Justia Iowa Supreme Court Opinion Summaries

Six unrelated criminal defendants in Scott County, Iowa, were each charged with serious misdemeanors in late 2024 and requested court-appointed counsel due to indigency. The Iowa District Court for Scott County initially appointed the Davenport local public defender’s office to represent each defendant. Shortly after these appointments, the Davenport Public Defender, citing a temporary overload of cases as specified in Iowa Code section 13B.9(4)(a), filed motions to withdraw from representing these defendants. The office asserted it was ethically unable to handle the additional cases after considering all relevant factors, including attorney staffing and caseloads.The district associate judge denied these withdrawal motions, stating the Davenport office was fully staffed and that insufficient information had been provided about its workload. The court also noted the lack of available contract or noncontract attorneys to appoint in place of the public defender. Despite repeated filings by the Davenport PD asserting the overload, the district court continued to deny withdrawal, eventually ordering the chief public defender to appear in each case. The State Public Defender then filed a petition for a writ of certiorari with the Iowa Supreme Court, challenging the district court’s refusal to allow the Davenport PD to withdraw.The Supreme Court of Iowa held that while district courts have a limited role in ensuring the statutory precondition of a temporary overload is met, they must be highly deferential to a local public defender’s professional representation regarding such overload. The court concluded that the Davenport PD’s representations satisfied its burden to establish a temporary overload. The district court exceeded its authority by refusing to accept these representations and denying withdrawal. The Supreme Court sustained the writ of certiorari and vacated the district court’s orders attaching the Davenport PD to the six cases. View "State Public Defender v. Iowa District Court For Scott County" on Justia Law

The defendant, a former employee of a tattoo studio, embezzled approximately $120,000 from her employer over a nine-month period. After being charged with first-degree theft, she pleaded guilty under a plea agreement in which both she and the State recommended a deferred judgment, with restitution payments as a condition of probation. Prior to sentencing, a presentence investigation report (PSI) was submitted, but it did not include any victim-impact statements. At the sentencing hearing, the business owner delivered an oral victim-impact statement detailing the emotional and financial harm caused by the theft. The district court declined to follow the parties’ joint recommendation and instead imposed the statutory maximum prison sentence of up to ten years.The defendant appealed to the Iowa Court of Appeals, arguing that the district court abused its discretion by sentencing her to prison and by allegedly relying on improper factors contained in the victim-impact statement, which she claimed included unproven allegations. The Court of Appeals affirmed the district court’s judgment, holding that the defendant had not preserved error regarding the victim-impact statement because she failed to object at the sentencing hearing. The appellate court also found no indication that the district court had relied on improper factors.Upon further review, the Supreme Court of Iowa vacated the Court of Appeals’ decision. The Supreme Court clarified that, with respect to previously unseen oral victim-impact statements delivered at sentencing, defendants are not required to object contemporaneously in order to raise claims on direct appeal about improper sentencing considerations. However, the Supreme Court concluded that the victim-impact statement in this case was largely appropriate and that the record did not indicate the district court relied on any improper factors. The Supreme Court affirmed the district court’s judgment and sentence. View "State of Iowa v. Hallock" on Justia Law

The defendant was charged with multiple sexual offenses arising from alleged abuse of his grandchild in Worth County, Iowa, and a separate set of charges in another county. Pursuant to a plea agreement, he entered a guilty plea to lascivious acts with a child, and the remaining charges in both counties were dismissed. At sentencing, the presentence investigation report recommended incarceration, and the defendant, along with supportive family members, argued for probation. No victim impact statement was presented at the sentencing hearing, and the defendant did not object to its absence. The district court imposed a ten-year sentence and lifetime supervision.Shortly after sentencing, the defendant moved for resentencing, claiming that a newly obtained written statement from the victim, advocating for probation, should be considered. The district court denied the motion, finding no error in the sentencing process and noting that the victim impact statement appeared to have been generated after sentencing. The defendant filed a notice of appeal challenging both the sentence itself and the denial of his motion for resentencing. The Iowa Court of Appeals rejected the sentencing challenge and held it lacked jurisdiction to consider the resentencing issue, reasoning that the notice of appeal did not specifically reference the post-sentencing order.On further review, the Supreme Court of Iowa held that once good cause to appeal is established, appellate jurisdiction extends to all issues raised in the appeal, including those connected to the sentencing hearing and its aftermath. The court concluded that the notice of appeal was sufficient to encompass the denial of the resentencing motion. Nevertheless, the court found no abuse of discretion by the district court in denying resentencing, holding that the defendant has no general right to a second sentencing nor a right to insist that a victim’s statement be considered in mitigation. The judgment of the district court was affirmed. View "State of Iowa v. Warburton" on Justia Law

