Justia Iowa Supreme Court Opinion Summaries

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

Jessenia Burton, a student driver, was involved in a car accident during a drivers' education course on April 30, 2017. Burton and her parents sued several defendants, including West Bend Mutual Insurance Company, which provided coverage for the vehicles used in the course. Burton retained neuropsychologist Dr. Daniel Tranel, who conducted an evaluation and diagnosed her with a concussion, postconcussion syndrome, PTSD, and major depressive disorder. Dr. Tranel's report included summaries of psychological and neuropsychological tests administered to Burton.The Iowa District Court for Polk County granted West Bend's motion to compel the production of Dr. Tranel's psychological test material and test data. The court reasoned that since Burton made her mental condition an element of her claim, the information was discoverable under Iowa Code section 228.6(4)(a). The court ordered the information to be produced to West Bend and its attorneys, issuing a protective order to limit further disclosure.The Iowa Supreme Court reviewed the case and reversed the district court's decision. The court held that Iowa Code section 228.9 explicitly prohibits the disclosure of psychological test material and test data in a judicial proceeding to anyone other than a licensed psychologist designated by the individual. The court emphasized that the statute's language is clear and unambiguous, and the only exception to this prohibition is disclosure to another licensed psychologist. The court concluded that the district court erred in granting the motion to compel and vacated the protective order. The case was remanded for further proceedings consistent with this interpretation. View "Burton v. West Bend Mutual Insurance Company" on Justia Law

A vacancy on the Scott County Board of Supervisors occurred when Tony Knobbe resigned to become the Scott County Treasurer. A committee of county officials decided to fill the vacancy by appointment and kept certain applications confidential during the process. The committee referred to applicants by numbers and only revealed the name of the appointed individual. After the appointment, two individuals submitted open records requests for the confidential names and applications, which Scott County denied, citing Iowa Code section 22.7(18).The individuals filed a petition in the Iowa District Court for Scott County, which granted summary judgment in favor of Scott County, determining that the applications were exempt from disclosure under Iowa Code section 22.7(18). The district court relied on the precedent set in City of Sioux City v. Greater Sioux City Press Club, which held that employment applications could be kept confidential.The Iowa Supreme Court reviewed the case and reversed the district court's decision. The court held that the applications for the vacant county board of supervisors position were not confidential under section 22.7(18). The court reasoned that the applicants were not promised confidentiality beforehand, and the public nature of the appointment process meant it was not reasonable to believe that people would be deterred from applying if their applications were disclosed. The court ordered that the names and applications be disclosed and awarded costs and reasonable attorney fees to the plaintiffs. The case was remanded for further proceedings. View "Diercks v. Scott County, Iowa" on Justia Law

Gerry Greenland was convicted of attempted murder, assault on a peace officer with intent to cause serious injury while using a dangerous weapon, and simple assault. The incident occurred on May 23, 2019, when Greenland, after a series of confrontations with family members on a farm, used a tractor equipped with bale spears to attack Sheriff Ben Boswell's vehicle. Greenland's actions included ramming the sheriff's car, causing significant damage and endangering the sheriff's life.The Iowa District Court for Decatur County found Greenland guilty of all charges and sentenced him to concurrent terms of incarceration, totaling a maximum of twenty-five years. Greenland appealed, arguing insufficient evidence for his convictions and that the assault conviction should merge with the attempted murder conviction. The Iowa Court of Appeals affirmed the convictions, holding that there was sufficient evidence to support the convictions and that the convictions did not merge because they were based on separate and distinct actions.The Iowa Supreme Court reviewed the case, focusing on whether the convictions for assault on a peace officer and attempted murder should merge under Iowa Code section 701.9. The court held that the convictions did not merge because the assault involved alternative theories, including the use or display of a dangerous weapon, which was not an element of attempted murder. The court disavowed a previous statement in State v. Braggs that suggested it is impossible to commit attempted murder without also committing an assault, clarifying that assault is not always a lesser included offense of attempted murder. The court affirmed the decisions of the Court of Appeals and the District Court. View "State of Iowa v. Greenland" on Justia Law

