Justia Iowa Supreme Court Opinion Summaries

Articles Posted in Civil Procedure
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The case involves two attorneys, Jeffrey Peterzalek and Molly Weber, who sought to quash subpoenas for their depositions in a civil rights case brought by Charis Paulson against her employers, the State of Iowa and the Iowa Department of Public Safety (DPS). Paulson alleged gender-motivated discrimination and retaliation. Weber had represented DPS in its response to Paulson's civil rights complaint before the Iowa Civil Rights Commission (ICRC), while Peterzalek had represented DPS and its leaders in various other matters over the years. The district court declined to quash the subpoenas but ordered that the depositions be sealed. The attorneys then filed a petition for writ of certiorari with the Supreme Court of Iowa.The Supreme Court of Iowa granted the writ and retained the case. The attorneys argued that the court should adopt the Shelton test, which narrowly limits the circumstances in which opposing counsel may be deposed. They also argued that they should not be deposed or, alternatively, that substantial limitations should be imposed if their depositions were allowed.The Supreme Court of Iowa agreed with the attorneys' argument to adopt the Shelton test. Applying the test, the court concluded that Weber's deposition should be quashed as she was opposing counsel in the ongoing dispute and the information sought could be obtained by other means and was protected by the work-product doctrine. However, the court affirmed the district court's refusal to quash the subpoena for Peterzalek's deposition, as he was not opposing counsel in the ongoing dispute. The court remanded the case for further proceedings, including the entry of an order quashing the subpoena for Weber's deposition. View "Peterzalek v. Iowa District Court for Polk County" on Justia Law

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An elderly woman, Janice Geerdes, and her long-time friend, Albert Gomez Cruz, had a partnership raising hogs on a piece of land. Initially, Janice deeded half of her interest in the land to Albert. Over a decade later, she deeded the rest of her interest in the land to Albert, receiving nothing in return. About six months later, Janice’s adult daughters were appointed her conservator and guardian. The conservator challenged the validity of the quitclaim deed based on undue influence and lack of capacity.The district court set aside the deed, finding that there was undue influence through a confidential relationship and that Janice lacked the necessary capacity to deed her interest in the land. The court of appeals affirmed the decision on the basis of lack of capacity.The Supreme Court of Iowa, however, disagreed with the lower courts. The Supreme Court found that the conservator did not establish by clear, convincing, and satisfactory evidence that there was undue influence or that Janice lacked capacity at the time of the gift. The court found that the lower courts gave too much weight to the perceived improvidence of the transaction and too little weight to the testimony of the third-party accountant who witnessed the transaction. Therefore, the Supreme Court vacated the decision of the court of appeals, reversed the district court judgment, and remanded for further proceedings. View "Conservatorship of Janice Geerdes v. Cruz" on Justia Law

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Emilio Puente, a police officer for the City of Iowa City, resigned from his position and later attempted to rescind his resignation. When the City rejected his attempt, Puente filed an action with the Civil Service Commission of Iowa City (Commission) for review of the City’s refusal to reinstate him. The Commission dismissed Puente's complaint, agreeing with the City that it was untimely. Puente then filed a petition for judicial review in the Johnson County District Court, which was dismissed for lack of jurisdiction. The court concluded that Puente’s “petition for judicial review” was not a “notice of appeal” as required by Iowa Code § 400.27.The Iowa Court of Appeals affirmed the district court's decision. The court of appeals relied on the differences between a chapter 17A proceeding and an appeal under section 400.27 to conclude that the petition for judicial review could not be deemed a notice of appeal. The court of appeals noted that the two are initiated differently, have different venue provisions and service requirements, and have different standards and scopes of review.The Supreme Court of Iowa reversed the lower courts' decisions. The Supreme Court found that Puente had substantially complied with the requirements for filing a notice of appeal from the Commission’s decision to the district court. The court noted that Puente's petition sought "judicial review" of the Commission’s decision, identifying the Commission as a “respondent” rather than a “defendant.” The court concluded that Puente's reference to the wrong Code provision for venue did not mean he failed to substantially comply with the correct Code provision. The court vacated the decision of the court of appeals, reversed the district court judgment dismissing Puente’s appeal from the Commission’s decision, and remanded for further proceedings. View "Puente v. Civil Service Commission of Iowa City" on Justia Law

