Justia Iowa Supreme Court Opinion Summaries

Sarah Kingsbury, a pharmacy technician, suffered a workplace injury at Walmart in August 2021 and subsequently sought workers’ compensation benefits for injuries to her right lower extremity and right shoulder. She later amended her claim to include the Second Injury Fund of Iowa, citing a prior left lower extremity injury from 2009. Kingsbury and Walmart entered into a compromise settlement in which Walmart did not admit the extent of permanent disability, though it accepted responsibility for the injury itself. The settlement was for a lump sum and explicitly released Walmart from all further liability related to the injury, without specifying a degree of permanent disability.The deputy workers’ compensation commissioner granted summary judgment to the Fund, finding that Kingsbury’s settlement with Walmart precluded her from proving a compensable permanent disability necessary to trigger Fund liability. The commissioner affirmed this decision. Kingsbury sought judicial review, and the Iowa District Court for Polk County reversed the commissioner’s decision, concluding the settlement with Walmart did not bar her claim against the Fund.The Supreme Court of Iowa reviewed the case and held that, under Iowa Code section 85.35(10), a compromise settlement with an employer that does not establish liability for permanent disability bars a subsequent claim against the Second Injury Fund for the same subject matter. The court reasoned that Fund liability is contingent upon first establishing the employer’s liability for permanent disability, which was not done here due to the nature of the compromise settlement. Therefore, the Supreme Court of Iowa reversed the district court’s ruling and remanded the case with instructions to affirm the commissioner’s dismissal of Kingsbury’s claim against the Fund. View "Kingsbury v. Second Injury Fund of Iowa" on Justia Law

A renewable energy developer spent several years and millions of dollars planning a large wind turbine project across numerous parcels in Worth County, Iowa. The developer did not select a turbine model or finalize the number and placement of turbines, nor did it apply for or secure any county permits for the construction or operation of the turbines. The only permits obtained related to meteorological towers. While the developer’s preliminary activities were extensive, they did not include actual construction of any turbines. At the time, part of the county was zoned, but most was unzoned and did not require permits for such projects.Public opinion shifted against wind energy development, leading to the election of new county supervisors. In response, the Worth County Board of Supervisors imposed a temporary moratorium on commercial wind energy systems while drafting new regulations. Eventually, the Board enacted an ordinance imposing setbacks, maximum turbine heights, noise limits, and shadow flicker restrictions. Rather than seeking waivers or adapting the project to the new rules, the developer filed suit, arguing it had vested rights under the prior regulatory framework and that the county acted in bad faith. After a bench trial, the Iowa District Court for Worth County ruled for the developer, finding both vested rights and bad faith.The Supreme Court of Iowa reviewed the case de novo and reversed the district court’s decision. The Supreme Court held that, under Iowa law, the vested rights doctrine applies only where a developer has obtained a permit or formal governmental approval for the project. Since the developer had not applied for or received such approval for the turbines, no vested rights existed. The court further found no evidence of illegality or improper purpose in the county’s actions, rejecting the bad faith claim. The court remanded the case for further proceedings on any remaining claims. View "Worthwhile Wind, LLC v. Worth County Board of Supervisors" on Justia Law