Benjamin Trane established a private therapeutic boarding school for troubled youth, which was shut down after a police raid. Trane was charged with sexual abuse of a minor, sexual exploitation by a counselor or therapist, and child endangerment. The first two charges involved an underage female victim, while the third charge involved two boys placed in isolation rooms. A jury found Trane guilty on all counts. On direct appeal, the Iowa Supreme Court conditionally affirmed his convictions but remanded for a hearing on a rape shield issue, preserving his ineffective-assistance-of-counsel claims for postconviction relief (PCR) proceedings.In the Iowa District Court for Lee (South) County, Trane alleged ineffective assistance of trial counsel for failing to move to sever the child endangerment count and for not objecting to the marshaling instruction on that count. The district court rejected the severance claim, finding Trane made an informed decision to forego a motion for severance to avoid delay. However, the court ordered a new trial on the child endangerment charge, finding that the marshaling instruction allowed a nonunanimous verdict, thereby prejudicing Trane.The Iowa Supreme Court reviewed the case de novo. The court affirmed the district court's finding that Trane chose to forego a motion to sever the child endangerment count. However, the court reversed the district court's order for a new trial on the child endangerment charge. The court agreed that the marshaling instruction was erroneous but found no prejudice because both child victims were similarly situated, and there was no reasonable probability that jurors did not find Trane guilty of endangering both children. Thus, the court affirmed the denial of relief on the severance claim and reversed the order for a new trial on the child endangerment charge. View "Trane v. State of Iowa" on Justia Law

A financial advisor, employed by Principal Securities, Inc., was terminated for failing to obtain a second client consent when rebalancing accounts using a new trading system. The advisor argued that the termination report filed by Principal with the Financial Industry Regulatory Authority (FINRA) was misleading and initiated arbitration to seek changes to the report. The arbitrator ruled in favor of the advisor, recommending changes to the termination report to reflect that the advisor's failure was due to a lack of training and that the advisor was encouraged not to resign during the investigation.The Iowa District Court for Polk County vacated the arbitration award, finding it unsupported by substantial evidence. The advisor appealed, and the case was transferred to the Iowa Court of Appeals. A divided panel of the Court of Appeals affirmed the district court's decision, with the majority agreeing that the information provided by Principal was not defamatory or misleading. The dissenting judge believed that substantial evidence supported the arbitration award.The Iowa Supreme Court reviewed the case and applied a highly deferential standard of review. The court concluded that substantial evidence supported the arbitrator's determination that the termination report was misleading and that the recommended changes were justified. The court vacated the decision of the Court of Appeals, reversed the district court's judgment, and remanded the case with instructions to confirm the arbitration award. View "Principal Securities, Inc. v. Gelbman" on Justia Law

A man passed away, and his wife made a claim on his estate for half of the money he had removed from their joint bank account before his death. The wife argued that the couple owned the account as joint tenants, and her husband had withdrawn funds exceeding his interest. The district court dismissed her claim, concluding that she was making a claim for conversion sounding in tort and had not met the legal standard.The wife appealed, arguing that the district court applied the wrong legal standard and that a standard from caselaw on joint tenancies should apply. The Iowa Court of Appeals agreed with her, reversed the district court's decision, and remanded the case. The estate sought further review from the Iowa Supreme Court.The Iowa Supreme Court affirmed the decision of the Court of Appeals, holding that the district court applied an incorrect legal standard. The correct standard, as established in Anderson v. Iowa Department of Human Services, involves determining the respective rights of joint tenants based on their agreement and the presumption that each joint tenant is entitled to half of the joint account, which can be rebutted. The court remanded the case for a new trial to allow for proper fact-finding regarding whether the husband removed funds in excess of his interest in the joint account. View "In re Estate of Johnston" on Justia Law