Justia Iowa Supreme Court Opinion Summaries

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

In the 1950s, Bert and Donna Miller sought fertility treatment at the University of Iowa Hospitals and Clinics. Dr. John H. Randall, the head of the department, assisted them, resulting in the birth of three children. Decades later, DNA testing revealed that Dr. Randall, not Bert Miller, was the biological father of two of the children. The plaintiffs, Bert Miller and Nancy Duffner, sued the State of Iowa under the Fraud in Assisted Reproduction Act (FARA), alleging that Dr. Randall used his own sperm without their parents' knowledge or consent.The Iowa District Court for Johnson County dismissed the case, ruling that FARA, enacted in 2022, does not apply retroactively to actions taken decades earlier. The court found that FARA lacks any express language indicating legislative intent for retrospective application, and thus, it operates only prospectively. The plaintiffs appealed, arguing that FARA's provision allowing children to sue "at any time" implies retroactive application.The Iowa Supreme Court reviewed the case and affirmed the district court's decision. The court held that FARA does not apply to fertility fraud committed before the statute was enacted. The court emphasized that without an express retroactivity provision, statutes creating new substantive liabilities are presumed to operate only prospectively. The court found no language in FARA that rebuts this presumption and concluded that the statute's provision allowing actions to be brought "at any time" pertains only to future violations. Therefore, the plaintiffs' claims were dismissed with prejudice. View "Miller v. State" on Justia Law

Antoine Smith, a police officer for the City of Cedar Rapids, was ordered to retake his official photo, which he refused. This led to a formal administrative investigation by the Cedar Rapids Police Department. Smith was notified of the investigation and later interviewed, during which he admitted to violating the department's code of conduct. The investigation concluded with a recommendation for a ten-hour suspension without pay and a requirement for Smith to retake his photo. Smith's counsel requested the investigation results and materials, which were denied until after the disciplinary decision was made.The Iowa District Court for Linn County granted summary judgment in favor of the City, concluding that the City did not violate Iowa Code section 80F.1(3) or 80F.1(9) by withholding the investigative materials until after the disciplinary decision. Smith appealed this decision.The Iowa Supreme Court reviewed the case and affirmed the lower court's decision. The court held that under Iowa Code section 80F.1(3), an officer is entitled to the results of an investigation only after the agency has made a final determination, including whether discipline will be imposed. Similarly, under section 80F.1(9), the officer is entitled to investigative materials only after discipline is decided. The court concluded that the City did not violate these provisions by waiting until after the disciplinary decision to provide the requested materials. The court emphasized that the statutory language clearly conditions the rights to these materials on the imposition of discipline. View "Smith v. City of Cedar Rapids" on Justia Law

Marlene Banwart and her husband Richard filed a medical malpractice lawsuit in 2020 against Neurosurgery of North Iowa, P.C., Dr. David Beck, and Dr. Thomas Getta. Marlene had undergone a lumbar laminectomy performed by Dr. Beck in July 2018, followed by severe postoperative pain and complications, including an epidural hematoma that required emergency surgery. The plaintiffs alleged negligence in the surgery and postoperative care by Dr. Beck and Dr. Getta.The Iowa District Court for Cerro Gordo County ruled on cross-motions for summary judgment. The court dismissed the plaintiffs' action as time-barred, concluding that the Iowa Supreme Court's emergency supervisory orders tolling the statute of limitations during the COVID-19 pandemic were invalid. However, the court found that the plaintiffs had substantially complied with Iowa's certificate of merit affidavit statute, despite the certificates not being signed under oath or penalty of perjury. Both parties appealed these rulings.The Iowa Supreme Court reviewed the case and bypassed the statute of limitations issue, focusing on the cross-appeal regarding the certificate of merit. The court held that the plaintiffs' certificates did not substantially comply with Iowa Code section 147.140 because they were not signed under oath or penalty of perjury. The court also rejected the plaintiffs' claims that the statute was void for vagueness and that the defendants had waived their rights by delaying their challenge. Consequently, the court reversed the district court's ruling on the certificates of merit and remanded the case for entry of summary judgment in favor of the defendants. View "Banwart v. Neurosurgery of North Iowa, P.C." on Justia Law

Marleny Rivas filed a lawsuit against Derek Brownell and Lindsey Wessel to recover damages for injuries she sustained in a car accident on August 4, 2018. Rivas filed her lawsuit on October 16, 2020, beyond the two-year statute of limitations but within a seventy-six-day tolling period established by a supreme court supervisory order due to the COVID-19 pandemic.The defendants filed motions for summary judgment, arguing that the lawsuit was time-barred as it was filed beyond the two-year statute of limitations and that the supreme court's tolling provision violated the separation of powers and their due process rights. The Iowa District Court for Polk County granted the summary judgment, concluding that the supreme court lacked the authority to toll the statute of limitations, and thus Rivas's lawsuit was untimely. Rivas appealed the decision.The Iowa Supreme Court reviewed the case and addressed whether the supreme court had the emergency powers to toll the statute of limitations during the pandemic. The court held that the tolling provision in the supervisory order was within the court's constitutional authority to exercise supervisory and administrative control over the court system. The court found that the tolling provision was a valid response to the unprecedented public health emergency and did not violate the separation of powers or due process rights of the defendants. Consequently, the court reversed the district court's order of dismissal and remanded the case for further proceedings. View "Rivas v. Brownell" on Justia Law

