Justia Iowa Supreme Court Opinion Summaries

The case involves a challenge to an Iowa law that prohibits abortions after a fetal heartbeat is detected. The plaintiffs, Planned Parenthood of the Heartland, Inc., Emma Goldman Clinic, and Sarah Traxler, filed a lawsuit against the defendants, Kim Reynolds and the Iowa Board of Medicine, arguing that the law is unconstitutional. The district court granted a temporary injunction, blocking the enforcement of the law.The district court's decision was based on the application of the "undue burden" test, concluding that the plaintiffs were likely to succeed in their constitutional substantive due process challenge. The defendants appealed, arguing that the district court applied the wrong constitutional test and that the court should instead review the abortion restriction under the less demanding "rational basis" test.The Supreme Court of Iowa reversed the district court's decision. The court held that abortion is not a fundamental right under the Iowa Constitution and that abortion restrictions alleged to violate the due process clause are subject to the rational basis test. Applying this test, the court concluded that the fetal heartbeat statute is rationally related to the state’s legitimate interest in protecting unborn life. The court remanded the case for further proceedings, instructing the district court to dissolve the temporary injunction blocking enforcement of the fetal heartbeat statute. View "Planned Parenthood of the Heartland, Inc. v. Reynolds ex rel. State of Iowa" on Justia Law

The case involves a defendant who appealed the denial of her motion to suppress evidence obtained from a traffic stop, a dog sniff of her vehicle, and a search of her purse. The defendant was driving slower than the speed limit, causing traffic issues, and crossed the centerline multiple times. The officer, suspecting drug-related activity due to the defendant's history of drug offenses, initiated a traffic stop and requested a K-9 unit. The dog sniffed the exterior of the vehicle, occasionally touching it with its paws, and alerted to the presence of drugs. A subsequent search of the vehicle and the defendant's purse revealed methamphetamine and related paraphernalia.The defendant argued that the traffic stop was unjustified, the dog sniff constituted an unconstitutional search because the dog touched the exterior of her vehicle, and the search of her purse was unlawful. The district court denied the motions to suppress, and the defendant was found guilty on three counts.The Supreme Court of Iowa affirmed the lower court's decision. The court held that the traffic stop was justified due to the defendant's driving behavior. It also ruled that the dog sniff did not violate the Fourth Amendment or the Iowa Constitution, as the dog was in a place where police had a right to be and the sniff only revealed the presence or absence of contraband. The court did not rule on the legality of the purse search, as the defendant failed to properly raise and preserve the issue for appeal. View "State of Iowa v. Bauler" on Justia Law

Nathan Olsen, convicted of a sex offense in Wisconsin in 2009, moved to Iowa where he was required to register as a sex offender. After serving a prison sentence for an unrelated crime, Olsen moved to Illinois where he was not required to register. He wished to return to Iowa, but doing so would require him to register again. Olsen filed an application in the district court to modify his status as a sex offender and the registration requirements that would apply to him in Iowa before he moved back. The district court dismissed his application, and the court of appeals affirmed the dismissal.The district court and the court of appeals both concluded that Olsen's claim was not ripe for adjudication because his application sought to modify a "hypothetical" registration requirement predicated on his potential future return to Iowa. Olsen argued that the statute permitting only those who currently live, work, or attend school in Iowa the opportunity to modify their sex offender registration requirements unlawfully discriminates against nonresidents in violation of the Privileges and Immunities Clauses of the Iowa and United States Constitutions.The Supreme Court of Iowa found that the residency restriction imposed by the statute prohibits nonresidents from seeking the same fundamental privilege to access Iowa’s courts that a resident receives. However, the court was unable to evaluate the State’s justification for treating residents and nonresidents differently due to lack of evidence. Therefore, the court remanded the case for the parties to present evidence and for the district court to rule on Olsen’s constitutional challenge in light of that evidence. The court also rejected the State's argument that Olsen was not eligible for modification because five years hadn’t passed from the date of commencement of his requirement to register. View "Olsen v. State of Iowa" on Justia Law

The case involves Derek White, who was charged with child neglect or abuse and child endangerment causing bodily injury. The charges stemmed from the discovery of extensive bruising on a two-year-old child, D.C., who lived with White and several other children. During the trial, two of White's sons, J.W. and M.W., testified against him. However, they were allowed to testify from outside the courtroom via a one-way closed-circuit television system, which meant that they could not see White while they testified against him. White argued that this procedure violated his right of confrontation under the Iowa Constitution.The Iowa District Court for Osceola County rejected White's constitutional arguments and allowed the testimony of J.W. and M.W. via the one-way closed-circuit television system. The jury found White guilty as charged. On appeal, the Iowa Court of Appeals affirmed White's convictions. White then sought further review from the Supreme Court of Iowa.The Supreme Court of Iowa held that the procedure used for the testimony of J.W. and M.W. violated White's right of confrontation under the Iowa Constitution. The court reasoned that face-to-face confrontation requires that trial witnesses must be both visible to the accused and also able to see the accused. Therefore, when the witness and the accused are prevented from seeing each other, there can be no face-to-face confrontation, and the Iowa Constitution is not satisfied. The court reversed White's convictions and remanded the case for a new trial. View "State of Iowa v. White" on Justia Law