Several residents of Estherville, Iowa, sued a former police officer, the police chief, the City of Estherville, and its insurance company, alleging that the officer repeatedly accessed and disseminated their confidential criminal history and intelligence data for improper purposes between 2015 and his resignation on May 3, 2019. The officer used this data for personal gain, including assisting with vehicle repossessions and harassing certain plaintiffs. Complaints about his conduct were made to the police chief, who ultimately placed the officer on administrative leave and accepted his resignation. Criminal charges were later brought against the officer in 2022 for his actions.After learning of the wrongful data access between 2021 and 2022, the plaintiffs filed suit on July 7, 2023, in the Iowa District Court for Emmet County, asserting statutory and common law claims, including invasion of privacy and conspiracy, and seeking damages under Iowa Code section 692.6. The defendants moved to dismiss, arguing the two-year statute of limitations under the Iowa Municipal Tort Claims Act (IMTCA) barred the claims, since all alleged misconduct ended by May 3, 2019. The district court denied dismissal, holding that the statutory claim under section 692.6 was subject to a five-year limitation with a discovery rule, and that the remaining claims accrued when plaintiffs discovered the wrongdoing.On appeal, the Iowa Court of Appeals reversed the district court and ordered dismissal, concluding that all claims were governed by the IMTCA’s two-year statute of limitations and that the date of injury was when the data was accessed or disseminated, not when plaintiffs learned of it. The Iowa Supreme Court affirmed the appellate court, holding that the IMTCA’s statute of limitations applied to all claims and began at the time of the wrongful acts, regardless of later discovery or emotional harm. The case was remanded for dismissal. View "Abrahamson v. Scheevel" on Justia Law

The State of Iowa brought suit against several related corporate entities associated with the TikTok social media platform, alleging violations of the Iowa Consumer Frauds Act. The State claimed that TikTok misrepresented the safety and age-appropriateness of its app by maintaining a “12+” rating on app stores despite the presence of mature and inappropriate content. The app was widely downloaded and used in Iowa, with hundreds of thousands of devices in the state activating it. TikTok entered into terms of service agreements with Iowa users, collected location data, and targeted Iowa-specific advertisements, thereby generating revenue from its Iowa user base.In the Iowa District Court for Polk County, the TikTok entities moved to dismiss the State’s petition on several grounds, including lack of personal jurisdiction. The district court denied the motion, finding that it had personal jurisdiction over the defendants and that the State had properly pleaded a valid claim. The district court also denied the State’s request for a temporary injunction, concluding that irreparable harm had not been shown. The defendants sought interlocutory review solely on the issue of personal jurisdiction, which was granted.Upon review, the Iowa Supreme Court found that the TikTok entities had sufficient minimum contacts with Iowa, having purposefully availed themselves of the privilege of conducting business in the state by entering into ongoing contractual relationships, collecting data, and serving targeted advertisements. The court concluded that the State’s claims “arose out of or related to” these contacts, and that exercising jurisdiction did not offend traditional notions of fair play and substantial justice. Accordingly, the Iowa Supreme Court affirmed the district court’s denial of the defendants’ motion to dismiss for lack of personal jurisdiction. View "State of Iowa, Ex Rel. Attorney General Brenna Bird v. Tiktok, Inc." on Justia Law

