Justia Iowa Supreme Court Opinion Summaries

An elderly man with three children experienced a decline in health and mental capacity in his later years. After years of being cared for by one daughter, another daughter moved in, leading to significant family conflict. Shortly before his death, the man executed a new will, with the assistance of his attorney and after a medical evaluation confirmed his competency. This new will greatly favored one daughter over the others, and included a no-contest clause that would disinherit any beneficiary who challenged the will.After the man's death, the favored daughter, named as executor, admitted the will to probate. The other two children, feeling aggrieved by the changes, filed a lawsuit to set aside the will, alleging lack of testamentary capacity and undue influence by the favored daughter. A jury rejected their claims. When the executor filed the estate’s final report, the disfavored daughter objected, arguing that the no-contest clause should not apply because her challenge was made in good faith and with probable cause. The Iowa District Court for Clinton County overruled her objections, finding a lack of good faith and probable cause.On appeal, the Iowa Supreme Court clarified Iowa’s standards for avoiding enforcement of a no-contest clause: the challenger bears the burden to prove, under a totality-of-the-circumstances test, both subjective good faith and objective probable cause, as defined by the Restatement (Third) of Property. The court applied these standards de novo, giving deference to the district court’s factual findings, and concluded the appellant failed to meet her burden. Thus, the Supreme Court affirmed the district court’s enforcement of the no-contest clause and denial of the appellant’s objections to the final report. View "Felten v. Hoffman" on Justia Law

A candidate for city clerk with over ten years of experience working for the city requested her hiring interview with the Cedar Rapids City Council be conducted in a closed session, citing concerns about potential harm to her reputation if the interview were public and livestreamed. The council unanimously voted to honor her request and held the interview in closed session pursuant to Iowa Code § 21.5(1)(i), which allows closed sessions to protect an individual’s reputation when the individual requests it. The interview proceeded positively, and the candidate was later hired at a subsequent open meeting.A resident challenged the closed session, arguing that the council had violated the Iowa Open Meetings Act by not making an evidence-based determination of reputational harm before closing the interview. After a bench trial, the Iowa District Court for Linn County held that the council had not violated the statute, finding that a specific reputational threat need not be identified prior to closure if the interviewee requests it and the nature of the interview is unpredictable. The district court dismissed the case with prejudice.The Iowa Court of Appeals reversed, ruling that the city council should have conducted further inquiry into the necessity of closing the session and that a candidate’s request alone was insufficient without evidence of reputational harm. Upon further review, the Supreme Court of Iowa vacated the decision of the court of appeals and affirmed the district court’s judgment. The Supreme Court held that under Iowa Code § 21.5(1)(i), a governmental body may close a hiring interview at the candidate’s request as a precaution to protect reputation, without needing evidence of specific harm. The court also upheld the confidentiality of closed session records and found no error regarding courtroom access during trial. View "Teig v. Loeffler" on Justia Law

A high-speed police pursuit in Iowa ended with a motorcycle crash that left the rider, Augustin G. Mormann, paralyzed and ultimately led to his death after life support was withdrawn. The chase began when an Iowa State Trooper attempted to stop Mormann for speeding, but he fled, weaving through traffic and entering residential neighborhoods. The trooper disengaged due to safety concerns, but Manchester police officer James Wessels continued the pursuit at speeds exceeding 100 miles per hour. During the chase on a county road, Wessels’s police cruiser struck Mormann's motorcycle, leading to a crash that caused catastrophic injuries. Mormann was hospitalized, tested positive for methamphetamine, and died after choosing to discontinue life support. His family subsequently filed a civil suit against Wessels and the City of Manchester.In the Iowa District Court for Delaware County, the plaintiffs asserted claims including constitutional violations and, ultimately, common law assault and battery. The district court dismissed the constitutional claims after a change in Iowa law but allowed the assault and battery claims to proceed to trial. The jury found Wessels liable for both torts, awarding $4.25 million in compensatory damages and $10,000 in punitive damages. The court denied post-trial motions for judgment notwithstanding the verdict and for a new trial.The Iowa Supreme Court reviewed the case and affirmed the district court’s judgment. The court held that emergency response immunity under Iowa law does not shield a municipality or its officer from liability when the officer acts with reckless disregard for safety, as found by the jury. The court also concluded that the assault and battery claims were sufficiently pleaded under Iowa’s notice pleading standard, that there was substantial evidence to support the jury’s verdicts, and that the admission of the decedent’s dying declaration and evidence regarding police recording policies was proper. The punitive damages award was also upheld. View "Mormann v. City of Manchester, Iowa" on Justia Law