The Vagts family, who own and operate a dairy farm in West Union, Iowa, filed a nuisance suit against Northern Natural Gas Company (NNG). NNG operates a natural gas pipeline that runs under the Vagts' property and uses a cathodic protection system, which runs an electrical current through the pipeline to prevent corrosion. The Vagts alleged that stray voltage from the cathodic protection system distressed their dairy herd and caused them damages. The jury awarded the Vagts a total of $4.75 million in damages. NNG appealed, arguing that the district court erred in instructing the jury on nuisance without including negligence as an element of the claim and in denying NNG’s motion for remittitur.The district court held that negligence was not an element of the nuisance claim and instructed the jury accordingly. The jury found that the stray voltage from the cathodic protection system was definitely offensive, seriously annoying, and intolerable, that the stray voltage interfered with the Vagts’ normal use of land in the local community, and that this constituted a nuisance. The jury awarded the Vagts $3 million in economic damages, $1.25 million for personal inconvenience, annoyance, and discomfort, and $500,000 for the loss of use and enjoyment of land.On appeal, the Supreme Court of Iowa affirmed the district court's decision. The court held that under the controlling statute and precedents, negligence is not an element of a nuisance claim. The court also held that the district court did not abuse its discretion in declining to disturb the jury's verdict on damages. The court concluded that the jury's verdict was supported by the record when viewed in the light most favorable to the plaintiffs. View "Vagts v. Northern Natural Gas Company" on Justia Law

Shannon Hightower pleaded guilty to dependent adult abuse and theft in the second degree. She later appealed, arguing that there were defects in her guilty plea, her sentencing, and the conditions set for her appeal bond. Hightower also contended that Iowa Code section 814.29, which regulates judicial review of challenges to a guilty plea, was unconstitutional.The district court had found Hightower guilty based on her plea and sentenced her to concurrent prison terms. One of the court's reasons for the sentence was Hightower's failure to pay restitution prior to sentencing. After sentencing, Hightower filed a motion asking the court to order a stay of the sentence and to set a hearing to review concerns about her guilty plea. Alternatively, she asked the court to set an appropriate appeal bond. The court denied Hightower's request for a hearing about her guilty plea and set an appeal bond in the amount of $17,000 cash only.The Supreme Court of Iowa found that Hightower's guilty plea was defective due to the absence of an accurate advisory as to the maximum punishment she faced by pleading guilty. However, the court concluded that section 814.29 prevented it from vacating Hightower's plea. The court also agreed with Hightower that resentencing was required because the district court relied on an improper sentencing factor. Furthermore, the court agreed with Hightower that the district court erred by ordering unauthorized forfeiture requirements for Hightower’s appeal bond. The court affirmed Hightower’s conviction, vacated her sentence, and reversed the forfeiture requirements. The case was remanded for resentencing and for lawful disbursement of funds paid for Hightower’s release during the appeal. View "State of Iowa v. Hightower" on Justia Law

Sally Splittgerber suffered a fall while walking on a city sidewalk, leading to a personal injury lawsuit against the owner of the adjacent property, the lessee of that property (Bankers Trust), and the City of Des Moines. The plaintiffs alleged that these parties were negligent in maintaining the uneven sidewalk. After settling the claims, Bankers Trust sought contribution from the City for the settlement payment, arguing that the City, not the property owner or lessee, was responsible for maintaining the sidewalk.The district court, relying on the precedent set in Madden v. City of Iowa City, granted summary judgment in favor of the City. The court held that the City could impose liability on abutting landowners for damages resulting from other types of failures to maintain sidewalks, beyond just snow and ice removal. Bankers Trust appealed this decision, asking the Supreme Court of Iowa to overrule the Madden decision.The Supreme Court of Iowa agreed with Bankers Trust, stating that the Madden decision was wrongly decided. The court found that the City's attempt to shift costs and liability to abutting landowners for sidewalk maintenance and accidents beyond what the state statute allows was in direct conflict with the legislature's express determination about where such burdens reside. The court noted that the statute only permits cities to require abutting landowners to repair sidewalks if the city first notifies the landowners by certified mail that a repair is necessary, and only permits cities to hold abutting landowners liable for damages if they fail to remove snow and ice from the sidewalk.The court overruled the Madden decision, reversed the district court's summary judgment ruling, and remanded the case for further proceedings consistent with this opinion. View "Bankers Trust Company v. City Of Des Moines" on Justia Law

