Justia Iowa Supreme Court Opinion Summaries

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

Brothers Robert, Gary, and Richard Hunter, experienced farmers, converted their general partnership into a limited liability company (LLC) named Hunter Three Farms, LLC. Each brother owned twenty voting units, while Hunter of Iowa, Inc. owned forty nonvoting units. The LLC did not have an operating agreement but filed a statement of authority with the Iowa Secretary of State, which allowed a majority of voting members to make ordinary business decisions.In 2018, Richard submitted a claim to the Syngenta Corn Seed Settlement Program on behalf of "Hunter Farms" using the LLC's tax identification number, without informing his brothers. He received a $62,467.91 settlement payment, which he deposited into an account inaccessible to the LLC or his brothers. When Robert and Gary discovered the payment, they demanded Richard distribute the funds, but he refused, claiming entitlement to the entire amount. Robert and Gary then authorized the LLC to sue Richard to recover the settlement proceeds.The Iowa District Court for Greene County granted Richard's motion for summary judgment, ruling that the LLC lacked standing to sue without unanimous consent from all voting members, including Richard. The Iowa Court of Appeals reversed this decision, with a divided panel concluding that the LLC could sue Richard if all disinterested members authorized the litigation. The dissenting judge argued that unanimous consent was required.The Iowa Supreme Court reviewed the case and clarified that the issue was one of authority, not standing. The court held that a majority of the voting members could authorize the LLC to file a suit to recover funds owed to the company, as such actions are within the ordinary course of the LLC's activities. Consequently, the court vacated the decision of the Court of Appeals, reversed the district court's judgment, and remanded the case for further proceedings. View "Hunter Three Farms, LLC v. Hunter" on Justia Law

In 2016, a fourteen-year-old boy was involuntarily committed, disqualifying him from possessing firearms. Eight years later, he petitioned the district court to restore his firearm rights under Iowa Code section 724.31. The district court found that the statutory requirements were met and restored his firearm rights. The State appealed the decision.The Iowa District Court for Monona County initially reviewed the case and granted the petition to restore the petitioner’s firearm rights. The State then appealed the district court’s decision, arguing that the restoration requirements were not met and questioning the State’s right to appeal the decision.The Iowa Supreme Court reviewed the case and first addressed whether the State had the right to appeal the restoration order. The court concluded that the State did have the right to appeal under Iowa Rule of Appellate Procedure 6.103(1). The court then reviewed the merits of the case de novo and found that the petitioner had met the burden of proving by a preponderance of the evidence that he would not likely act in a manner dangerous to public safety and that granting the relief would not be contrary to the public interest. The court affirmed the district court’s order restoring the petitioner’s firearm rights. View "In re N.F." on Justia Law

The plaintiffs, peace officers employed by the Iowa Department of Corrections, alleged that they were disciplined following administrative investigations and subsequently requested copies of witness statements and investigation reports related to their cases. They claimed that the Department refused to provide these documents as required by Iowa Code chapter 80F. The officers filed a lawsuit seeking money damages and injunctive relief, asserting that the Department violated their rights under chapter 80F.The Iowa District Court for Polk County granted summary judgment in favor of the Iowa Department of Corrections, dismissing the officers' lawsuit. The district court concluded that chapter 80F did not grant the officers a right to bring a cause of action against their employing agency.The Iowa Supreme Court reviewed the case and affirmed the district court's decision. The court held that Iowa Code § 80F.1(13) does not provide a private right of action for officers against their employing agency. The court reasoned that the term "person" in § 80F.1(13) does not include government agencies, and the statute does not explicitly exempt the officers' claims from the exclusive remedies provided under the Iowa Administrative Procedure Act (chapter 17A). Therefore, the officers must follow the procedures outlined in chapter 17A to challenge the Department's actions. The court concluded that the officers' claims did not have a direct path to the courthouse through § 80F.1(13) and affirmed the summary judgment in favor of the Department. View "Chandler v. Iowa Department of Corrections" on Justia Law

Ezekiel Kieffer was convicted of domestic abuse assault impeding the flow of air or blood and domestic abuse assault causing injury after an altercation with his girlfriend, Daphne. The incident occurred after they returned intoxicated from a community event, leading to a physical confrontation where Kieffer strangled Daphne. Law enforcement was called, and Kieffer was charged and later convicted by a jury. He was sentenced to 180 days (with 93 days suspended) on each count, to be served concurrently, and was also subject to a firearm prohibition.In the Iowa District Court for Black Hawk County, Kieffer was found guilty on both charges. He appealed, arguing insufficient evidence of cohabitation with Daphne, a violation of the district court’s order in limine, and that the firearm prohibition violated his constitutional rights. The district court had denied his motion for a mistrial based on the State’s alleged violations of the order in limine and included a firearm prohibition in his sentencing order.The Iowa Supreme Court reviewed the case and affirmed the convictions and sentence. The court held that there was sufficient evidence to support the jury’s finding that Kieffer and Daphne were cohabiting, as they were in a serious relationship, and Daphne had moved in with Kieffer. The court also found that the district court did not abuse its discretion in denying Kieffer’s motion for a mistrial, as the alleged violations of the order in limine were promptly addressed and cured. Lastly, the court rejected Kieffer’s constitutional challenge to the firearm prohibition under the Second Amendment, citing recent federal jurisprudence upholding similar prohibitions. The court did not address the state constitutional challenge under article I, section 1A, as it was not necessary for the disposition of the case. View "State of Iowa v. Kieffer" on Justia Law

In June 2020, fourteen-year-old K.S. reported to the Sioux City Police Department that Taylor Smith, then twenty-three, had sexually assaulted her, resulting in her pregnancy. A DNA test confirmed Smith as the father. Smith was charged with third-degree sexual abuse, a class “C” felony, under Iowa Code section 709.4(1)(b)(3)(d). After a bench trial, Smith was found guilty. At sentencing, the district court imposed a $1,370 fine, which coincided with the increased minimum fine effective after the offense, and issued a notice of firearm prohibition.The Iowa District Court for Woodbury County sentenced Smith to an indeterminate term not exceeding ten years, imposed a $1,370 fine (suspended), a 15% crime services surcharge (suspended), and a $90 sexual abuse surcharge. The court also issued a notice of firearm prohibition based on Smith’s felony conviction. Smith appealed, arguing that the district court abused its discretion by imposing a fine based on an incorrect statutory range and challenged the firearm prohibition notice as unconstitutional.The Iowa Supreme Court reviewed the case. The court found that the district court misunderstood the applicable fine range, which should have been $1,000 to $10,000, not the increased range effective after the offense. This misunderstanding constituted an abuse of discretion. Consequently, the court vacated the fine portion of Smith’s sentence and remanded for resentencing. Regarding the firearm prohibition notice, the court determined it was not reviewable on direct appeal as it was not a term of Smith’s sentence but rather a collateral consequence of his felony conviction. Thus, the court did not address the constitutional challenges to the firearm prohibition. View "State of Iowa v. Smith" on Justia Law