Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed the district court's summary judgment in favor of Defendants on Plaintiffs' claim that the 2017 amendments to Iowa Code chapter 20, the Public Employment Relations Act (PERA), violate the equal protection clause of the Iowa Constitution, holding that the 2017 amendments withstood the constitutional challenges.The 2017 amendments resulted in new classifications that made many public employees lose significant statutory bargaining rights compared to other public employees with ostensibly similar jobs. Two unions representing public school employees filed this action seeking injunctive and declaratory relief against the State, the Iowa Public Employment Relations Board (PERB), and three PERB board members, alleging that the amendments violated the equal protection clause of the Iowa Constitution. The district court dismissed the action on summary judgment. The Supreme Court affirmed, holding that the legislative classifications are not so overinclusive or underinclusive as to be unconstitutional under this Court's rational basis test. View "Iowa State Education Ass'n v. State, Iowa Public Employment Relations Board" on Justia Law

The Supreme Court affirmed the ruling of the district court denying Jane Doe's motion to expunge her record, holding that the condition in Iowa Code 901C.2, the expungement statute, that an individual pay all court-imposed costs and fees does not violate the Equal Protection Clauses of the United States or Iowa Constitutions.Section 901C.2 creates a statutory right to expungement subject to several conditions. Doe was an indigent defendant who was denied expungement for failure to pay off her court-appointed attorney fees. On appeal, Defendant argued that the condition that she pay her court-appointed attorney fees violated her equal protection rights. The district court denied Doe's constitutional challenge and denied her motion to expunge her record. The Supreme Court affirmed, holding that the requirement to pay court costs, including court-appointed attorney fees, is rationally related to the government interest in collecting court debt. View "State v. Doe" on Justia Law

The Supreme Court affirmed Defendant's conviction but vacated the portion of Defendant's sentence regarding restitution, holding that remand was required because the district court did not have the benefit of the procedures outlined in State v. Albright, __ N.W.2d __ (Iowa 2019).The court of appeals affirmed Defendant's conviction, holding that Defendant's counsel was not ineffective for failing to challenge the sufficiency of the evidence. The court further found that the district court did not err in assessing restitution for appellate attorney fees. The Supreme Court granted further review and affirmed Defendant's conviction, letting the court of appeals decision stand as this Court's final decision regarding Defendant's ineffective assistance of counsel claims. As to Defendant's argument that the district court erred in ordering him to pay restitution in the form of appellate attorney fees without first determining his reasonable ability to pay those fees, the Court held that the restitution part of Defendant's sentence regarding those fees should be vacated and the case remanded to the district court to impose restitution consistent with this Court's decision in Albright. View "State v. Dieckmann" on Justia Law

The Supreme Court affirmed the judgment of the district court holding that sex offender registration requirements are not punitive and convicting Defendant of failing to report his Internet identifier for a Facebook account he was using under an assumed name, holding that the Internet identifier reporting requirement withstands challenge under the First Amendment and article I, section 7 of the Iowa Constitution.Defendant pleaded guilty to lascivious acts with a child and was placed on the sex offender registry pursuant to Iowa Code chapter 692A. The legislature's 2009 amendment to that statute added the requirement that the offender disclose his Internet identifiers. Defendant was later charged with failing to report his Internet identifier. Defendant argued that the statute, as applied, violated the Free Speech and Ex Post Facto Clauses in the state and federal constitutions. The district court rejected Defendant's constitutional challenges. The Supreme Court affirmed, holding that the Internet identifier reporting requirement of Iowa Code chapter 692A.104(1) is narrowly tailored to serve a significant governmental interest. View "State v. Aschbrenner" on Justia Law

The Supreme Court affirmed the evidentiary ruling of the district court and grant of summary judgment in favor of Medical School on Student's complaint that Medical School failed to accommodate her mental disability under the Iowa Civil Rights Act, Iowa Code chapter 216, holding that the district court properly declined to impute a staff psychotherapist's knowledge of Student's depression to Medical School's academic decision-makers and that the failure-to-accommodate claim failed as a matter of law.Student was treated for depression by the psychotherapist during the school year but did not consent to allow the psychotherpiast to discuss her depression with the faculty. Medical School eventually expelled Student based on her failing grades and lack of academic promise. In this complaint, Student filed an evidentiary motion to impute her psychotherapist's knowledge of her depression to the school's academic decision-makers. The district court denied the motion after applying statutory confidentiality requirements for mental health information. The court then granted Medical School summary judgment on Student's failure-to-accommodate claim. The Supreme Court affirmed, holding (1) the district court correctly ruled that confidential information the psychotherapist learned while treating Student was not imputed to Medical School; and (2) Medical School adequately engaged in the interactive process. View "Slaughter v. Des Moines University College of Osteopathic Medicine" on Justia Law

