Justia Iowa Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of kidnapping in the first degree, among other charges. Defendant was a juvenile at the time of the kidnapping. The district court sentenced Defendant to life imprisonment without the possibility of parole for the kidnapping conviction. After the U.S. Supreme Court decided Graham v. Florida, Defendant filed a motion to correct an illegal sentence on the kidnapping conviction, contending that his sentence violated the Eighth Amendment of the U.S. Constitution. The district court agreed that the sentence was unconstitutional and corrected Defendant’s conviction to life in prison with immediate parole eligibility. Defendant appealed, claiming, inter alia, that his sentence was unconstitutional under both the U.S. and the Iowa Constitutions. The court of appeals affirmed Defendant’s conviction and sentence as corrected. The Supreme Court conditionally affirmed, holding that Defendant’s sentence was constitutional under the U.S. Constitution. Because Defendant’s claims that his sentence was illegal under the Iowa Constitution were not fully developed, the Court did not reach those claims. Remanded. View "State v. Hoeck" on Justia Law

Dentist fired his long-time female dental assistant (Employee) at the request of his wife after she discovered Dentist and Employee had been texting. Wife claimed Employee "was a big threat" to the marriage. Employee subsequently brought this action against Dentist, alleging that he discriminated against her on the basis of sex. The district court granted summary judgment for Dentist, concluding that Employee was not fired because of her gender but because she was a threat to Dentist's marriage. The Supreme Court affirmed, holding that Dentist did not engage in unlawful gender discrimination in violation of the Iowa Civil Rights Act when he fired Employee at the request of his wife.View "Nelson v. Knight" on Justia Law

Defendant pleaded guilty to attempted murder and was sentenced to twenty-five years in prison. Defendant appealed, claiming his counsel provided ineffective assistance because counsel permitted him to plead guilty without an established factual basis for each element of the crime. The court of appeals vacated Defendant's conviction and sentence and remanded the case, concluding that the guilty plea colloquy failed to establish a factual basis for the underlying charge. The Supreme Court vacated the court of appeals' decision and affirmed the conviction and sentence of the district court, holding that the minutes of testimony provided an adequate factual basis to support Defendant's guilty plea. View "State v. Finney" on Justia Law

Plaintiff was a construction supply business that entered into a dispute with City over a project upgrading City's wastewater treatment facility. After City excluded Plaintiff from its list of preapproved material suppliers, Plaintiff filed this action seeking a declaration that City's preapproval process violated Iowa's public construction bidding statute and constitutional guarantees of equal protection and due process. In addition, Plaintiff sought relief under the Open Records Act, claiming that City's significant delay in responding to Plaintiff's open records request violated the Open Records Act. The district court rejected each of Plaintiff's claims. The Supreme Court (1) affirmed the judgment dismissing Plaintiff's public biding and constitutional claims, as (i) Plaintiff lacked standing to challenge City's preapproval process, and (ii) Plaintiff's constitutional claims failed on the merits; and (2) reversed the district court's ruling denying Plaintiff relief under the open records law, as City's substantial and inadequately explained delay in responding to Plaintiff's open records request violated the law. View "Horsfield Materials, Inc. v. City of Dyersville" on Justia Law

In an underlying termination of parental rights proceeding, the juvenile court concluded that while Mother, who was indigent, did not qualify for appointed counsel under Iowa Code 600A.6A, payment of the attorney’s fees at public expense was constitutionally required. The court subsequently appointed an attorney to represent Mother in the proceeding, and ultimately, Mother’s parental rights were terminated. The juvenile court ordered the State Public Defender to pay for the court-appointed counsel, but the Defender denied payment on the ground that the fees did not qualify for payment from the indigent defense fund. The appointed attorney sought judicial review, and the juvenile court subsequently ordered the Iowa Department of Management to pay the fees. The Defender and Department appealed the juvenile court’s appointment of counsel at public expense. The Supreme Court treated the appeal as a petition for an original writ of certiorari, which it granted as to the Department. The Court then annulled the writ, concluding that the juvenile court correctly appointed counsel at public expense to represent Mother in the contested termination proceeding under chapter 600A. View "Crowell v. State Pub. Defender" on Justia Law

