Justia Iowa Supreme Court Opinion Summaries

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The Supreme Court vacated the decision of the court of appeals concluding that the public-duty doctrine barred Plaintiffs' tort claims against the State of Iowa and two municipalities, holding that the district court correctly denied Defendants' motion for judgment on the pleadings.This case arose from an accident in which a driver traveling the wrong way on Interstate 80 collided with another vehicle, killing all of the occupants. Plaintiffs brought this action alleging that Defendants were liable because of their role in negligently constructing and operating a confusing interchange used by the errant driver. Defendants filed a joint motion for judgment on the pleadings under the public-duty doctrine, which the district court denied. The court of appeals reversed, concluding that the public-duty doctrine barred all of Plaintiffs' claims against Defendants. The Supreme Court vacated the decision below and remanded the case for further proceedings, holding that complaint was sufficient to avoid application of the public-duty doctrine for purposes of adjudicating the motion for judgment on the pleadings. View "Estate of Farrell v. State" on Justia Law

Posted in: Personal Injury
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The Supreme Court affirmed the decision of the district court granting summary judgment in favor of a beneficiary and ruling that an amendment to an irrevocable trust was invalid, holding that the surviving settlor of an irrevocable trust cannot, with the consent of all of the beneficiaries, modify the dispositive terms of an irrevocable trust without court approval.Donald and Collen Davis established the trust at issue. After Collen died, Donald sought to amend the dispositive terms of the trust. Donald and his four children signed a consent document on different days and then Donald executed an amendment altering the disposition of the trust estate. Katina Little, one of the children, brought this action challenging the validity of the amendment. The district court granted summary judgment for Little, concluding that the amendment to the trust agreement was void for lack of authority. The Supreme Court affirmed, holding that the consent of Donald and the four beneficiaries was insufficient to modify the trust after Collen's death. View "Little v. Davis" on Justia Law

Posted in: Trusts & Estates
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The Supreme Court held that the beneficiary of an estate cannot file a separate suit outside probate against the personal representative of the estate for claims arising out of and related to the personal representative's fees for administering the estate.After Roger Rand died testate, attorney Larry Storm informed Security National Bank that it had been nominated as the personal representative of the estate. Plaintiff, a beneficiary of the estate, later received a document entitled "Estate Administration Overview" that included a statement regarding fees for the estate's administration. The document reflected the maximum fees for ordinary services that a personal representative could receive. Plaintiff objected, arguing that Security National deprived the beneficiaries of the opportunity to replace the personal representative with another that required a smaller fee. The probate court reduced the fees to Security National below the requested amounts. Plaintiff then brought this suit against Security National arising from Security National's service as the personal representative of the estate. The district court held that Plaintiff's claims should have been asserted in the probate court or otherwise failed as a matter of law. The Supreme Court affirmed, holding that the district court properly granted summary judgment to Security National on all claims. View "Rand v. Security National Corp." on Justia Law

Posted in: Trusts & Estates
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In this case disputing whether a drainage district properly reclassified benefits in connection with a drainage repair project the Supreme Court affirmed, holding that the lower courts did not err.The drainage district at issue was formed more than a century ago, and a railroad that traversed the land within the district court was assessed 4.81 percent of the benefit of installation of tiling. In 2018, the drainage district determined that repairs were needed to the tiling and sought to reclassify the land in the district to equitably apportion the cost of the new repairs. The reclassification commission recommended that one-half of the repair cost be assessed to the railroad through the reclassification process. The drainage district approved the reclassification. The railroad brought this action challenging the reclassification. The district court granted summary judgment for the railroad, concluding that the reclassification commission acted inequitably, and declared the reclassification of benefits null and void. The court of appeals affirmed. The Supreme Court affirmed, holding that the railroad met its burden of showing that the assessment was inequitable and improper as a matter of law. View "Union Pacific Railroad Co. v. Drainage District 67 Board of Trustees" on Justia Law