A manufacturer of specialized products for road construction and a supplier had a longstanding business relationship, with the supplier relying heavily on the manufacturer’s goods for government paving projects. In 2021, the manufacturer faced supply chain disruptions and increased material costs due to the COVID-19 pandemic, leading to missed deliveries and eventually an ultimatum: the supplier must accept significant price increases on existing contracts or the business relationship would end. The supplier rejected the increases, deemed the manufacturer in breach, and procured substitute products from other vendors at prevailing market rates, which were significantly higher than the manufacturer’s proposed increased prices.The Iowa District Court for Cedar County held a bench trial, finding that contracts existed and were breached by the manufacturer when it refused to honor the original prices. The court awarded damages to both parties for breaches but offset the sums, ultimately finding the supplier’s cover purchases reasonable under the circumstances. Both parties appealed. The Iowa Court of Appeals affirmed the district court’s findings regarding contract formation, breach, and damages, including the reasonableness of the supplier’s cover purchases, but remanded for correction of prejudgment interest calculations.The Iowa Supreme Court reviewed only the question of whether the supplier’s procurement of substitute goods constituted reasonable “cover” under Iowa Code section 554.2712, given the manufacturer’s post-breach offer to fill the orders at a higher price. The court held that a buyer is not obligated to accept a breaching seller’s new terms to mitigate damages and that “cover” does not require dealing with the breaching seller. Substantial evidence supported the lower court’s finding that the supplier’s cover purchases were reasonable, even though they cost more than the manufacturer’s increased prices. The district court’s judgment was affirmed in relevant part, except regarding double prejudgment interest, which was remanded for correction. View "CMT Highway, LLC v. Logan Contractors Supply, Inc." on Justia Law

A long-serving and well-regarded police sergeant with the Des Moines Police Department experienced significant mental health difficulties after his close friend and fellow officer died by suicide. Several months later, following a night of heavy drinking at a family event, the sergeant drove while intoxicated and was arrested after engaging in belligerent and threatening conduct toward other officers. He subsequently sought psychological help and was diagnosed with post-traumatic stress disorder (PTSD) linked to his friend’s death. The police chief terminated his employment the day after he disclosed his PTSD diagnosis, despite his remorse and efforts to seek treatment.The sergeant brought suit in the Iowa District Court for Polk County under the Iowa Civil Rights Act, alleging that his termination constituted disability discrimination and that the city failed to provide a reasonable accommodation for his PTSD. At trial, the jury found in his favor on both claims and awarded substantial damages. The district court entered judgment for the plaintiff. The City appealed, arguing that the jury’s verdict was tainted by an erroneous jury instruction and that no reasonable accommodation was timely requested.On appeal, the Iowa Court of Appeals found that the evidence supported submitting the disability discrimination claim to the jury but determined that the jury instructions given—particularly one about stereotypes and unconscious bias—misstated the law and warranted a new trial on that claim. The appellate court also ruled that the failure-to-accommodate claim failed as a matter of law because the request for accommodation came only after misconduct occurred. The Iowa Supreme Court affirmed the appellate court’s decision, reversed the district court’s judgment, and remanded for a new trial on the disability-discrimination claim, holding that the instructional error required a new trial and that the failure-to-accommodate claim could not proceed. View "Hunter v. City of Des Moines, Iowa" on Justia Law

A school board in Iowa held two closed sessions in 2022 involving its then-superintendent. The first session was conducted at the superintendent’s request to evaluate his professional competency, following concerns raised by board members about conversations at a prior association meeting that some interpreted as attempts at undue influence in board leadership decisions. The board discussed these ethical concerns and whether to seek legal advice, before continuing the evaluation with the superintendent present. Later, after the superintendent left the district, the board held another closed session to discuss the possible filing of an ethics complaint against him, focusing on both the earlier conversations and an unrelated alleged disclosure of confidential information.The Iowa District Court for Woodbury County found that the first closed session violated the Iowa Open Meetings Act because the initial discussion was not directly related to the superintendent’s evaluation, but rather to a potential investigation and complaint. The court found no violation regarding the second session, reasoning that the records discussed were confidential and thus justified a closed meeting. For the first session, the court imposed statutory damages and attorney fees against one board member, while finding the other members acted in good faith.The Supreme Court of Iowa reviewed the case, considering whether the discussions in each session were permissible under the exceptions to the Iowa Open Meetings Act. The court concluded that the first session’s discussion of ethical concerns was directly related to evaluating the superintendent’s professional competency and thus fell within the statutory exception. Regarding the second session, the court held that the board's discussion of draft complaints intended for submission to a regulatory body qualified as review of confidential records, also justifying a closed session. The Supreme Court of Iowa reversed the district court’s finding of a violation and attorney fee award for the first meeting, and affirmed the decision for the second meeting. View "Gausman v. Sioux City Community School District" on Justia Law

