Justia Iowa Supreme Court Opinion Summaries

Cynthia Miles, a sixty-four-year-old woman suffering from acute psychosis and a history of suicidal ideation, experienced several psychiatric crises in 2021. After multiple hospitalizations and escapes from care facilities, she was admitted to Harbor Point, an unlocked mental health facility, where she again escaped on November 11, 2021. Despite a search, Miles was never found. Her family, having previously experienced her disappearances followed by safe returns, could not determine her fate. After extensive efforts to locate her failed, her family petitioned the Iowa District Court for Pottawattamie County for a judicial determination of death. Following a jury trial, the court issued a certificate of presumed death on August 29, 2022.Subsequently, Miles’s daughter, as administrator of her estate, filed a wrongful death lawsuit against several healthcare providers. The defendants asserted that the action was time-barred under Iowa’s two-year statute of limitations for wrongful death claims, arguing that the limitations period began either at Miles’s disappearance or when the family first sought a declaration of death. The Iowa District Court for Cass County rejected this argument, ruling that the statute of limitations began only upon the judicial declaration of death, not the earlier disappearance.The Iowa Supreme Court reviewed the interlocutory appeal to determine when the limitations period commenced. The court held that, in a case where there is no known physical injury and it is unclear whether the missing person is alive or dead, the statute of limitations for a wrongful death claim does not begin to run until there is a judicial determination of death. The court affirmed the district court’s ruling, allowing the wrongful death action to proceed as timely filed. View "Schneide v. Holliday" on Justia Law

A patient suffered an injury during knee surgery in March 2022 and, together with his wife, filed a medical malpractice lawsuit against the operating surgeon and the orthopedic clinic in January 2023. Iowa law requires medical malpractice plaintiffs to serve a certificate of merit affidavit within sixty days after the defendant’s answer to the lawsuit. The plaintiffs served a certificate of merit within the deadline. However, the document was not sworn before an authorized officer and did not include the phrase “penalty of perjury” as required by Iowa statutes. Over a year later, the plaintiffs served an amended certificate that met the affidavit requirements, but it was well past the statutory deadline.After the defendants answered and discovery proceeded for more than a year, the defendants moved to dismiss in the Iowa District Court for Polk County, arguing that the timely certificate did not comply with statutory requirements. The district court found that the initial certificate was neither a true affidavit nor a permissible substitute under the relevant statutes. The court also concluded that the late-filed, proper affidavit could not cure the statutory violation because it was not filed within the required sixty days and there was no extension by agreement or motion. The district court dismissed the case.The Iowa Supreme Court reviewed the appeal. It held that substantial compliance with the certificate of merit affidavit requirement means providing either a true affidavit executed before an authorized person or a statement under penalty of perjury within sixty days. The plaintiffs failed to do either within the deadline, and their later submission could not cure the defect. The court also rejected arguments that the defendants had waived the affidavit requirement or that the statutory scheme violated the Iowa Constitution. The decision of the district court was affirmed. View "Rarick v. Smidt" on Justia Law

After a woman was injured in a car accident and treated at a hospital, an X-ray suggested a lung nodule, and her medical records recommended a chest CT scan for further investigation. No CT scan was ordered or performed, and she was released. Almost two years later, after suffering a femur fracture, a CT scan at a different hospital revealed cancer, and she subsequently passed away. Her husband and children, representing themselves and her estate, brought a wrongful-death medical malpractice suit against the hospital and multiple providers, alleging failure to properly follow up on the lung nodule.In the Iowa District Court for Scott County, the plaintiffs timely served certificates of merit as required by Iowa Code section 147.140, but these certificates were neither notarized nor included a statement that they were signed under penalty of perjury. Following the Iowa Supreme Court’s decision in Miller v. Catholic Health Initiatives-Iowa, Corp., the defendants moved to dismiss, arguing the certificates did not satisfy statutory requirements. The plaintiffs resisted, providing new expert statements but maintaining these were not amendments. The district court granted the defendants’ motion to dismiss with prejudice. After the death of one of the original plaintiffs, his son was appointed as executor and administrator for the estates. Notices of appeal were filed, initially signed by the non-lawyer administrator.The Supreme Court of Iowa first determined that the estates’ appeal should not be dismissed due to the unauthorized practice of law in filing the notice of appeal, since counsel promptly appeared and continued representation. On the substantive issue, the court was evenly divided on whether the district court correctly dismissed the suit for noncompliance with section 147.140. As a result, the dismissal was affirmed by operation of law. The motion to dismiss the appeal was denied, but the district court judgment was affirmed. View "Willhoite v. Genesis Health System" on Justia Law