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The Supreme Court affirmed the judgment of the district court convicting and sentencing Defendant but remanded for entry of a nun pro tune order to correct the fine suspended in the written sentencing order to the amount orally pronounced at the sentencing hearing.Pursuant to a plea agreement, Defendant pleaded guilty to several drug offenses. The district court imposed a thirty-year prison sentence with the mandatory minimum reduced by Defendant's guilty plea. On appeal, Defendant argued that the district court failed to consider its discretion for a lower mandatory minimum sentence under Iowa Code 124.413(3) and that there was a discrepancy between the fine stated orally at sentencing and in the written order. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion by imposing the agreed-upon prison sentence; and (2) the fine should be reset through a nunc pro tunc order on remand. View "State v. Wilbourn" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court granting Defendant a new trial at which a key witness associated with missing records would be barred from testifying, holding that the unavailability of the records did not entitle Defendant to a retrial.Defendant was convicted of solicitation to commit murder. At issue on appeal was whether the district court erred in denying Defendant's requests to obtain the privileged counseling records of two of the State's key witnesses on the grounds that the records might contain critical exculpatory information. The court of appeals reversed and remanded with instructions for the district court to review the counseling records. On remand, the two federal agencies believed to have the records refused to turn them over. The district court presumed the records contained exculpatory information and granted Defendant a new trial. The court of appeals reversed and remanded the case. The Supreme Court affirmed, holding that the trial court erred in allocating the discovery burden and ordering a new trial without requiring Defendant to show that he’d exhausted every available avenue to lawfully obtain the medical records for the court to review. View "State v. Retterath" on Justia Law

Posted in: Criminal Law
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In this dispute over the just compensation award for commercial property the Supreme Court held that the district court did not abuse its discretion by limiting the testimony of the property owner regarding his opinion testimony that sales of other commercial property were comparable where that opinion required technical or specialized knowledge.An Iowa municipality condemned part of the owner's undeveloped land for a road. The district court allowed the owner to opine as to the site's reduction in value resulting from the taking but barred the owner's evidence of comparable sales on the grounds that the owner relied on hearsay and was unqualified as an expert. The Supreme Court affirmed, holding that the owner, a former restaurant manager, was not qualified as an expert under Iowa R. Evid. 5.702 to offer the opinion testimony given his lack of expertise and the complexity of these commercial real estate valuations. View "Rausch v. City of Marion" on Justia Law

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The Supreme Court reversed the district court's grant of summary judgment in favor of Plaintiff in this real estate dispute, holding that Plaintiff offered sufficient evidence to survive Defendants' motion for summary judgment.A few months after purchasing a home Plaintiff discovered water in the basement. Plaintiff later sued the sellers, her real estate agent, the seller's real estate agent, and a home inspector, alleging that they had misrepresented the condition of the house. The district court granted summary judgment for Defendants based on Plaintiff's failure to designate an expert on causation and damages. The court of appeals affirmed. The Supreme Court vacated the opinion of the court of appeals and reversed the summary judgment, holding that expert testimony was not required for Plaintiff to survive Defendants' motion for summary judgment on either causation or damages. View "Putman v. Walther" on Justia Law

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The Supreme Court reversed the judgment of the district court granting a tax deed holder possession of disputed property and remanded the case for dismissal, holding that Iowa R. Civ. P. 1.943 barred the tax deed holder's third forcible entry and detainer (FED) action, and the district court erred in concluding otherwise.At issue was Rule 1.943, under which a second voluntary dismissal of a tax deed holder's FED action operates as an adjudication on the merits unless the court orders otherwise. The tax deed holder in this case twice purported to dismiss without prejudice its FED petition against the property owner who was delinquent in paying taxes. The district court allowed the tax deed holder's third FED action to go forward. The Supreme Court reversed, holding that the district court erred by allowing the third FED action to go forward because it involved the same claim as the two prior actions. View "ACC Holdings, LLC v. Rooney" on Justia Law

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The Supreme Court affirmed the order of the district court granting summary judgment in favor of Insurer in this insurance dispute, holding that summary judgment was properly granted.Insured, which operated a bar and restaurant, made a claim under its commercial property insurance policy for business interruption coverage for the period it closed its business in response to the order of the West Virginia Governor that bars and restaurants shut down in response to the COVID-19 pandemic. Insurer denied the claim. The Supreme Court affirmed, holding (1) the language "direct physical loss of or damage to Covered Property" requires a physical aspect to the property loss before coverage is triggered; and (2) Insured's claim failed under the provision that required actual damage to nearby property. View "Jesse’s Embers, LLC v. Western Agricultural Insurance Co." on Justia Law

Posted in: Insurance Law