Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the district court entering summary judgment in favor of Defendants and dismissing Plaintiff's action with prejudice, holding that Defendant was not entitled to relief on any of his claims of error.Plaintiff sued a neighboring confined animal feeding operation (CAFO) alleging common law nuisance, trespass, and drainage law violations. Defendants moved for summary judgment based on the statutory immunity in Iowa Code 657.11. Plaintiff, relying on , argued that section 657.11, as applied, violated the Iowa Constitution's inalienable rights clause. The district court granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding (1) the three-part test set forth in Gacke is overruled; (2) under rational basis review, Plaintiff's constitutional challenge to section 657.11 was unavailing; (2) Plaintiff failed to preserve error on his takings claim; and (3) as to Plaintiff's trespass and drainage claims Plaintiff failed to generate a question of fact precluding summary judgment on statutory nuisance immunity or causation. View "Garrison v. New Fashion Pork LLP" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder arising from events in 1990 after his fourth trial, held almost thirty years after the crime, holding that Defendant was not entitled to relief on any of his claims of error.On appeal, Defendant argued that his conviction must be reversed due to juror misconduct, the improper admission of certain testimony, the erroneous exclusion of hearsay evidence, and a violation of due process. The Supreme Court disagreed and affirmed his conviction, holding that none of Defendant's allegations of error warranted reversal of his convictions. View "State v. Liggins" on Justia Law

The Supreme Court reversed the ruling of the district court finding Iowa Code 815.1(4)(c) to be unconstitutional, holding that the State is not constitutionally required to provide ancillary services to an indigent defendant represented by private counsel if funds available to the counsel can reasonably be expected to cover the services.In 2019, the General Assembly enacted section 815.1, thereby changing the process by which an indigent defendant can obtain state funding for investigation costs when the defendant chooses to be represented by privately-retained counsel. The district court found section 815.1 unconstitutional under the Sixth Amendment, severed section 815.1(4)(c) from the statute, and granted Defendant's request for ancillary services at state expenses. The Supreme Court reversed, holding that the State is constitutionally permitted to consider the funds available to a retained attorney in determining whether it is required to provide state funding for ancillary services. View "Amaya v. State Public Defender" on Justia Law

The Supreme Court reversed the order of the district court granting summary judgment in favor of the cities of Pella and Oskaloosa regarding the validity of an agreement between the cities and Mahaska County to establish a regional airport authority, holding that Landowners had standing to challenge the agreement.Landowners brought this action seeking a judgment that the agreement at issue was illegal and an injunction to prevent the transaction. The district court held that Landowners lacked standing to bring the suit and granted summary judgment in favor of the Cities. The Supreme Court reversed, holding (1) by entering into the agreement, the County's Board of Supervisors bound future board to a particular course of legislative action, in violation of the Iowa Constitution; (2) the agreement violated precedent regarding delegation of a municipality's legislative power; and (3) therefore, the district court erred in declaring the agreement to be valid and ordering specific performance by the County of its obligations under the agreement. View "Site A Landowners v. South Central Regional Airport Agency" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment entered by the district court in this action involving former co-counsel on a contingent-fee case, holding that the district court erred in finding insufficient evidence that the Hope Law Firm's new entity, Hope Law Firm & Associates, P.C., was a successor entity to Hope Law Firm, P.L.C.Lawyer James Larew had an of-counsel arrangement with the Hope Law Firm and agreed to work on a particular client's case in exchange for a portion of the firm's fee. Larew and the firm later ended the of-counsel arrangement, and Larew ultimately won a large judgment at trial. This litigation concerned the disposition of the fee. On appeal, Larew appealed the district court's determination on the terms of an implied-in-fact contract, quantum meruit calculation, successor liability, and other causes of action. The Supreme Court reversed the district court's ruling as to successor liability and otherwise affirmed, holding that Larew showed that Hope Law Firm & Associates, P.C. was a successor entity to Hope Law Firm, P.L.C. View "Larew v. Hope Law Firm, P.L.C." on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court ruling that Willard McNaughton's right and interest in the disputed property in this case had been extinguished, holding that the district court erred.McNaughton entered into an easement agreement with Jeanine and Stanley Chartier to allow a portion of a road to pass through McNaughton's property. The Chartiers subsequently sold their property, giving rise to this dispute over a paved portion of the easement. The district court ruled that McNaughton had dedicated the concrete portion of the easement to the City of Lawton. The court of appeals reversed. The Supreme Court affirmed, holding that the district court erred in finding that McNaughton dedicated the concrete portion of the easement to the City and in holding that McNaughton's rights to the easement area were extinguished. View "McNaughton v. Chartier" on Justia Law

