Justia Iowa Supreme Court Opinion Summaries
State of Iowa v. Woods
During a traffic stop, Kevin Woods was found in possession of drugs, a scale, a loaded semiautomatic pistol, and additional high-capacity firearm magazines. He was charged with possession of a controlled substance and carrying a dangerous weapon while in the illegal possession of a controlled substance or while committing an indictable offense. Woods pleaded guilty to both charges but challenged the latter conviction, arguing it violated his Second Amendment rights and article I, section 1A of the Iowa Constitution.The Iowa District Court for Polk County denied Woods's motion to dismiss the dangerous weapon charge, reasoning that the legislature could impose reasonable time, place, and manner restrictions on the right to keep and bear arms. The court concluded that the prohibition on carrying firearms while illegally possessing a controlled substance or committing an indictable offense was a reasonable regulation supported by historical analogues. Woods entered a conditional guilty plea, preserving his right to appeal the constitutionality of his conviction.The Iowa Supreme Court reviewed the case and affirmed the lower court's decision. The court held that the Second Amendment does not cover the right to carry a firearm while illegally possessing a controlled substance or committing an indictable offense. The court reasoned that the federal constitutional right to keep and bear arms is limited to responsible, law-abiding citizens engaged in lawful conduct. Additionally, the court found that even if the conduct were covered by the Second Amendment, the regulation was consistent with the nation's historical tradition of firearm regulation. The court also concluded that Woods's conviction did not violate article I, section 1A of the Iowa Constitution, as the state has a compelling interest in public safety, and the statute was narrowly tailored to serve that interest. View "State of Iowa v. Woods" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Sikora v. State of Iowa
Eugene Sikora, a former prisoner, claims that the State of Iowa failed to release him from prison when his sentence was over. He was convicted of three felonies in 2016 and sentenced to concurrent five-year terms, which were suspended for probation. In 2017, his probation was revoked, and he was imprisoned until March 2019. Sikora alleges that due to a miscalculation, he was imprisoned for nearly five months longer than allowed, as the defendants did not credit him for 292 days served in county jails and a custodial residential center.Sikora filed a suit over three years after his release, seeking money damages for wrongful imprisonment. He named the State of Iowa and the director of the Iowa Department of Corrections as defendants, asserting five tort claims, including violations of his constitutional rights and negligence. The defendants moved to dismiss the suit, arguing sovereign immunity and other defenses. The district court dismissed some of Sikora’s claims but allowed others to proceed. However, after the Iowa Supreme Court's decision in Burnett v. Smith, which overruled the precedent allowing constitutional tort claims, the district court dismissed Sikora’s remaining claims and denied his motion to amend his petition to add new defendants and claims.The Iowa Supreme Court affirmed the district court’s dismissal, holding that sovereign immunity barred Sikora’s claims. The court concluded that all of Sikora’s claims were essentially false imprisonment claims, which are barred by sovereign immunity under Iowa Code section 669.14(4). The court also rejected Sikora’s arguments that constitutional torts and claims against individual state employees could proceed, emphasizing that the Iowa Tort Claims Act (ITCA) provides the exclusive mechanism for such claims and explicitly prohibits claims based on false imprisonment. View "Sikora v. State of Iowa" on Justia Law
State of Iowa v. Cole
Jordan Cole consented to a one-year protective order in a domestic abuse case, which prohibited him from possessing firearms under Iowa Code section 724.26(2)(a). Despite this, Cole pawned stolen firearms while the order was in effect. He was charged with theft and violations of section 724.26(2)(a). The theft charge was dropped, and Cole was convicted of two violations of section 724.26(2)(a). He was sentenced to concurrent prison sentences, which were suspended with probation.Cole appealed his convictions, arguing that section 724.26(2)(a) violated the Second Amendment and article I, section 1A of the Iowa Constitution. He also claimed an error in his sentencing order. The Iowa District Court for Story County had denied his motion to dismiss the charges based on these constitutional claims. Cole and the State agreed to dismiss two charges, and Cole waived his jury rights, leading to a trial on the minutes of testimony. The district court found Cole guilty and sentenced him to concurrent terms, suspended with probation, but stated that if probation was revoked, the sentences could be served consecutively.The Iowa Supreme Court reviewed the case and held that Cole waived his Second Amendment and article I, section 1A rights by consenting to the protective order, which explicitly prohibited firearm possession. The court affirmed his convictions but agreed with Cole that the sentencing order's provision for consecutive sentences upon probation revocation was unlawful. The court remanded the case for entry of a corrected sentencing order, ensuring that any revocation of probation would not result in consecutive sentences. View "State of Iowa v. Cole" on Justia Law
Posted in:
Constitutional Law, Criminal Law
State v. Scullark
Patrick Scullark, Jr. was charged with possession of a controlled substance after police officers found methamphetamine in his fanny pack during a search incident to his arrest on unrelated charges. Scullark attempted to pass the fanny pack to another person before being handcuffed. He argued that the search violated his constitutional rights because he could no longer access the fanny pack at the time it was searched.The Iowa District Court for Black Hawk County denied Scullark’s motion to suppress the evidence, finding the search valid as a search incident to arrest. Scullark entered a conditional guilty plea, preserving his right to appeal the suppression ruling. The Iowa Court of Appeals reversed the district court’s decision, agreeing with Scullark that the search did not satisfy the search incident to arrest (SITA) exception because he could not access the fanny pack at the time it was searched.The Iowa Supreme Court reviewed the case and vacated the court of appeals decision, affirming the district court’s order. The court held that the search of the fanny pack was valid under both the United States Constitution and the Iowa Constitution. The court concluded that because the fanny pack was worn around Scullark’s waist at the time of his arrest, it was considered part of his person. Therefore, the search was justified as a search of his person incident to a lawful arrest, requiring no additional justification. The court emphasized that the SITA exception allows for a full search of the arrestee’s person and items immediately associated with the person. View "State v. Scullark" on Justia Law
Posted in:
Constitutional Law, Criminal Law
McClure v. Ei Du Pont Nemours and Co.
