Justia Iowa Supreme Court Opinion Summaries

A Florida resident who worked as an independent contractor driver for an Indiana-based transportation company initiated a lawsuit in the United States District Court for the Northern District of Iowa, alleging violations of Iowa’s business opportunity promotions statutes. The Indiana company, registered to do business in Iowa as a foreign corporation and having appointed an agent for service of process as required by Iowa law, argued that it had no substantial presence or employees in Iowa. The plaintiff asserted that the company’s registration and agent appointment constituted consent to personal jurisdiction, among other arguments.The United States District Court for the Northern District of Iowa denied the Indiana company’s motion to dismiss for lack of personal jurisdiction. It concluded that, under Iowa law, a foreign corporation consents to personal jurisdiction by registering to do business in Iowa and designating an agent for service. However, recognizing the absence of controlling Iowa precedent on this issue, the federal court certified a question of state law to the Iowa Supreme Court for resolution.The Iowa Supreme Court answered the certified question and held that, under Iowa law, a foreign corporation does not consent to personal jurisdiction merely by registering to do business in Iowa, appointing an agent for service of process, or receiving service through that agent. The court determined that Iowa Code chapter 490 does not require foreign corporations to consent to personal jurisdiction as a condition of registration or agent appointment, and declined to interpret the statute as implicitly imposing such consent. The Iowa Supreme Court’s answer was in the negative, clarifying that registration and agent appointment do not constitute consent to personal jurisdiction in Iowa. View "Kelchner v. CRST Expedited, Inc." on Justia Law

A Texas truck driver was injured while making roadside repairs in Iowa when his parked semi was struck by another vehicle. After the accident, the driver retained a Texas attorney to pursue his personal injury claim. That attorney negotiated with the insurer for the other driver, ultimately agreeing to a settlement of $125,000 and requesting a release. However, the client did not sign the release and later replaced his attorney, claiming he had not authorized the settlement. The client then filed a lawsuit in Iowa, seeking additional compensation and naming the driver, the driver’s employer, and others as defendants.The defendants responded by moving to enforce the settlement agreement in the Iowa District Court for Warren County. The district court, acting as factfinder with no objection from either party, held a hearing, accepted evidence, and considered the client’s affidavit. The court found that the attorney was presumed to have settlement authority and that the client had not rebutted this presumption with clear and convincing evidence. The court enforced the settlement and dismissed the case upon payment of the agreed sum. The client’s motion to reconsider was denied, and he appealed.The Iowa Court of Appeals affirmed, finding the district court’s factual findings were supported by substantial evidence. The Iowa Supreme Court granted further review. The Supreme Court held that, because the client did not object to the district court’s procedure, the court properly acted as factfinder. The Supreme Court further held that the district court’s finding—that the attorney had authority to settle—was supported by substantial evidence, and thus the settlement agreement was enforceable. The court affirmed the decisions of the lower courts. View "Recio v. Fridley" on Justia Law

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

Minor Doe, Father Doe, and Mother Doe filed a lawsuit against the Western Dubuque Community School District and several school officials after Minor Doe was assaulted by another student during class. The plaintiffs claimed negligence, breach of fiduciary duty, and loss of consortium. The school did not contact medical personnel or the parents after the incident, and Minor Doe was later diagnosed with a concussion.The Iowa District Court for Dubuque County dismissed the case on four grounds: failure to meet the heightened pleading requirements of the Iowa Municipal Tort Claims Act (IMTCA), improper use of pseudonyms, failure of the breach of fiduciary duty claim as a matter of law, and the consortium claim failing without the underlying causes of action. The plaintiffs appealed the dismissal.The Iowa Supreme Court reviewed the case and concluded that the district court erred in dismissing the case based on the IMTCA’s qualified immunity provision and the use of pseudonyms. The court held that the IMTCA’s qualified immunity provision does not apply to common law claims and that pseudonymous petitions are generally disfavored but may be allowed in certain circumstances. The court found that the plaintiffs should have been given an opportunity to amend their petition to use their real names. However, the court affirmed the dismissal of the breach of fiduciary duty claim, stating that schools and their officials do not generally have fiduciary relationships with students.The Iowa Supreme Court reversed the district court’s dismissal of the negligence and consortium claims and remanded the case for further proceedings, while affirming the dismissal of the breach of fiduciary duty claim. View "Doe v. Western Dubuque Community School District" on Justia Law