The Supreme Court held that the Iowa Constitution is not the source of a fundamental right to an abortion necessitating a strict scrutiny standard of review for regulations affecting that right.In Planned Parenthood of the Heartland, Inc. v. Iowa Board of Medicine (PPH I), 865 N.W.2d 252 (Iowa 2015), the Supreme Court applied the federal undue burden test established in Planned Parenthood of Southeastern Pennsylvania v. Casey, 505 U.S. 833 (1992), under the Iowa Constitution. In Planned Parenthood of the Heartland v. Reynolds (PPH II), 915 N.W.2d 206, (Iowa 2018), the Supreme Court rejected the undue burden test and found that the due process clause of the Iowa Constitution protected abortion as a fundamental right. In 2020, the general assembly added a mandatory 24-hour waiting period for abortion to pending legislation limiting courts' ability to withdraw life-sustaining procedures. Planned Parenthood successfully sued in district court to block the statute from taking effect. The district court granted summary judgment for Planned Parenthood. The Supreme Court reversed, holding (1) PPH II is overruled; and (2) therefore, the Casey undue burden test applied in PPH I remains the governing standard. View "Planned Parenthood of the Heartland, Inc. v. Reynolds ex rel. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeals and the district court on the questions of lien validity and priority in this mechanics' lien case, holding that there was no error.Law requires that general contractors and owner-builders post a notice of commencement of work to Iowa's centralized, internet-based registry for mechanics' liens within ten days of starting work on a residential construction project. In the instant case, the owner-builder did not post notices of commencement on the registry for the five residential lots that it was developing, but two subcontractors did so several months after construction had begun. When the project went into default, a priority dispute arose between the two subcontractors and the project's commercial lender. The district court and court of appeals found for the subcontractors. The Supreme Court affirmed, holding (1) Iowa Code 572.13 did not change the principle that mechanics' liens will, in some circumstances, have priority over previously-recorded mortgages; and (2) the ten-day deadline for posting the notice of commencement to the registry applies to general contractors and owner-builders but not to subcontractors. View "Borst Brothers Construction, Inc. v. Finance of America Commercial, LLC" on Justia Law

The Supreme Court affirmed in part and vacated in part the decision of the court of appeals affirming the decision of the Iowa Department of Transportation (DOT) to rescind Petitioner's license under Iowa Code 322.3(12), holding that there was substantial evidence to revoke the motor vehicle dealer license.Petitioner, who owned and operated a vehicle dealership, pleaded guilty to one count of structuring transactions to avoid mandatory reporting requirements in violation of 31 U.S.C. 5324(a)(1) and (3) and was sentenced to a term of probation. The DOT then revoked Petitioner's Motor Vehicle Dealer License for a period of five years because of the structuring conviction. The district court upheld the revocation, stayed enforcement of the license revocation until the completion of the appeal, and tolled the entirety of the five-year revocation period. The court of appeals upheld the license revocation but determined that the district court lacked the authority to toll the five-year license revocation period. The Supreme Court held (1) there was substantial evidence to revoke the motor vehicle dealer license; and (2) the revocation period shall be extended by the length of the stay. View "Carreras v. Iowa Department of Transportation, Motor Vehicle Division" on Justia Law

The Supreme Court affirmed Defendant's convictions for drug- and firearm-related offenses, holding that the district court did not abuse its discretion by granting defense counsel's motion to withdraw and did not err in concluding that Defendant knowingly, voluntarily, and intelligently waived his right to counsel.The district court granted defense counsel's motion to withdraw from representation of Defendant approximately three weeks before Defendant's speedy trial expiration date. Although the district court offered to appoint another attorney to represent Defendant, Defendant demanded that he represent himself with the assistance of standby counsel. After conducting colloquies the district court allowed Defendant to proceed pro se with the assistance of standby counsel. The Supreme Court affirmed Defendant's convictions, holding that the district court (1) did not abuse its discretion by granting defense counsel’s motion to withdraw based on defense counsel’s statements that professional considerations required termination of the representation; and (2) correctly concluded that Defendant knowingly, intelligently, and voluntarily waived his right to counsel after engaging in a thorough colloquy. View "State v. Miller" on Justia Law