In 2016, a fourteen-year-old boy was involuntarily committed, disqualifying him from possessing firearms. Eight years later, he petitioned the district court to restore his firearm rights under Iowa Code section 724.31. The district court found that the statutory requirements were met and restored his firearm rights. The State appealed the decision.The Iowa District Court for Monona County initially reviewed the case and granted the petition to restore the petitioner’s firearm rights. The State then appealed the district court’s decision, arguing that the restoration requirements were not met and questioning the State’s right to appeal the decision.The Iowa Supreme Court reviewed the case and first addressed whether the State had the right to appeal the restoration order. The court concluded that the State did have the right to appeal under Iowa Rule of Appellate Procedure 6.103(1). The court then reviewed the merits of the case de novo and found that the petitioner had met the burden of proving by a preponderance of the evidence that he would not likely act in a manner dangerous to public safety and that granting the relief would not be contrary to the public interest. The court affirmed the district court’s order restoring the petitioner’s firearm rights. View "In re N.F." on Justia Law

Jessenia Burton, a student driver, was involved in a car accident during a drivers' education course on April 30, 2017. Burton and her parents sued several defendants, including West Bend Mutual Insurance Company, which provided coverage for the vehicles used in the course. Burton retained neuropsychologist Dr. Daniel Tranel, who conducted an evaluation and diagnosed her with a concussion, postconcussion syndrome, PTSD, and major depressive disorder. Dr. Tranel's report included summaries of psychological and neuropsychological tests administered to Burton.The Iowa District Court for Polk County granted West Bend's motion to compel the production of Dr. Tranel's psychological test material and test data. The court reasoned that since Burton made her mental condition an element of her claim, the information was discoverable under Iowa Code section 228.6(4)(a). The court ordered the information to be produced to West Bend and its attorneys, issuing a protective order to limit further disclosure.The Iowa Supreme Court reviewed the case and reversed the district court's decision. The court held that Iowa Code section 228.9 explicitly prohibits the disclosure of psychological test material and test data in a judicial proceeding to anyone other than a licensed psychologist designated by the individual. The court emphasized that the statute's language is clear and unambiguous, and the only exception to this prohibition is disclosure to another licensed psychologist. The court concluded that the district court erred in granting the motion to compel and vacated the protective order. The case was remanded for further proceedings consistent with this interpretation. View "Burton v. West Bend Mutual Insurance Company" on Justia Law

A vacancy on the Scott County Board of Supervisors occurred when Tony Knobbe resigned to become the Scott County Treasurer. A committee of county officials decided to fill the vacancy by appointment and kept certain applications confidential during the process. The committee referred to applicants by numbers and only revealed the name of the appointed individual. After the appointment, two individuals submitted open records requests for the confidential names and applications, which Scott County denied, citing Iowa Code section 22.7(18).The individuals filed a petition in the Iowa District Court for Scott County, which granted summary judgment in favor of Scott County, determining that the applications were exempt from disclosure under Iowa Code section 22.7(18). The district court relied on the precedent set in City of Sioux City v. Greater Sioux City Press Club, which held that employment applications could be kept confidential.The Iowa Supreme Court reviewed the case and reversed the district court's decision. The court held that the applications for the vacant county board of supervisors position were not confidential under section 22.7(18). The court reasoned that the applicants were not promised confidentiality beforehand, and the public nature of the appointment process meant it was not reasonable to believe that people would be deterred from applying if their applications were disclosed. The court ordered that the names and applications be disclosed and awarded costs and reasonable attorney fees to the plaintiffs. The case was remanded for further proceedings. View "Diercks v. Scott County, Iowa" on Justia Law

A man passed away, and his wife made a claim on his estate for half of the money he had removed from their joint bank account before his death. The wife argued that the couple owned the account as joint tenants, and her husband had withdrawn funds exceeding his interest. The district court dismissed her claim, concluding that she was making a claim for conversion sounding in tort and had not met the legal standard.The wife appealed, arguing that the district court applied the wrong legal standard and that a standard from caselaw on joint tenancies should apply. The Iowa Court of Appeals agreed with her, reversed the district court's decision, and remanded the case. The estate sought further review from the Iowa Supreme Court.The Iowa Supreme Court affirmed the decision of the Court of Appeals, holding that the district court applied an incorrect legal standard. The correct standard, as established in Anderson v. Iowa Department of Human Services, involves determining the respective rights of joint tenants based on their agreement and the presumption that each joint tenant is entitled to half of the joint account, which can be rebutted. The court remanded the case for a new trial to allow for proper fact-finding regarding whether the husband removed funds in excess of his interest in the joint account. View "In re Estate of Johnston" on Justia Law