A private trust owning land near a community park at Triboji Beach, adjacent to West Okoboji Lake, sought to quiet title to an unpaved road (Lakeview Drive) bordering its property. The land, including the road, had originally been dedicated to public use in 1929 by the Tribune Company. Despite the public’s longstanding use of the road for access to the beach and park, the trust initiated a quiet-title action against “Unknown Claimants,” providing notice solely by publication in a local newspaper. No parties appeared to contest the petition, resulting in a default judgment for the trust.Following the judgment, a group of neighboring landowners who regularly used the road discovered the action and filed a petition in the Iowa District Court for Dickinson County to vacate the default judgment. They argued that they, as well as the State of Iowa, should have received personal service because they were known or readily ascertainable interested parties. The district court initially agreed, finding that failure to personally serve the landowners and the State constituted fraud. However, after reconsideration, the district court reversed itself, holding that neither the landowners nor the State had a specific property interest requiring personal service and dismissed the petition to vacate, reinstating the default judgment.The Iowa Supreme Court reviewed the case and held that the trust’s failure to provide personal service to the neighboring landowners, who were known or readily ascertainable and had a potential adverse interest, constituted a procedural irregularity requiring the default judgment to be vacated. The Court also determined the trust was required to personally serve the State due to its potential jurisdiction under Iowa Code § 461A.11(2). The Supreme Court reversed the district court’s dismissal and remanded for further proceedings. View "Streeter v. The Dunn Trust Dated May 20, 2005" on Justia Law

A patient underwent surgery on September 4, 2020, and died twelve days later. Her estate and children brought a medical malpractice suit against the surgeon and hospital, alleging negligence. The defendants sought dismissal, arguing the plaintiffs had not satisfied Iowa’s certificate of merit requirements under Iowa Code section 147.140(1), which mandates a supporting expert affidavit early in medical malpractice litigation. The district court denied the motion to dismiss.The defendants then sought interlocutory review from the Iowa Supreme Court. The Iowa Supreme Court reversed the district court’s denial, finding the plaintiffs had not complied with the statutory affidavit requirement, and remanded with instructions to dismiss the case with prejudice. Following the remand, the plaintiffs attempted to file dismissals without prejudice before and after the district court’s order of dismissal with prejudice. Despite these filings, the district court entered a dismissal with prejudice as directed by the Iowa Supreme Court. The plaintiffs then filed a new lawsuit asserting the same claims against the same defendants. The defendants moved to dismiss this second action, citing claim preclusion (res judicata) and the statute of limitations. The Iowa District Court for Clinton County dismissed the second action.On appeal, the Iowa Supreme Court affirmed the dismissal. The court held that its prior mandate required dismissal with prejudice, and any attempt by the plaintiffs to dismiss without prejudice was contrary to that mandate and thus ineffective. The court found that the elements of claim preclusion were satisfied: the parties and claims were identical to the prior action, and there was a final judgment on the merits. Accordingly, the second lawsuit was barred. The Iowa Supreme Court affirmed the district court’s dismissal on claim preclusion grounds. View "Shontz v. Mercy Medical Center-Clinton, Inc." on Justia Law

