Justia Iowa Supreme Court Opinion Summaries

Aaron Cannon, a student at Palmer College of Chiropractic, was blind and requested that Palmer make accommodations for his visual disability. Palmer denied the request, explaining that it could not provide the proposed accommodations and curricular modifications because they would fundamentally alter its educational program. Cannon eventually withdrew from the program. Cannon filed a complaint with the Davenport Civil Rights Commission, arguing that Palmer had discriminated against him on the basis of his disability. The Commission granted relief, finding that Palmer had failed to comply with the applicable federal and state disability laws. The district court reversed. The Supreme Court reversed, holding that the Commission did not erroneously interpret or irrationally apply the applicable law in concluding that Palmer failed to establish that Cannon’s suggested accommodations would fundamentally alter its curriculum. View "Palmer College of Chiropractic v. Davenport Civil Rights Comm’n" on Justia Law

John Goodpaster worked as a customer service manager for Schwan’s Home Service, Inc., the largest home delivery frozen foods company in the nation, at Schwan’s Des Moines location. Goodpaster’s duty was to sell and deliver company products, and a basic requirement of Goodpaster’s job was that he drive a commercial vehicle. When Goodpaster began experiencing medical problems, his sales began to decrease, and he was eventually terminated. Goodpaster sued Schwan’s under the Iowa Civil Rights Act (ICRA) for disability discrimination and retaliation, claiming his employment was terminated because he had multiple sclerosis. The district court granted summary judgment in favor of Schwan’s. The Supreme Court reversed, holding (1) multiple sclerosis is a disability contemplated by the ICRA; and (2) a genuine issue of material fact existed regarding whether Goodpaster was qualified to perform the essential functions of his position. Remanded. View "Goodpaster v. Schwan’s Home Serv., Inc." on Justia Law

Defendant was charged with and pled guilty to criminal transmission of HIV in violation of Iowa Code 709C.1. The district court accepted the plea, sentenced Defendant to twenty-five years suspended and placed Defendant on probation for five years. Defendant subsequently filed an application for postconviction relief, claiming that his trial counsel provided ineffective assistance for allowing him to plead guilty, by failing to challenge the factual basis of the plea, and failing to complete a proper investigation before the plea hearing. The district court denied the application, and the court of appeals affirmed. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the trial court, holding that the guilty plea record did not contain a factual basis to support the plea, and the court in this case could not use the rule of judicial notice to establish the factual basis in the guilty plea record. Remanded. View "Rhoades v. State" on Justia Law

After a jury trial, Defendant was convicted of third-degree sexual abuse. Six years later, the Supreme Court overturned Defendant's conviction and sentence and remanded for a new trial. The second trial resulted in Defendant's acquittal. Defendant subsequently filed an application to be declared a wrongfully imprisoned individual pursuant to Iowa Code 663A.1. The district court granted the application. The State appealed. The Supreme Court reversed and remanded, holding (1) Defendant was eligible to bring a wrongful imprisonment claim when he was acquitted on retrial; (2) the district court erred by failing to consider testimony that had been presented at Defendant's two criminal trials in making the wrongful imprisonment determination, even though the State did not show the witnesses were no longer available; and (3) while substantial evidence supported the district court's finding of innocence on the existing record, a remand was necessary for the court to consider the full record, including the prior testimony.View "State v. DeSimone" on Justia Law

The Iowa Supreme Court Attorney Disciplinary Board filed a complaint against Attorney Doe based on sexual misconduct allegations by the attorney's client, Jane Doe. The Grievance Commission of the Iowa Supreme Court scheduled a hearing on the matter. Jane's attorney requested a continuance of the scheduled hearing so that she could be present when Jane testified before the Commission. The Commission President quashed Jane's attorney's appearance and denied her request for a continuance, stating that witnesses testifying before the Commission were not entitled to have an attorney present during the proceedings and that that absence of Jane's attorney from the hearing would cause no unfairness to Jane. The Supreme Court reversed the Commission's order, holding that a person called upon to be a witness before the Commission may be represented by counsel for the limited purpose of protecting rights personal to the witness in the proceeding.View "Iowa Supreme Court Attorney Disciplinary Bd. v. Attorney Doe No. 762" on Justia Law