In February 2014, Clint Shalla entered into a debt settlement agreement with Greg and Heather Koch to prevent a foreclosure on his farm. The Kochs agreed to purchase the farm and give Clint an exclusive option to repurchase it by August 15, 2015, with written notice and financing commitment. Clint's wife, Michelle, was not a party to the agreement but conveyed her marital interest in the property. Clint sought financing from Christopher Goerdt, then president of Peoples Trust and Savings Bank, who allegedly agreed to secure financing. Clint missed the option deadline, and the Kochs later agreed to sell the farm for a higher price. Goerdt, who had moved to County Bank, secured financing for the Shallas, but was later found to be involved in fraudulent activities.The Iowa District Court for Washington County granted partial summary judgment in favor of Peoples Bank, dismissing Michelle's fraudulent misrepresentation claim. The court later reconsidered and dismissed the Shallas' negligence and fraudulent misrepresentation claims, citing Iowa Code section 535.17. The court ruled in favor of County Bank in the foreclosure action and found Goerdt liable for conversion. The Shallas appealed, and the Iowa Court of Appeals affirmed the district court's judgment, with a dissent on the application of the statute of frauds.The Iowa Supreme Court reviewed the case and affirmed the lower courts' decisions. The court held that Iowa Code section 535.17, the credit agreement statute of frauds, barred the Shallas' claims for negligence and fraudulent misrepresentation. The court concluded that the statute applies to all actions related to unwritten credit agreements, regardless of whether the claims are framed in contract or tort. The case was remanded to the district court for a determination of County Bank's attorney fees, including appellate attorney fees. View "County Bank v. Shalla" on Justia Law

A railroad worker, Phillip Morgan, committed suicide after experiencing months of alleged harassment by his supervisor at Union Pacific Railroad Company. His wife, Kera Morgan, acting as the administrator of his estate, filed a lawsuit under the Federal Employers’ Liability Act (FELA), seeking wrongful death damages. She claimed that the harassment and stress from his job led to Phillip's emotional distress and eventual suicide.The Iowa District Court for Polk County granted summary judgment in favor of Union Pacific, concluding that Phillip's injuries were emotional and not tied to a physical impact or near physical harm, thus falling outside the scope of FELA. The court held that FELA did not cover emotional injuries unless there was a physical impact or the worker was in imminent danger of physical harm.The Iowa Supreme Court reviewed the case and affirmed the district court's decision. The court held that under the precedent set by the United States Supreme Court in Consolidated Rail v. Gottshall, FELA incorporates common law limits on compensable injuries. The court concluded that Phillip's emotional injuries, which led to his suicide, did not meet the "zone of danger" test established in Gottshall. This test requires that the worker must have been in immediate risk of physical impact or harm to recover for emotional injuries under FELA. Since Phillip's injuries were purely emotional and not tied to any physical impact or imminent threat of physical harm, the court ruled that FELA did not provide coverage for his case. View "Estate of Morgan v. Union Pacific Railroad Company" on Justia Law

A mother sought to modify an existing child custody order to change the school district her daughter attends after moving to a new residence. The father objected, arguing that changing schools would be disruptive and limit his time with the daughter. Unable to reach an agreement through mediation, the mother petitioned the court to modify the custody decree.The Iowa District Court for Worth County denied the mother's request, determining that changing school districts was not in the daughter's best interests. The mother appealed, and while the appeal was pending, the Iowa Supreme Court decided In re Marriage of Frazier. The Court of Appeals, interpreting Frazier, concluded that the district court lacked authority to hear the mother's petition because she was not seeking to alter the parents' status as joint legal custodians. The Court of Appeals affirmed the district court's ruling without considering the merits of the mother's petition.The Iowa Supreme Court reviewed the case and disagreed with the Court of Appeals' interpretation of Frazier. The Supreme Court held that a court that entered a custody decree has the authority to modify it when requested, even if the modification does not relate to who has legal custody. The Supreme Court found that the district court had the authority to rule on the mother's petition since the decree specified the daughter's school district, and the mother sought to modify that based on a change of circumstances.On de novo review, the Iowa Supreme Court agreed with the district court's determination that changing school districts was not in the daughter's best interests. Therefore, the Supreme Court vacated the Court of Appeals decision and affirmed the district court's order denying the modification petition. View "Venechuk v. Landherr" on Justia Law