This case arose after the City of Davenport settled three harassment claims with city employees for approximately $1.9 million. The settlements were publicly approved by the city council in December 2023, but there were allegations suggesting that the agreements were reached before the November 2023 city election and were intentionally announced afterward. The Iowa Auditor of State initiated a reaudit focusing on these settlements and issued a subpoena to the City requesting documents, including minutes and recordings of closed city council sessions. The City provided some documents but withheld others, citing attorney–client privilege and the attorney work-product privilege, and sought to modify the subpoena in Scott County District Court.The Iowa District Court for Scott County reviewed the matter and initially ordered the City to produce the closed-session materials for in camera review to determine if they constituted attorney work product. In a subsequent order, the court held that while the Auditor could not access attorney work product, Iowa law did permit access to attorney–client privileged communications, as the statutory exceptions did not explicitly include such privilege. The court planned an evidentiary hearing to clarify relevance but confirmed its intent to review the materials in camera, potentially granting the Auditor access to attorney–client privileged communications.The Supreme Court of Iowa reviewed the case on interlocutory appeal. The Court held that the attorney–client privilege is a longstanding protection under Iowa law and is not displaced by the statutory provisions governing the Auditor’s subpoena power, which do not expressly override the privilege. The Court concluded that the attorney–client privilege limits the Auditor’s access to materials, just as it does for other investigative bodies. The Supreme Court of Iowa reversed the district court’s ruling and remanded the case for further proceedings consistent with its opinion. View "City of Davenport v. Office of Auditor of State of Iowa" on Justia Law

A vehicle was reported stolen in La Crosse, Wisconsin. The following day, Dillon Heiller was found in possession of the vehicle in Waukon, Iowa, and was arrested by local police after being observed acting suspiciously by a homeowner, who then called authorities. Heiller was charged in Allamakee County with theft by taking, specifically for taking possession or control of the vehicle with intent to deprive the owner. At trial, the State presented evidence that Heiller was in possession of the vehicle in Iowa, but did not call the vehicle’s owner as a witness. Heiller testified that he had purchased the vehicle from another individual. The jury convicted him of theft in the second degree.The Iowa District Court for Allamakee County denied Heiller's motion for acquittal on jurisdictional grounds, and the Iowa Court of Appeals affirmed the conviction, holding that Heiller had not preserved error on the issue of Iowa’s criminal jurisdiction because he did not request a related jury instruction. The court of appeals applied its earlier decision in a companion case, concluding that the jurisdictional issue could not be raised for the first time on appeal.Upon further review, the Supreme Court of Iowa held that Iowa’s criminal jurisdiction statute (Iowa Code section 803.1) establishes nonwaivable prerequisites for prosecution, and the question of criminal jurisdiction is a question of law for the court, not an element for the jury. The court found that no element of theft by taking occurred in Iowa; the act of taking occurred in Wisconsin. Accordingly, Iowa lacked statutory authority to prosecute Heiller for theft by taking or any lesser included offense. The Supreme Court of Iowa vacated the court of appeals’ decision, vacated the conviction and sentence, and remanded the case to the district court. View "State of Iowa v. Heiller" on Justia Law