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A juvenile, K.C., was charged with two serious misdemeanors: carrying dangerous weapons and possession of marijuana. As K.C. was 17 at the time of the incident, the juvenile court had initial jurisdiction. However, after K.C. turned 18, the State filed a petition to waive the juvenile court's jurisdiction. In preparation for the waiver hearing, K.C. hired a forensic psychologist, Dr. Tracy Thomas, to conduct an evaluation. K.C. requested the State to cover Dr. Thomas's fees, which were estimated to be $7,990. The juvenile court initially authorized the fees but later set a limit of $4,590, deeming the full amount unreasonable. K.C. filed a motion for additional expert fees, which was denied by the juvenile court. K.C. then filed a petition for a writ of certiorari, arguing that the juvenile court acted illegally by not properly determining whether the requested expert fees were reasonable.The Supreme Court of Iowa agreed with K.C. that the juvenile court's order was not supported by substantial evidence. The court noted that three of the four reasons the juvenile court initially cited for deeming the full fee unreasonable were no longer relevant. The court also found that the juvenile court failed to provide any explanation for why it declined to increase the fee award or reconsider its denial. The Supreme Court of Iowa concluded that the juvenile court's reasoning was based on an erroneous application of law and thereby abused its discretion.The Supreme Court of Iowa sustained the writ of certiorari, vacated the juvenile court's orders denying K.C.'s requests for additional expert fees, and remanded the matter for entry of an order authorizing the full $7,791.20 in expert fees for Dr. Thomas's work. View "K.C. v. Iowa District Court for Polk County" on Justia Law

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The Supreme Court of Iowa reviewed a case involving a dispute between the University of Iowa and Modern Piping, Inc., a mechanical contractor. The dispute arose during the construction of the University of Iowa Stead Family Children’s Hospital. Modern Piping sought to arbitrate some delay disputes, but the University obtained a temporary injunction preventing arbitration. Modern Piping successfully had the injunction dissolved and sought to recover not only the fees and costs it incurred in doing so, but also restitution for the University's wrongful injunction.The district court initially granted the University an ex parte temporary injunction against Modern Piping, preventing arbitration of specific disputes. Modern Piping intervened and successfully had the injunction dissolved. The University appealed this decision but was unsuccessful. Meanwhile, the parties arbitrated the original disputes, resulting in the University paying Modern Piping over $16 million pursuant to the arbitration award.The Supreme Court of Iowa held that the restitution awarded to Modern Piping was not a proper remedy for a claim for wrongful injunction and could not stand. The court affirmed the $21,784.50 award to Modern Piping for fees and costs but reversed the $12,784,177.00 award for restitution. The court found that Modern Piping's claim for restitution was not directly correlated to the injunction, and therefore, it was not entitled to recover restitution in the form of a broad-reaching unjust enrichment claim. The case was remanded for entry of an order consistent with this directive. View "The University of Iowa v. Modern Piping, Inc." on Justia Law

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The case revolves around the Kirkwood Institute's request for public records from the Office of the Auditor of State in Iowa. The Institute sought emails between the Auditor's office and two investigative reporters. The Auditor's office withheld ten email chains, citing Iowa Code § 11.42 and § 22.7(18), which protect certain types of information. Kirkwood sued, arguing that the Auditor's office failed to show that these exceptions applied to the withheld emails. Additionally, Kirkwood claimed that the Auditor's office failed to disclose an eleventh email chain that had been quoted in a reporter's blog.The district court granted summary judgment in favor of the Auditor's office, holding that the ten email chains were exempt from production and that no violation occurred with the late turnover of the eleventh email chain. Kirkwood appealed this decision.The Supreme Court of Iowa affirmed in part, reversed in part, and remanded the case. The court found that there was a factual issue as to whether the delay in producing the eleventh email was reasonable. It also found that the district court erred in granting summary judgment on the Auditor's office's withholding of nine emails under § 11.42, as it was not immediately apparent that these emails were received in the course of an audit or examination. However, the court affirmed the district court's decision regarding the tenth email withheld under § 22.7(18), agreeing that it fell within the exception created in this statute. View "Kirkwood Institute, Inc. v. Sand" on Justia Law