Scott Hampe was employed by Charles Gabus Motors, Inc. (Gabus) from 2008 until December 2019. Gabus conducted an unannounced drug test on December 5, 2019, assisted by Mid-Iowa Occupational Testing (Mid-Iowa). Hampe was selected as an alternate for testing and was ultimately tested. During the test, Hampe provided two insufficient urine samples and decided to leave the testing area to care for his sick child, despite being warned by his manager that leaving would result in termination. Hampe was subsequently fired.Hampe filed a lawsuit against Gabus and Mid-Iowa in May 2020, alleging violations of Iowa Code section 730.5, which governs employer drug testing, and asserting common law claims. The Iowa District Court for Polk County granted summary judgment in favor of Gabus and Mid-Iowa, dismissing all of Hampe’s claims. Hampe appealed, and the Iowa Court of Appeals affirmed the dismissal of claims against Mid-Iowa and most claims against Gabus but reversed the dismissal of claims related to testing pool requirements, supervisor training, and uniform disciplinary policy, finding genuine issues of material fact.The Iowa Supreme Court reviewed the case and focused on Hampe’s claim that Gabus violated section 730.5’s requirements for the composition of testing pools. The court concluded that Gabus failed to substantially comply with the statutory requirements for the testing pool, as the pool included employees who were not scheduled to work at the time of testing. The court also found that Hampe was aggrieved by this failure, as his selection for testing and subsequent termination were based on a non-compliant process. The court reversed the district court’s judgment in part, affirmed it in part, and remanded the case for further proceedings to determine the appropriate relief for Hampe. The court also deemed Hampe’s claims concerning supervisor training and uniform disciplinary policy moot in light of the resolution of the pooling claim. View "Hampe v. Charles Gabus Motors, Inc." on Justia Law

A county board of supervisors approved a nonprofit entity’s application to rezone a parcel of land in rural Polk County. Another nonprofit entity and several nearby landowners filed a lawsuit challenging the rezoning decision. The plaintiffs argued that the rezoning violated the county’s comprehensive land use plan, zoning ordinances, and constituted illegal spot zoning. The board of supervisors moved to dismiss the lawsuit, claiming the plaintiffs lacked standing and were subject to heightened pleading requirements under Iowa’s Municipal Tort Claims Act.The Iowa District Court for Polk County granted the motion to dismiss, concluding that the plaintiffs failed to establish standing and were subject to the Act’s heightened pleading requirements. The court found that the individual plaintiffs did not adequately allege their proximity to the rezoned property or their personal concerns, and that the nonprofit organization did not sufficiently allege that its members had a specific and personal interest in the rezoning. The court also ruled that the plaintiffs could not amend their petition due to the Act’s requirements.The Iowa Supreme Court reviewed the case and reversed the district court’s decision. The Supreme Court held that the heightened pleading requirements and penalties under Iowa Code § 670.4A(3) did not apply because the plaintiffs were not seeking monetary damages. The court found that the individual plaintiffs had sufficiently alleged standing based on their proximity to the rezoned property and the nature of the proposed changes. However, the court concluded that the nonprofit organization had not established standing but should be allowed to amend its petition. The case was remanded for further proceedings. View "1000 Friends of Iowa v. Polk County Board of Supervisors" on Justia Law

Jahn Patric Kirlin and Sara Louise Kirlin filed a medical malpractice lawsuit against Dr. Christian William Jones, Dr. Barclay A. Monaster, and Physicians Clinic Inc. d/b/a Methodist Physicians Clinic – Council Bluffs. Jahn Kirlin experienced severe neck pain and headaches, and despite seeking medical help, an MRI was delayed. Dr. Monaster, who had returned from treatment for alcohol abuse, refused to order an MRI, and Kirlin later suffered a stroke after a chiropractic adjustment. The plaintiffs allege that the defendants altered medical records and that Dr. Monaster was intoxicated during treatment.The Pottawattamie County District Court initially dismissed the case due to a defective certificate of merit. The plaintiffs refiled with a new certificate, but the court granted summary judgment for the defendants. The Iowa Supreme Court reversed this decision, allowing the plaintiffs to proceed.Upon remand, the district court did not set new deadlines, leading to confusion about the applicable expert certification deadline. The defendants moved for summary judgment again, arguing the plaintiffs missed the deadline. The district court agreed, finding no good cause to extend the deadline, and granted summary judgment to the defendants.The Iowa Supreme Court reviewed the case and found that the district court abused its discretion by not finding good cause for the plaintiffs' delayed expert certification. The court noted the confusion about deadlines, lack of prejudice to the defendants, the plaintiffs' diligence, and the defendants' actions. The court reversed the summary judgment and remanded the case for further proceedings. View "Kirlin v. Monaster" on Justia Law