Jack Rose was a resident at Oakland Manor, a skilled nursing facility in Iowa. During the COVID-19 pandemic, Rose was hospitalized and later returned to the facility, where he was placed in precautionary isolation following public health guidance. After attending off-site medical appointments, he was again isolated but was subsequently hospitalized for a suspected stroke and tested positive for COVID-19. Rose died in the hospital, with COVID-19 listed as the immediate cause of death. A federal inspection later found Oakland Manor had failed to fully comply with recommended infection-control protocols, including inconsistent use of personal protective equipment and incomplete isolation measures.The plaintiffs, Rose’s sons, brought wrongful death and other related claims against Oakland Manor, alleging reckless and willful misconduct in failing to follow federal and state COVID-19 prevention guidelines. The Iowa District Court for Pottawattamie County granted summary judgment in favor of Oakland Manor, holding that the plaintiffs' evidence—primarily a federal inspection report and an expert witness disclosure—did not establish reckless or willful misconduct as required to overcome statutory immunity provided to health care providers for COVID-19-related injuries. The plaintiffs appealed, and the Iowa Court of Appeals affirmed the dismissal, finding insufficient evidence of recklessness and, in addition, lack of qualified evidence regarding causation.The Iowa Supreme Court reviewed the case and affirmed the district court’s judgment, concluding that the plaintiffs had not presented sufficient evidence to create a genuine issue of material fact regarding recklessness or willful misconduct under Iowa Code section 686D.6(2). The Court vacated the portion of the Court of Appeals decision related to causation, holding that the deficiencies at Oakland Manor amounted at most to negligence, not recklessness, and thus statutory immunity applied. View "Rose v. Oakland Healthcare Management, LLC" on Justia Law

An information security executive was hired by a financial institution to improve its internal controls but was later terminated. During her tenure, a subordinate raised concerns about compliance, which led to an internal audit and ultimately contributed to the decision to fire her. She believed her firing was motivated by sex discrimination and defamatory statements made by colleagues regarding her job performance. She first filed a complaint with the Iowa Civil Rights Commission, then a federal lawsuit against her employer and several individuals, alleging discrimination, defamation, and other claims. Most of her claims, including defamation, were dismissed by the United States District Court for the Southern District of Iowa for failure to state a claim, and summary judgment was granted to the defendants on the remaining claims. She did not appeal.Several months after her federal lawsuit concluded, she filed a new defamation action in the Iowa District Court for Polk County against a different set of coworkers, based on statements and internal reports from more than three years prior. The defendants moved to dismiss, arguing that the claims were barred by Iowa’s two-year statute of limitations for injuries to reputation. The district court granted the motion to dismiss, finding that the limitations period began at publication or, alternatively, that she was on inquiry notice of the claims by the time she filed her first lawsuit.On appeal, the Iowa Court of Appeals reversed, holding that the discovery rule might apply to defamation claims and that factual issues about notice precluded dismissal. Upon further review, the Iowa Supreme Court vacated the appellate decision and affirmed the district court’s dismissal, holding that the plaintiff was on inquiry notice of her defamation claims more than two years before filing suit, so the claims were time-barred regardless of the discovery rule’s application. View "Betz v. Mathisen" on Justia Law

