adjacent lots 19 and 20 to the river. However, the deed contained critical errors: the grantor was incorrectly named, and the legal description of the easement did not actually reach the riverbank or follow the usable path.After Mark and Stacey Fink acquired lots 19 and 20 in 2021, they disputed the Lawsons’ right to use the path and initiated a lawsuit seeking to quiet title, damages, and other relief. The Lawsons defended on the basis of various types of easements and counterclaimed to quiet title for the easement. The Iowa District Court for Delaware County denied the Lawsons’ request for reformation of the easement deed, granted quiet title to the Finks, and rejected the Lawsons’ defenses and counterclaims. The Lawsons appealed, and the Iowa Court of Appeals affirmed most of the district court’s rulings but identified an error regarding the prescriptive easement defense.On further review, the Iowa Supreme Court conducted a de novo review and held that the district court had the equitable power to reform the faulty easement deed to reflect the express intent of the grantor and the actual agreement between the original parties. The court found clear, convincing evidence of mutual mistake regarding both the grantor’s identity and the path’s legal description. Therefore, the Supreme Court vacated the decision of the court of appeals, reversed the district court’s judgment, and remanded for reformation of the easement deed consistent with its opinion. View "Fink v. Lawson" on Justia Law

Two tenants rented a duplex in Iowa City and became frustrated by frequent showings of their rental unit by their landlord to prospective tenants for the next lease period. Although their lease allowed the landlord to enter with the tenants’ consent and required at least twenty-four hours’ notice, the landlord sometimes entered outside a scheduled window and, on a few occasions, without prior notice. The tenants objected to showings without notice and occasionally refused entry. They eventually filed a small claims action, alleging multiple instances of common law trespass and seeking damages and attorney fees.A magistrate in the Iowa District Court for Johnson County found that four trespasses occurred—two on the same day and two on separate days—and awarded damages equaling three days’ rent, but denied attorney fees, reasoning that the relevant statute only applied to rental deposit disputes. The district court affirmed most of the magistrate’s decision, slightly increasing the damages to three and a half days’ rent to account for the second trespass on the same day, but likewise denied attorney fees.On appeal, the Iowa Supreme Court affirmed the district court’s judgment. The court held that consent, whether express or implied, negates trespass, and that the tenants’ actions reasonably led the landlord to believe entry was permitted for the contested showings. The court found no basis for additional trespass findings. It also concluded that the district court’s damages award was supported by the record and that Iowa Code section 562A.12(8) authorizes attorney fees only in rental deposit disputes, not in common law trespass actions. Thus, the denial of attorney fees was affirmed. View "Butter v. Midwest Property Management IC, LLC" on Justia Law

A man was convicted of second-degree sexual abuse arising from the abuse of his seven-year-old granddaughter. The alleged abuse occurred when the child and her brother visited their grandparents’ home. The granddaughter testified that the defendant touched her genitals after she asked for a belly rub, and that he told her not to reveal what had happened. Later that day, she disclosed the abuse to her family, and her father, a police officer, confronted the defendant. The defendant made statements about “helping [her] explore her sexuality” to both his son-in-law and his wife. The next day, police arrested the defendant, who was questioned after being transported to the station.In the Iowa District Court for Polk County, the defendant moved to suppress his confession, arguing his statutory and constitutional rights were violated. The district court found a violation of his statutory right under Iowa Code section 804.20 to make a phone call, and suppressed his confession, but rejected his constitutional right-to-counsel claim. The jury, without hearing the confession, convicted the defendant. The court also permitted the child to testify via one-way closed-circuit television, over defense objection, and allowed the defendant’s then-wife to testify about his statements to her.On appeal, the Supreme Court of Iowa found sufficient evidence to support the conviction based on the child’s testimony. However, the court held that allowing the complaining witness to testify via one-way closed-circuit television violated the defendant’s state constitutional right to face-to-face confrontation under article I, section 10 of the Iowa Constitution, as interpreted in State v. White. The court concluded this error was not harmless, vacated the conviction, and remanded for a new trial. The court affirmed the admissibility of the wife’s testimony, reversed the suppression of the confession, and rejected the constitutional right-to-counsel claim. View "State of Iowa v. Lindaman" on Justia Law

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