Defendant was charged with and convicted of operating a motor vehicle while under the influence. Defendant appealed, contending that the district court erred in denying his motion to suppress the evidence obtained from the stop of his vehicle after the police received an anonymous tip reporting a drunk driver. The Supreme Court reversed and suppressed all evidence seized from the stop, holding that the investigatory stop of Defendant was illegal under the Fourth Amendment, as a bare assertion by an anonymous tipster reporting drunk driving, without relaying to the police a personal observation of erratic driving or other facts to establish the driver is intoxicated, does not provide reasonable suspicion to stop a vehicle. Remanded for a new trial. View "State v. Kooima" on Justia Law

Plaintiff formed a contract with Imperial Premium Finance with regard to a financing arrangement for life insurance. Imperial later assigned its interest in the arrangement to Defendant, a limited partnership with its principal place of business in California. Plaintiff filed a petition for declaratory judgment in Iowa, claiming that the contract was not valid. The district court granted Defendant’s motion to dismiss for lack of personal jurisdiction, concluding that that contacts of Imperial, the assignor, did not impute to Defendant, the assignee. The Supreme Court reversed, holding (1) an assignor’s contacts with Iowa are not automatically imputed to the assignee for purposes of obtaining personal jurisdiction over the assignee, but this assignee is subject to personal jurisdiction in Iowa based on its own contacts with this forum through the contractual relationships it assumed by the assignment; and (2) Defendant in this case did have the required minimum contacts to subject Defendant to personal jurisdiction in Iowa. Remanded. View "Ostrem v. PrideCo Secure Loan Fund, LP" on Justia Law

Plaintiffs were employees of limited liability corporations located in Iowa. Plaintiffs filed lawsuits against the businesses and certain individuals affiliated with the businesses, alleging that Defendants violated the Iowa Civil Rights Act (ICRA) by engaging in sexual harassment, sex discrimination, and retaliation. The lawsuits demanded punitive damages. Defendants moved to strike the claim for punitive damages. The district court granted the motion, concluding that punitive damages were not available under the ICRA. Plaintiffs sought, and the Supreme Court granted, interlocutory appeal. The Court then affirmed the district court, holding that an award of punitive damages is not permitted under the ICRA.View "Ackelson v. Manley Toy Direct, LLC" on Justia Law

After a jury trial, Defendant was convicted of escape. Defendant appealed, arguing, among other things, that the district court abused its discretion when it refused to instruct the jury that the crime of absence from custody was a lesser included offense of escape. The court of appeals denied each claim raised by Defendant and affirmed. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the district court, holding that the crime of absence from custody is a lesser included offense of the crime of escape. Remanded for a new trial. View "State v. Miller" on Justia Law

The Iowa Department of Natural Resources (DNR) revoked Plaintiffs' hunting licenses after finding that each Plaintiff did not meet the criteria to claim resident status under Iowa Code chapter 483A and that establishing residency solely for the purposes of hunting was improper under section 483A.1A(10). In each case, an administrative law judge affirmed the DNR's decision. The district court affirmed the agency action, concluding (1) to be considered a landowner for the purposes of obtaining landowner hunting privileges, a person must be a resident of Iowa, and (2) the ALJ's findings that Plaintiffs were not Iowa residents were supported by substantial evidence, notwithstanding the facts and each owned land in Iowa and paid taxes in Iowa. The Supreme Court affirmed, holding (1) the decisions of the ALJs in Plaintiffs' respective cases were supported by substantial evidence; and (2) Iowa's licensing scheme, which distinguishes between resident landowners and nonresident landowners, is not an unconstitutional impairment of privileges protected by the Privileges and Immunities Clause. View "Democko v. Iowa Dep't of Nat. Res." on Justia Law