An employee of a plumbing subcontractor was injured when a trench collapsed at a residential construction site, resulting in serious physical and emotional harm. The employee had been directed by his supervisor to enter a trench that did not comply with OSHA safety regulations. The general contractor for the project was not present at the site and only learned of the accident months later, after an OSHA investigation. The subcontractor, not the general contractor, was responsible for the trenching work and the day-to-day safety of its employees.After receiving workers’ compensation and settling gross negligence claims against his co-employees, the injured worker proceeded to trial solely on a negligence claim against the general contractor. The Iowa District Court for Polk County denied the general contractor’s motions for directed verdict and judgment notwithstanding the verdict, allowing the case to go to a jury, which found the general contractor liable and awarded substantial compensatory and punitive damages.The Supreme Court of Iowa reviewed the case and reversed the district court’s decision. The court held that, as a general rule, a general contractor does not owe a duty of care to the employees of an independent contractor. The court found that neither the “retained control” nor “peculiar risk” exceptions to this rule applied. The general contractor did not retain operative control over the subcontractor’s work, either by contract or by conduct, and residential trenching work is not inherently or peculiarly dangerous as a matter of law under Iowa precedent. Accordingly, the Supreme Court of Iowa held that the general contractor was entitled to judgment notwithstanding the verdict and reversed the lower court’s ruling. View "Kono v. D.R. Horton, Inc." on Justia Law

A patient underwent surgery on September 4, 2020, and died twelve days later. Her estate and children brought a medical malpractice suit against the surgeon and hospital, alleging negligence. The defendants sought dismissal, arguing the plaintiffs had not satisfied Iowa’s certificate of merit requirements under Iowa Code section 147.140(1), which mandates a supporting expert affidavit early in medical malpractice litigation. The district court denied the motion to dismiss.The defendants then sought interlocutory review from the Iowa Supreme Court. The Iowa Supreme Court reversed the district court’s denial, finding the plaintiffs had not complied with the statutory affidavit requirement, and remanded with instructions to dismiss the case with prejudice. Following the remand, the plaintiffs attempted to file dismissals without prejudice before and after the district court’s order of dismissal with prejudice. Despite these filings, the district court entered a dismissal with prejudice as directed by the Iowa Supreme Court. The plaintiffs then filed a new lawsuit asserting the same claims against the same defendants. The defendants moved to dismiss this second action, citing claim preclusion (res judicata) and the statute of limitations. The Iowa District Court for Clinton County dismissed the second action.On appeal, the Iowa Supreme Court affirmed the dismissal. The court held that its prior mandate required dismissal with prejudice, and any attempt by the plaintiffs to dismiss without prejudice was contrary to that mandate and thus ineffective. The court found that the elements of claim preclusion were satisfied: the parties and claims were identical to the prior action, and there was a final judgment on the merits. Accordingly, the second lawsuit was barred. The Iowa Supreme Court affirmed the district court’s dismissal on claim preclusion grounds. View "Shontz v. Mercy Medical Center-Clinton, Inc." on Justia Law

The case involves two drainage districts in Pottawattamie County, Iowa, which undertook a reclassification process after proposing improvements to levees under their management. The reclassification determined how costs for the improvements would be apportioned among properties benefitting from the work. The Iowa Department of Transportation (IDOT) owns state highway land running through the districts, comprising less than 5% of the land but, under the reclassification, was assigned more than 75% of the costs. The method for assessing IDOT’s benefit relied largely on projected benefits to motorists, such as avoided delays from fewer road closures, rather than on direct benefits to the highway property or its owner.The boards of trustees for the districts approved the reclassification despite IDOT’s objections. IDOT then sought judicial review in the Iowa District Court for Pottawattamie County, arguing that the assessment method violated Iowa Code section 307.45 and that assessments should be based on benefits to the property or its owner, not third-party users. The district court set aside the reclassifications, agreeing that section 307.45 applied and that the assessments were not conducted in a uniform manner as required by that statute. However, the district court did not limit the scope of “benefits” solely to those accruing to the property or its owner.On appeal, the Supreme Court of Iowa affirmed the district court’s decision to set aside the reclassification but modified the reasoning. The court held that Iowa Code section 307.45 does not apply to drainage districts, as they are not cities, counties, or subdivisions thereof. The court further held that assessments against IDOT highway property must be based only on benefits to the property and its owner—the State—not on benefits to non-owner users such as motorists. The judgment was affirmed as modified. View "State of Iowa, ex rel. Iowa Department of Transportation v. Honey Creek Drainage District No. 6 Board of Trustees" on Justia Law