A warehouse employee, Darrell McClure, claimed he was discriminated against by his employer, Corteva Agriscience, based on his disability and age. McClure, who had worked for the company for 36 years, suffered from heart attacks and had medical restrictions that limited his ability to work night shifts. Despite these restrictions, he was involved in several safety violations and incidents, leading to his termination in July 2020. McClure filed a lawsuit under the Iowa Civil Rights Act (ICRA), alleging age and disability discrimination, retaliation, and hostile work environment.The Iowa District Court for Keokuk County granted summary judgment in favor of Corteva, dismissing all of McClure's claims. McClure appealed, and the Iowa Court of Appeals affirmed the dismissal of the retaliation and hostile work environment claims but reinstated the age and disability discrimination claims, finding that there were factual disputes that precluded summary judgment.The Iowa Supreme Court reviewed the case and agreed with Corteva that McClure failed to present sufficient evidence of a qualifying disability or age discrimination. The court found that McClure did not demonstrate that his medical condition substantially limited his ability to work in a broad range of jobs, nor did he show that Corteva perceived him as disabled based on myths, fears, or stereotypes. Additionally, the court concluded that McClure did not provide adequate comparator evidence or discriminatory atmosphere evidence to support his age discrimination claim.The Iowa Supreme Court vacated the part of the Court of Appeals decision that reinstated McClure's age and disability discrimination claims and affirmed the district court's grant of summary judgment in favor of Corteva. View "McClure v. Ei Du Pont Nemours and Co." on Justia Law
Posted in:
Labor & Employment Law
State of Iowa v. Amble
In 2023, police in Des Moines, Iowa, received a tip about suspected narcotics trafficking at a residence. Acting under Iowa Code section 808.16, officers conducted warrantless searches of garbage bags placed curbside for collection. The searches revealed evidence of drug dealing, which was used to obtain a warrant to search the home, leading to further evidence and charges against two occupants, Charles Amble and John Mandracchia. The defendants moved to suppress the evidence, arguing that section 808.16 was unconstitutional.The Iowa District Court for Polk County ruled in favor of the defendants, declaring Iowa Code section 808.16 facially unconstitutional under article I, section 8 of the Iowa Constitution, as interpreted in State v. Wright. The court suppressed the evidence obtained from the garbage searches and the subsequent home search. The State appealed the decision.The Iowa Supreme Court reviewed the case and concluded that the district court erred in its ruling. The court held that the specific provision in Iowa Code section 808.16(3), which deems garbage placed outside for collection in a publicly accessible area as abandoned property, is constitutional both facially and as applied in this case. This provision preempts conflicting local ordinances and negates any reasonable expectation of privacy in such garbage. Consequently, the warrantless trash pulls conducted by the police were lawful, and the evidence obtained was admissible.The Iowa Supreme Court reversed the district court's suppression ruling and remanded the case for further proceedings consistent with its opinion. View "State of Iowa v. Amble" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Lucas v. Warhol
The plaintiff, Rhonda Lucas, filed a personal injury lawsuit against Peter Warhol and Progressive Direct Insurance Company following a car accident. Lucas struggled to serve Warhol, who had no fixed address and may have been homeless. Despite various efforts, including hiring a private investigator and attempting service through the Iowa Department of Transportation (DOT), Warhol remained unserved eleven months after the lawsuit was filed. The district court eventually allowed Lucas to serve Warhol by serving an attorney hired by Warhol’s liability insurance carrier.The Iowa District Court for Polk County denied Warhol’s motion to dismiss for lack of timely service, finding good cause to extend the time for service due to the difficulty in locating Warhol. The court also permitted alternative service on the attorney. Warhol appealed, and the Iowa Supreme Court granted interlocutory review. While the appeal was pending, Lucas personally served Warhol.The Iowa Supreme Court addressed three issues: whether the district court should have dismissed the case for untimely service, whether the district court erred in permitting service on the attorney, and the effect of the personal service during the interlocutory review. The court held that the district court was correct in finding good cause to extend the time for service due to Lucas’s diligent efforts and Warhol’s homelessness. However, the court found that serving the attorney did not satisfy due process requirements, as there was no evidence of contact between Warhol and the attorney. The court concluded that the personal service on Warhol during the interlocutory review should be treated as timely.The Iowa Supreme Court affirmed the district court’s refusal to dismiss the case, reversed the order permitting service on the attorney, and remanded for further proceedings. View "Lucas v. Warhol" on Justia Law
