Justia Iowa Supreme Court Opinion Summaries

Jim Book, the owner of an auto repair shop in Iowa, bought from an Iowa retailer four Treadstone tires manufactured in China by Doublestar Dongfeng Tyre Company, Ltd. Jim’s son, Dylan Book, was airing up one of the tires when it exploded, causing severe and permanent injuries. Dylan, through his mother, filed a products-liability action in Iowa seeking recovery from Doublestar and Voma Tire Corporation, a national tire distributor that sold several of Doublestar’s tires. Doublestar moved to dismiss for lack of personal jurisdiction. The district court granted the motion. The Supreme Court reversed, holding that the Federal Constitution permits the exercise of personal jurisdiction over a high-volume, foreign manufacturer, such as Doublestar, whose allegedly dangerous product purchased in Iowa injured a resident here. View "Book v. Voma Tire Corp." on Justia Law

An Iowa plaintiff sued a nonresident corporation (Defendant) for unfair competition and civil conspiracy. Defendant filed a motion to dismiss for lack of personal jurisdiction. The district court denied the motion, concluding that general jurisdiction was established because Defendant’s passive website held Defendant out as having a manufacturing facility in Sioux Center, Iowa. In fact, the Sioux Center facility was owned and operated by a separate Iowa defendant that supplied the product to Defendant. The Supreme Court affirmed the order denying Defendant’s motion to dismiss but on an alternative ground, holding (1) the district court erred by exercising general jurisdiction over Defendant based solely on the inaccurate statement on Defendant’s website, as there was no proof that Defendant was “essentially at home” in Iowa to establish general jurisdiction; but (2) the totality of Defendant’s contacts with Iowa were sufficient to subject it to specific jurisdiction on claims related to those contacts. View "Sioux Pharm, Inc. v. Summit Nutritionals Int’l, Inc." on Justia Law

Plaintiff worked as a service dog trainer but was not disabled. Plaintiff filed a lawsuit against Drake University Law School, where she was a student, alleging that Drake barred her from bringing with her a dog she was training into the classroom and to another event in violation of Iowa Code 216C.11(2). The district court granted Drake’s motion to dismiss after applying the four-factor test adopted from Cort v. Ash for determining whether an Iowa statute provides an implied private right of action, concluding that section 216C.11(2) creates no private enforcement action. The Supreme Court affirmed the judgment of the district court, holding that, under an application of the Cort factors, section 216C.11(2) does not provide a service dog trainer with a private right to sue. View "Shumate v. Drake Univ." on Justia Law