A judgment creditor, Green Belt Bank & Trust, sought to collect on a $2.6 million judgment against Mashon Van Mill and others. After initial efforts to collect failed, Green Belt initiated garnishment proceedings against Unverferth Manufacturing Company, alleging that Unverferth owed substantial sums to Mashon for services. Unverferth initially indicated payments were for Mashon’s personal services but later clarified that Mashon worked as an independent contractor, invoicing through “Hill Top Industries,” a name also connected to Mashon. The parties disputed whether funds paid to Hill Top Industries were subject to garnishment and, if so, whether statutory limits applied.The Iowa District Court for Butler County found that Hill Top Industries was not distinct from Mashon, so the funds paid by Unverferth were subject to garnishment. However, the court limited the garnishment amount to 10% of the total payments, applying the cap in Iowa Code section 642.21(1), which restricts garnishment of an employee’s earnings. Green Belt challenged this ruling, arguing that the cap did not apply because Mashon was not an employee, and appealed after the district court denied reconsideration.The Iowa Court of Appeals affirmed the district court’s application of the statutory limit, following its own prior precedent. On further review, the Supreme Court of Iowa held that the statutory garnishment limits in Iowa Code section 642.21(1) apply only to earnings of employees, not independent contractors. The Court reasoned that “employee” has a distinct legal meaning that excludes independent contractors and overruled contrary appellate precedent. The Supreme Court affirmed in part and vacated in part the decision of the Court of Appeals, and reversed in part the district court’s judgment, remanding for entry of a judgment without application of the statutory garnishment cap. View "Green Belt Bank & Trust v. Van Mill" on Justia Law

A developer purchased a building for redevelopment and, after refinancing with a new bank, began negotiating a construction loan. The parties executed a document outlining proposed financing, which included an exclusivity clause requiring the developer to work only with the bank while the bank conducted due diligence. The proposal depended on the developer receiving specific tax credits. When those credits were not awarded, the bank proposed new terms or ending negotiations. The developer then sought financing from other lenders, ultimately securing a loan elsewhere, which led the bank to sue for breach of contract (based on the exclusivity clause) and for fraud.The Iowa District Court for Scott County granted summary judgment for the developer on the breach of contract claim, finding the proposal to be an unenforceable agreement to agree or, alternatively, discharged by the failed condition precedent (the tax credits). The court also excluded the financing proposal from trial on the fraud claim, concerned the jury would confuse it with a binding contract. The jury returned a verdict for the developer on the fraud claim. The Iowa Court of Appeals reversed, finding the exclusivity clause enforceable and the exclusion of the proposal at trial improper.The Supreme Court of Iowa granted further review. It held that while the exclusivity clause was severable and otherwise definite enough to be independently enforceable, the developer’s duty under that clause was discharged when the required tax credits were not obtained and the original deal was abandoned. Thus, there was no breach. The Supreme Court also concluded that the district court did not abuse its discretion by excluding the proposal from the fraud trial, as its admission risked unfair prejudice without preventing the bank from presenting its case. The Supreme Court vacated the court of appeals’ decision and affirmed the district court’s judgment. View "Northwest Bank & Trust Company v. Pershing Hill Lofts, LLC" on Justia Law

A woman died after a rapid health decline while receiving emergency and critical care at a West Des Moines hospital. Her husband, who was appointed as the administrator of her estate, filed a wrongful-death medical malpractice lawsuit against various medical providers. He brought the suit both on behalf of the estate and in his individual capacity, alleging multiple claims including negligence and seeking damages for emotional and financial loss. The husband, a nonlawyer, filed the petition without legal counsel and argued that, as the sole beneficiary, he should be allowed to proceed pro se or, alternatively, be given time to retain an attorney if one was required.The Iowa District Court for Polk County dismissed the lawsuit, ruling that the petition was a legal nullity because a nonlawyer cannot represent an estate or other parties in court, and denied the husband’s request for more time to secure counsel. The court also denied his motion to amend the petition. On appeal, the Iowa Court of Appeals affirmed the dismissal, agreeing that the wrongful-death action could not proceed without a lawyer and finding that the request for additional time had not been properly preserved for appeal. Two appellate judges dissented, concluding the husband was entitled to a warning and additional time to obtain counsel.The Supreme Court of Iowa granted further review. The court held that a nonlawyer cannot represent an estate or other persons in a wrongful-death action in district court. However, it found that the district court abused its discretion by not granting the husband reasonable time to retain counsel before dismissing the case. The Supreme Court vacated the court of appeals’ decision, reversed the district court’s judgment, and remanded the case with instructions to allow at least thirty days for the husband to secure trial counsel. View "Estate of Tornell v. Trinity Health Corporation" 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

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