The case involves claims brought by the parents of a minor child, P.F., who was allegedly bullied, harassed, and assaulted by another student at Clay Elementary School during the 2022–2023 school year due to his sexual orientation. The parents assert that the school district and three employees were aware of these incidents but failed to protect P.F. or notify his parents, instead blaming P.F. or dismissing the other student’s conduct. After removing P.F. from the school and filing reports with authorities, the parents pursued legal action, first filing a complaint with the Iowa Civil Rights Commission (ICRC), which issued a right-to-sue letter. The parents then filed an amended petition in the Iowa District Court for Polk County, asserting three claims under the Iowa Civil Rights Act (ICRA) and three common law tort claims.The defendants moved to dismiss all claims, arguing that the heightened pleading requirements and qualified immunity provisions of the Iowa Municipal Tort Claims Act (IMTCA), as amended by Iowa Code section 670.4A, applied. The Iowa District Court for Polk County denied the motion, finding that the ICRA claims were not torts subject to the IMTCA and that the common law claims met the IMTCA’s pleading standard. The defendants appealed, asserting a right to immediate appeal under section 670.4A(4).The Iowa Supreme Court reviewed the appeal and held that the IMTCA’s qualified immunity and heightened pleading requirements do not apply to claims brought under the ICRA or to common law tort claims, as clarified in Doe v. Western Dubuque Community School District. Because section 670.4A did not apply to any of the claims, the defendants were not entitled to an appeal as of right. The court dismissed the appeal for lack of appellate jurisdiction and remanded the case. View "Fogle v. Clay Elementary School-Southeast Polk Community School District" on Justia Law

In this case, two women in Boone, Iowa, reported separate incidents in which a man exposed himself to them in retail parking lots in the spring of 2022. Both women described the perpetrator and his vehicle, and law enforcement investigations led to Pat Kepner as a suspect. The identification process included photo arrays and video footage, with one woman identifying Kepner in a photo array and both later identifying him from video. Kepner was charged with two counts of indecent exposure, and at trial, the eyewitnesses’ identifications were central to the State’s case.At trial in the Iowa District Court for Boone County, Kepner sought to introduce expert testimony from Dr. Kim MacLin, a psychologist specializing in memory and eyewitness identification. Dr. MacLin’s proposed testimony focused on general scientific principles regarding the reliability of eyewitness identifications and the effects of investigative procedures on witness confidence and accuracy. The district court excluded this testimony, reasoning that it would improperly address witness credibility and could confuse the jury. The jury convicted Kepner on both counts, and the district court entered a suspended sentence. The Iowa Court of Appeals affirmed the conviction, finding no abuse of discretion in excluding the expert testimony.The Supreme Court of Iowa reviewed the case and held that the district court abused its discretion by categorically excluding Dr. MacLin’s generalized expert testimony. The court clarified that such testimony, which does not directly or indirectly vouch for a witness’s credibility but instead provides general scientific context, is admissible and can assist the jury in evaluating eyewitness identifications. The court further found that the exclusion of this testimony was prejudicial given the centrality of identification to the case. Accordingly, the Supreme Court of Iowa vacated the decision of the Court of Appeals, reversed the district court’s judgment, and remanded the case for a new trial. View "State of Iowa v. Kepner" on Justia Law

Frederick Hawkins III was involved in a series of assaults against three women at a church in Ames, Iowa, where a nonprofit organization was serving meals. Over the course of a few minutes, Hawkins assaulted M.B. in a stairwell by grabbing her, rubbing his genitals against her, and putting his hand down her pants. He then slapped or grabbed C.C.’s buttocks as she passed him on the stairs, and shortly after, in an elevator, he touched E.M.’s buttocks while making sexually suggestive remarks and gestures. Hawkins was apprehended at the scene after police were called.The Iowa District Court for Story County, after a bench trial, found Hawkins guilty of three counts of assault with intent to commit sexual abuse, rejecting his diminished responsibility defense and finding sufficient evidence of specific intent for each assault. Hawkins appealed, arguing there was insufficient evidence of specific intent to commit sexual abuse regarding the assaults on C.C. and E.M. The Iowa Court of Appeals affirmed the convictions, holding that substantial evidence supported the findings of specific intent, and remanded for resentencing due to a sentencing error.The Supreme Court of Iowa reviewed only the sufficiency of the evidence regarding Hawkins’s specific intent to commit sexual abuse against C.C. and E.M. The court held that, considering the totality of the circumstances—including the rapid succession and similarity of the assaults, Hawkins’s conduct, and the context of the events—there was substantial circumstantial evidence from which a rational factfinder could infer specific intent for all three assaults. The court affirmed the convictions but vacated the sentence due to the conceded sentencing error and remanded for a new sentencing hearing. View "State of Iowa v. Hawkins" on Justia Law

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