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The case involves William and Mary Goche, LLC; Global Assets, LLC; and Joseph Goche (collectively “Goche”), who own land in three different drainage districts in Kossuth County. The Kossuth County Board of Supervisors administers these districts. Goche alleged that the board of supervisors administered the districts in a way that specifically caused him harm. He brought a suit against the board of supervisors, current and former supervisors, and engineering firm Bolton & Menk, Inc., asserting claims for breach of fiduciary duty and seeking punitive damages for the defendants’ alleged breaches.The defendants moved to dismiss the claims, arguing that they owed no fiduciary duty to Goche as an individual landowner within the drainage districts. The district court granted the motions, leading to Goche's appeal. However, in the appeal, Goche abandoned his breach of fiduciary duty claims and instead contended that he is entitled to proceed against the defendants on a standalone cause of action for punitive damages.The Supreme Court of Iowa disagreed with Goche's argument. The court clarified that punitive damages are a form of damages available to a plaintiff incidental to a recognized cause of action and not a freestanding cause of action. The court also noted that Goche conceded that the defendants owed him no fiduciary duty in the administration of the drainage districts or in providing engineering services to the districts. Therefore, the court affirmed the judgment of the district court, dismissing Goche's claims. View "William and Mary Goche, LLC v. Kossuth County Board of Supervisors in their capacity as Trustees of Drainage Districts 4, 18, and 80" on Justia Law

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The case involves Tracy White, an employee of the Iowa Department of Human Services (DHS), who filed a lawsuit against the State of Iowa and DHS under the Iowa Civil Rights Act (ICRA) alleging a hostile work environment. White's complaints about her supervisor led to his termination, but she remained employed at the agency. The jury awarded her $260,000 for past emotional distress and $530,000 for future emotional distress. The State appealed, arguing that the evidence was insufficient to prove White's hostile work environment claim, that the district court erred by admitting certain evidence and incorrectly instructing the jury, and that the future emotional distress damages were excessive.The district court had denied the State's pretrial motion to exclude certain evidence, referred to as "me too" evidence, as unduly prejudicial. This evidence consisted of reports of alleged discrimination experienced by other employees, which White, as a supervisor, had received and relied on to support her own hostile work environment claim. The State argued that such evidence, of which White was unaware, could not prove that she personally experienced a hostile work environment.The Supreme Court of Iowa agreed with the State, concluding that the harassment White personally experienced was not objectively severe or pervasive enough to alter the terms or conditions of her employment. The court held that the district court erred by denying the State's motion for judgment notwithstanding the verdict (JNOV). The court reversed the judgment for White and remanded the case for entry of an order granting the State's motion for JNOV. View "White v. State" on Justia Law

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In this case, the Iowa Supreme Court reviewed a dispute involving property owners David and Jeanie Vaudt and Wells Fargo Bank, which held the mortgage on neighboring property owned by Fredesvindo Enamorado Diaz and Denice Enamorado. The Vaudts had installed a landscaping barrier that encroached on the Enamorado's property. When the Enamorados disputed the boundary, the Vaudts filed a petition to quiet title, claiming boundary by acquiescence and adverse possession. Wells Fargo moved to dismiss the claims, arguing they were time-barred by a one-year statute of limitations related to property transfers by trustees. The district court agreed with Wells Fargo, citing a previous Iowa Supreme Court ruling (Heer v. Thola).The Vaudts appealed, asking the Supreme Court to overrule Heer. They argued their claims arose from the conduct of the Enamorados' predecessors in interest, not the transfer of property by the trustee's deed. The Supreme Court agreed with the Vaudts, stating that Heer incorrectly interpreted the statute of limitations, which applies specifically to claims arising from transfers by trustees, not to all adverse claims. The court overruled Heer, rejecting its broad application of the one-year statute of limitations to boundary-by-acquiescence claims.The court reversed the district court's dismissal of the Vaudts' claims, remanding the case for further proceedings. View "Vaudt v. Wells Fargo Bank, N.A." on Justia Law

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The Supreme Court of Iowa was asked to consider whether the Iowa Constitution supports a legislative privilege that protects legislators from compelled production of documents related to legislation. The court concluded that the Iowa Constitution does indeed contain a legislative privilege that protects legislators from compelled document production, particularly in relation to communications with third parties about the legislative process. The case arose from subpoenas served on several Iowa legislators by the League of Latin American Citizens of Iowa (LULAC). LULAC sought discovery of communications related to recent legislative changes to voting procedures. The legislators objected to the subpoenas, arguing they were protected from compelled document production by a legislative privilege under the Iowa Constitution. The court ruled that the privilege extends to communications with third parties where the communications relate directly to the legislative process of considering and enacting legislation. However, the court did not decide whether this legislative privilege was absolute or qualified, as it concluded that the requested documents were not relevant to LULAC's claims and were therefore protected by the legislative privilege, regardless of its extent. The court reversed the district court's judgment granting in part LULAC's motion to compel and remanded with instructions to quash the subpoenas. View "Smith v. Iowa District Court for Polk County" on Justia Law