A corrections officer at the Anamosa State Penitentiary was killed during a prison escape attempt in March 2021, along with a nurse, when two inmates armed themselves with tools from the prison’s machine shop and attacked staff in the infirmary. The inmates were apprehended and convicted of first-degree murder. The officer’s surviving spouse filed compensation claims with the state appeal board against co-employees of the Iowa Department of Corrections, alleging gross negligence contributed to the security lapses that enabled the attack. The claims identified several co-employees by name as potential parties at fault.After the claims were withdrawn due to lack of resolution, the surviving spouse filed suit in the Iowa District Court for Jones County against twenty-six co-employees, including some not previously named in the administrative process. The defendants moved to dismiss, arguing that Iowa’s workers’ compensation law precluded gross negligence claims against state or local government co-employees, that the spouse failed to comply with administrative requirements under the Iowa Tort Claims Act (ITCA), and that the pleading was insufficient under qualified immunity standards. The district court denied the motion on all grounds.The Iowa Supreme Court reviewed the case after treating the appeal as an interlocutory application. The court held that Iowa Code section 85.2 does not bar gross negligence claims against state co-employees; such claims are permissible under section 85.20(2). The court also found that, while the administrative claims process under the ITCA was satisfied as to those co-employees named in the initial claims, it was not satisfied for those not identified. Therefore, the motion to dismiss was properly denied for co-employees named in the administrative claims and should have been granted for those who were not. The denial was affirmed in part, reversed in part, and the case remanded. View "Montague v. Skinner" on Justia Law

The defendant faced four criminal charges in separate cases—three for theft (shoplifting) and one for interference with official acts following an arrest. As part of a single plea agreement, he pled guilty to two theft charges; in return, the State dismissed the remaining two cases, with the defendant agreeing to pay costs in the dismissed cases. The Iowa District Court for Polk County sentenced the defendant in the two theft cases, dismissed the other two, and ordered him to pay costs for the dismissed cases, including indigent defense recoupment and filing fees.After the district court’s dispositional orders, the defendant appealed, challenging the court’s authority to assess costs in the dismissed cases. The Iowa Supreme Court granted discretionary review to address this issue. The State conceded that no statute authorized the district court to impose costs in dismissed criminal cases. The Supreme Court examined relevant statutory provisions, noting that neither Chapter 815 nor Chapter 910 of the Iowa Code allows for assessment of costs against a defendant when a case is dismissed, as such authority was repealed in 2012.The Iowa Supreme Court held that parties cannot confer statutory authority on the court through a plea agreement for a disposition not authorized by statute. Accordingly, the district court’s orders assessing costs in the dismissed cases were ultra vires and invalid. The Supreme Court vacated the convictions, sentences, and dispositional orders, and remanded the cases. On remand, the State may elect either to vacate only the unauthorized cost orders while enforcing the remainder of the plea bargain, or to vacate the entire plea agreement and all resulting orders, with the option to reinstate any dismissed charges. View "State of Iowa v. Pagliai" on Justia Law

This case concerns a dispute over waterfront access involving two neighboring parties. Donald and Linda Lawson purchased Lot 21, which was situated near the Maquoketa River, in 2002. Their decision to buy the property was influenced by a well-cleared path leading to the water, which they believed was covered by an easement. The easement deed they received purported to grant them access across adjacent lots 19 and 20 to the river. However, the deed contained critical errors: the grantor was incorrectly named, and the legal description of the easement did not actually reach the riverbank or follow the usable path.After Mark and Stacey Fink acquired lots 19 and 20 in 2021, they disputed the Lawsons’ right to use the path and initiated a lawsuit seeking to quiet title, damages, and other relief. The Lawsons defended on the basis of various types of easements and counterclaimed to quiet title for the easement. The Iowa District Court for Delaware County denied the Lawsons’ request for reformation of the easement deed, granted quiet title to the Finks, and rejected the Lawsons’ defenses and counterclaims. The Lawsons appealed, and the Iowa Court of Appeals affirmed most of the district court’s rulings but identified an error regarding the prescriptive easement defense.On further review, the Iowa Supreme Court conducted a de novo review and held that the district court had the equitable power to reform the faulty easement deed to reflect the express intent of the grantor and the actual agreement between the original parties. The court found clear, convincing evidence of mutual mistake regarding both the grantor’s identity and the path’s legal description. Therefore, the Supreme Court vacated the decision of the court of appeals, reversed the district court’s judgment, and remanded for reformation of the easement deed consistent with its opinion. View "Fink v. Lawson" on Justia Law