The Supreme Court affirmed Defendant’s convictions but vacated certain portions of Defendant’s sentences, holding that the imposition of a surcharge violated the Ex Post Facto Clauses of the state and federal constitutions and that the district court erroneously ordered restitution without determining Defendant’s reasonable ability to pay.Defendant pled guilty to lascivious acts with a child and sexual exploitation of a minor. On appeal, Defendant argued that the district court failed to comply with Iowa R. Crim. P. 2.8(2)(b) in accepting his guilty pleas, did not adequately inquire into an alleged communication breakdown in the attorney-client relationship, violated the Ex Post Facto Clauses by imposing a surcharge, and erred in ordering restitution without first determining his reasonable ability to pay. The Supreme Court held (1) Defendant did not preserve error on his guilty pleas challenge; (2) the record on appeal was insufficient to conduct an ineffective assistance of counsel analysis and to determine whether the district court adequately inquired into the alleged communication breakdown; and (3) the surcharge and restitution were erroneously imposed. View "State v. Petty" on Justia Law

The Supreme Court affirmed Defendant’s convictions for willful injury causing bodily injury and kidnapping in the first degree but vacated the restitution portion of the sentencing order and remanded the case to the district court to order restitution in a manner consistent with this opinion, holding that the restitution order did not comply with restitution law.Specifically, the Court held (1) substantial evidence supported Defendant’s conviction for first-degree kidnapping; (2) Defendant was not prejudiced when the court instructed the jury on a lesser included charge of kidnapping in the second degree; (3) this Court cannot reach Defendant’s ineffective assistance of counsel claims; and (4) the lower court’s finding that Defendant had the reasonable ability to pay and ordering restitution for certain items without having the amount of each item of restitution before it was contrary to the statutory scheme as outlined in this opinion. View "State v. Albright" on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that challenged portions of Iowa Administrative Code rule 441-78.1(4) violate the Iowa Civil Rights Act (ICRA) and determining that the Iowa Department of Human Services’ (DHS) denial of Medicaid coverage for gender-affirming surgeries was reversible, holding that the rule violates the ICRA’s prohibition against gender-identity discrimination.At issue was the language of rule 441-78.1(4) pertaining to the exclusion of Iowa Medicaid coverage of surgical procedures related to “gender identity disorders” violated the ICRA or the Iowa Constitution’s equal protection clause. The district court concluded that the challenged portions of the rule violated both the ICRA and the Constitution and that the DHS’s denial of Medicaid coverage for gender-affirming surgeries would result in a disproportionate negative impact on private rights and that the decision was unreasonable, arbitrary, and capricious. The Supreme Court affirmed, holding (1) rule 441-78.1(4)’s exclusion of Medicaid coverage for gender-affirming surgery violates the ICRA as amended by the legislature in 2007; and (2) under the doctrine of constitutional avoidance the Court did not address the constitutional claim. View "Good v. Iowa Department of Human Services" on Justia Law

The Supreme Court affirmed the judgment of the district court vacating an award of fees incurred during agency proceedings under a fee-shifting provision in Division II of the Davenport Civil Rights Ordinance for a housing discrimination violation charged under Division III that lacked a corresponding fee-shifting remedy, holding that that the district court correctly denied an award of attorney fees.A tenant filed a complaint with the Davenport Civil Rights Commission alleging discrimination based on familial status in violation of the Davenport Civil Rights Ordinance and the Federal Fair Housing Act (FHA). An administrative law judge found that the landlord committed a Division III fair housing violation and award the tenant both damages and attorney fees and costs. The Commission approved the ALJ’s decision. The district court reversed the damages award and vacated the fee award. The court of appeals reinstated the fee award. The Supreme Court held that the court of appeals erred in awarding attorney fees because (1) the fee-shifting provision in Division II of the Ordinance was inapplicable to the fair housing violation in Division III; and (2) the Commission could not award fees under the FHA. View "Seeberger v. Davenport Civil Rights Commission" on Justia Law

The Supreme Court affirmed Defendant’s conviction of operating while intoxicated (OUI), second offense, holding that Defendant’s rights under Iowa Code 804.20 were not violated when a law enforcement officer denied Defendant’s request to call his wife until after sobriety testing occurred.Defendant was driving a motor vehicle when he was involved in an accident in the midst of a snowstorm. Because of the weather conditions, the law enforcement officer that responded to the scene transported Defendant to a protected location - the sally port of the nearby law enforcement center - for the completion of field sobriety testing. Before leaving the scene, Defendant asked to talk to his wife, but the request was denied. Defendant subsequently failed field sobriety tests. Defendant was later convicted of OUI. Defendant appealed, arguing that his rights were violated because he had been “restrained of his liberty” within the meaning of section 804.20 at the sally port. The Supreme Court affirmed, holding that Defendant’s rights under section 804.20 were not violated when the officer refused to allow Defendant the opportunity to speak with his wife until after field sobriety testing had been completed at the sally port because the sally port was a location for testing, not a “place of detention” within the meaning of section 804.20. View "State v. Davis" on Justia Law