Posted in:
Civil Procedure, Personal Injury
Estate of Kahn v. City of Clermont, Iowa
A mother and daughter drowned while floating on innertubes on the Turkey River after going over a low-head dam. Their estates sued the State of Iowa, Fayette County, the Fayette County Conservation Board, and the City of Clermont, alleging negligence and premises liability for failing to maintain warnings about the dam. The defendants moved to dismiss the claims.The Iowa District Court for Fayette County dismissed all claims. The court concluded that the claims were barred by the public-duty doctrine and that the petition failed to meet the heightened pleading requirements in Iowa Code § 670.4A. The court also dismissed the claims against the State, referring generally to the reasons set forth in the State’s motion, which included qualified immunity, sovereign immunity, discretionary function immunity, and the public-duty doctrine.The Iowa Supreme Court reviewed the case and reversed the district court’s dismissal. The court held that the heightened pleading requirements did not apply to the estates’ common law tort claims of negligence and premises liability. The court also determined that the public-duty doctrine did not bar the claims, as the allegations involved affirmative acts of negligence by the defendants. Additionally, the court found that the State’s sovereign immunity and discretionary function immunity did not apply at this stage, as the petition alleged inattention rather than considered choices by the State. The court also rejected the recreational immunity defense, concluding that the estates sufficiently pleaded an exception to the statute.The Iowa Supreme Court reversed the district court’s dismissal of the claims and remanded the case for further proceedings. View "Estate of Kahn v. City of Clermont, Iowa" on Justia Law
Posted in:
Government & Administrative Law, Personal Injury
Robinson v. Central Iowa Power Cooperative
Siblings Martin, Paula, and Tom Robinson, along with Tom’s wife Laura, own adjoining farm properties and claim a drainage easement across properties owned by Central Iowa Power Cooperative (CIPCO) and Kenneth and Deanice Ludolph, which the Ludolphs leased to Coggon Solar, LLC. The Robinsons allege that CIPCO violated their drainage easement by rerouting a drainage tile line and that Coggon Solar’s solar farm development would further violate their easement. They sought declaratory and injunctive relief, damages, and claimed a right to access and repair the drainage tile on the servient properties.The Iowa District Court for Linn County dismissed the Robinsons’ lawsuit, quieted title in favor of the defendants, and awarded attorney fees to the defendants. The court held that the Robinsons had the right to drain surface water onto the servient estates but not along a fixed route, and they did not have a right to access or repair the drainage tile on the servient estates. The court also granted summary judgment in favor of CIPCO and Coggon Solar on the quiet-title action and dismissed the Robinsons’ nuisance claim.The Iowa Supreme Court affirmed the district court’s decision. The court held that the Robinsons have a legal and natural easement to drain surface water onto the servient estates but do not have a drainage easement along a fixed route or a right to access and repair the drainage tile on the servient properties. The court found no evidence that CIPCO’s rerouting of the tile line caused any detriment or injury to the Robinsons. The court also upheld the award of attorney fees, finding no abuse of discretion by the district court. View "Robinson v. Central Iowa Power Cooperative" on Justia Law
Posted in:
Real Estate & Property Law
Rheeder v. Gray
A custodian for a city police department sued the city and some of its employees, claiming she experienced sexual harassment and retaliation in violation of the Iowa Civil Rights Act (ICRA). The custodian alleged that a deputy chief made her uncomfortable with his behavior and comments, and that after she reported this, she faced retaliation from her administrative manager, who threatened her and her coworkers.The Iowa District Court for Linn County denied the defendants' motions for summary judgment on the custodian's claims of sexual harassment and retaliation, except for the claim of constructive discharge. The defendants then sought interlocutory review.The Iowa Supreme Court reviewed the case and found that the alleged harassment by the deputy chief was not sufficiently severe or pervasive to support an ICRA claim. The court also determined that the alleged acts of retaliation by the administrative manager did not amount to a materially adverse action as required for an ICRA claim. Consequently, the court reversed the district court's decision and remanded the case for dismissal of the custodian's claims. View "Rheeder v. Gray" on Justia Law
Posted in:
Civil Rights, Labor & Employment Law