The plaintiff, Ron Myers, suffered a leg injury after slipping on a diving board at a city pool in Cedar Falls, Iowa. He sued the City of Cedar Falls, alleging that the diving board lacked a slip-resistant surface required by state regulations. The City moved for summary judgment, arguing that it was immune from liability under Iowa Code section 670.4(1)(l), which grants immunity to operators of municipal swimming pools unless there is a "knowing" violation of regulations. The district court granted the City's motion, concluding that Myers failed to establish a "knowing" violation of the regulations.Myers appealed the decision, and the case was transferred to the court of appeals. The court of appeals reversed the district court's decision, finding that there were factual questions about the condition of the diving board that precluded summary judgment. The City then sought further review from the Supreme Court of Iowa.The Supreme Court of Iowa accepted the City's invitation to overrule a previous decision, Sanon v. City of Pella, which had interpreted the "criminal offense" exception to immunity for operators of municipal swimming pools under Iowa Code section 670.4(1)(l) to include violations of agency regulations. The court found that Sanon was "egregiously wrong" and had caused ongoing problems. The court held that the legislature did not make violating swimming pool regulations a criminal offense, and therefore, the City was immune from liability under Iowa Code section 670.4(1)(l). The court vacated the decision of the court of appeals and affirmed the district court's summary judgment. View "Myers v. City of Cedar Falls" on Justia Law

The case involves a dispute over the boundary between two parcels of land in Wapello County, Iowa. The northern parcel was owned by the Handlings and the southern parcel by the Sims. Both parties treated a fence line as the boundary between their properties for many years. In the mid-1990s, Scott Hubbell began leasing both properties for farming. In 2004, he built a machine shed south of the fence line, assuming it was on the southern property. In 2014, Hubbell and his wife purchased both properties, becoming the sole owners. In 2017, they sold the southern property to the Remmarks and in 2018, they sold the northern property to Sundance Land Company. A survey commissioned by Sundance revealed that the legal boundary between the properties ran south of the fence line, meaning the machine shed was encroaching onto the northern property. Sundance filed a petition to quiet title according to the survey boundary lines, alleging that the Remmarks were trespassing on the northern property.The district court found that a boundary line by acquiescence had been established at the old fence line during the Handlings’ and Sims’ respective ownership of the properties. The court rejected Sundance’s argument that the Hubbells’ common ownership of both parcels from 2014 to 2017 erased the boundary by acquiescence. The court of appeals affirmed the district court's decision.The Supreme Court of Iowa disagreed with the lower courts' decisions. The court held that when two adjoining parcels come under common ownership, any potential boundary by acquiescence between them is eradicated, and the ten-year clock for calculating boundary by acquiescence restarts when separate ownership resumes. The court vacated the decision of the court of appeals, reversed the district court judgment, and remanded for entry of judgment for Sundance in accordance with this opinion. View "Sundance Land Company, LLC v. Remmark" on Justia Law

In this case, a private citizen, Robert Teig, appealed a summary judgment granted to city officials in his lawsuit alleging violations of the Iowa Open Records Act. Teig had requested job applications and other documents related to the City of Cedar Rapids' hiring processes for a new city clerk and city attorney. The City refused many of Teig's requests, citing attorney-client privilege and the Act's confidentiality provisions as reasons for withholding several documents.The district court granted the City's motion for summary judgment, leading to Teig's appeal. He argued that job applications submitted to governmental bodies are not confidential under chapter 22, municipalities cannot claim attorney-client privilege in the context of an open records request, search and retrieval fees are not authorized by chapter 22, the defendants unreasonably delayed fulfilling certain requests, and the district court should have granted him leave to submit additional interrogatories in the ensuing litigation.The Supreme Court of Iowa affirmed in part and reversed in part the district court's decision. The court held that documents subject to attorney-client privilege are protected from disclosure under chapter 22 and that chapter 22 authorizes municipalities or governmental bodies to charge search and retrieval fees. However, the court found that while job applications are generally protected from disclosure, that protection extends only to persons "outside of government." Therefore, the City was obligated to disclose those applications submitted by current employees of the City, although it properly withheld external applications. The court also found that the district court failed to address Teig’s claims of undue delay related to billing records. The case was remanded for further proceedings. View "Teig v. Chavez" on Justia Law