Defendant was convicted of operating while intoxicated, second offense. Defendant appealed the district court’s denial of his motion to suppress the breath-test result obtained after his arrest, arguing that he had been denied his statutory right to an independent chemical test. The court of appeals reversed, concluding that the district court erred in denying Defendant’s motion to suppress. The Supreme Court affirmed, holding (1) Defendant’s statutory right to an independent chemical test was violated when he made statements that could be reasonably construed as a request for an independent test under Iowa Code 321J.11 but law enforcement denied his request, and (2) the error was not harmless. Remanded for a new trial. View "State v. Lukins" on Justia Law

Defendant was charged with and found guilty of driving under revocation. Defendant appealed, arguing that the district court’s admission of a certified abstract of his driving record and affidavits of the mailing of suspension notices violated his rights under the Confrontation Clauses of the United States and Iowa Constitutions. The court of appeals concluded that the admission of the disputed documents did not violate the Confrontation Clauses. The Supreme Court affirmed, holding (1) the admission of the certified abstract of Defendant’s driving record did not violate the Confrontation Clauses; and (2) the admission of the affidavits of the mailing of suspension notices violated the Confrontation Clauses, but their admission into evidence was harmless error. View "State v. Kennedy" on Justia Law

Police officers stopped Defendant’s vehicle after discovering that the vehicle’s license plate frame covered up the county name on the license plate, which the officers believed violated Iowa Code 321.37(3). As a result of the stop, Defendant was charged with possession with intent to deliver crack cocaine, a drug tax stamp violation, and driving under suspension. A district court judge denied Defendant’s motion to suppress, concluding that the license plate frame violation gave no reason to stop Defendant but that the stop was lawful based on a reasonable suspicion of drug dealing. A different judge who presided at trial upheld the stop based on the license plate violation alone. After a jury trial, Defendant was found guilty as charged. The court of appeals affirmed, which held that the traffic stop was lawful based on reasonable suspicion of drug dealing without deciding the license plate issue. The Supreme Court affirmed the conviction without reaching the issue of whether the traffic stop was lawful based on reasonable suspicion of drug dealing, holding that a license plate frame that covers up the county name violates Iowa Code 321.37(3) and provides a valid basis for a traffic stop. View "State v. Harrison" on Justia Law

After a jury trial, Defendant was convicted of voluntary manslaughter and five counts of intimidation with a dangerous weapon with intent. The Supreme Court vacated Defendant’s convictions on three counts of intimidation with a dangerous weapon with intent and affirmed his remaining convictions, holding (1) trial counsel was ineffective for failing to move for a judgment of acquittal after the verdict on the intimidation counts because the evidence did not support the verdicts that Defendant committed five separate and distinct acts of intimidation with a dangerous weapon with intent; (2) however, substantial evidence supported two separate and distinct crimes of intimidation with a dangerous weapon with intent; (3) the record was inadequate to decide Defendant’s separate allegation of ineffective assistance of counsel; and (4) the district court did not abuse its discretion in failing to admit certain photographs into evidence. Remanded. View "State v. Ross" on Justia Law

Plaintiff was terminated from his employment as dean of students and vice president of student services at the University of Iowa by the University's president, Sally Mason, after a report from the Stolar Partnership (Stolar), a law firm retained by the Board of Regents (Regents) to investigate the University's response to a sexual assault of a student athlete by other student athletes, came out highly critical of Plaintiff. Plaintiff sued the University, Mason, the Regents, and Stolar for wrongful termination and related causes of action. The district court granted summary judgment for Defendants on all claims. The Supreme Court affirmed, holding that the district court did not err (1) in denying Plaintiff's motion to compel discovery of written communications between Stolar and the Regents based on its finding that the attorney-client privilege protected the communications from disclosure; and (2) in granting summary judgment to Defendants on Plaintiff's various claims.View "Jones v. Univ. of Iowa" on Justia Law