Justia Iowa Supreme Court Opinion Summaries

In February 2014, Clint Shalla entered into a debt settlement agreement with Greg and Heather Koch to prevent a foreclosure on his farm. The Kochs agreed to purchase the farm and give Clint an exclusive option to repurchase it by August 15, 2015, with written notice and financing commitment. Clint's wife, Michelle, was not a party to the agreement but conveyed her marital interest in the property. Clint sought financing from Christopher Goerdt, then president of Peoples Trust and Savings Bank, who allegedly agreed to secure financing. Clint missed the option deadline, and the Kochs later agreed to sell the farm for a higher price. Goerdt, who had moved to County Bank, secured financing for the Shallas, but was later found to be involved in fraudulent activities.The Iowa District Court for Washington County granted partial summary judgment in favor of Peoples Bank, dismissing Michelle's fraudulent misrepresentation claim. The court later reconsidered and dismissed the Shallas' negligence and fraudulent misrepresentation claims, citing Iowa Code section 535.17. The court ruled in favor of County Bank in the foreclosure action and found Goerdt liable for conversion. The Shallas appealed, and the Iowa Court of Appeals affirmed the district court's judgment, with a dissent on the application of the statute of frauds.The Iowa Supreme Court reviewed the case and affirmed the lower courts' decisions. The court held that Iowa Code section 535.17, the credit agreement statute of frauds, barred the Shallas' claims for negligence and fraudulent misrepresentation. The court concluded that the statute applies to all actions related to unwritten credit agreements, regardless of whether the claims are framed in contract or tort. The case was remanded to the district court for a determination of County Bank's attorney fees, including appellate attorney fees. View "County Bank v. Shalla" on Justia Law

Barry and Jacklynn Graham hired Bradshaw Renovations, LLC to renovate their home. They agreed on a contract with an initial estimate of $136,168.16, which was later revised to $139,168.16. The contract included provisions for revising estimates and required written approval for changes. Throughout the project, Bradshaw sent invoices that varied from the initial estimate, leading to the Grahams' concerns about billing practices. After paying $140,098.79, the Grahams disputed a final invoice of $18,779.15, leading to a legal dispute.The Iowa District Court for Polk County held a jury trial, which found in favor of the Grahams on their breach of contract and consumer fraud claims, awarding them $16,000 and $40,000 respectively. The court denied Bradshaw's claims for unjust enrichment and quantum meruit. Bradshaw's motions for directed verdict and judgment notwithstanding the verdict were also denied. The court awarded attorney fees to the Grahams for their consumer fraud claim.The Iowa Court of Appeals affirmed the jury verdict, the district court's denial of Bradshaw's posttrial motions, and the dismissal of Bradshaw's equitable claims. It also affirmed the attorney fee award but remanded for determination of appellate attorney fees.The Iowa Supreme Court reviewed the case and found that the Grahams did not present substantial evidence of consumer fraud as defined by Iowa Code section 714H.3(1). The court reversed the district court's ruling on the consumer fraud claim and remanded for entry of judgment consistent with this opinion. The court affirmed the district court's dismissal of Bradshaw's unjust enrichment and quantum meruit claims, as these were covered by the written contract. The court also upheld the $16,000 jury award for the breach of contract claim. View "Bradshaw Renovations, LLC v. Graham" on Justia Law

John and Deena Dostart were awarded $182,408.30 in compensatory damages and $17,591.70 in exemplary damages by a jury for consumer fraud claims against their general contractor, Tyler Custom Homes, Ltd., and its owner, James Harmeyer. Columbia Insurance Group, which provided a commercial-general-liability (CGL) insurance policy to Tyler Custom Homes, declined to indemnify the judgment, arguing that consumer fraud is excluded from coverage under the CGL policy. Unable to collect directly from Tyler Custom Homes or Harmeyer, the Dostarts filed a suit seeking payment of the unsatisfied judgment from Columbia.The Iowa District Court for Polk County granted Columbia's motion for summary judgment regarding the exemplary damages but found that fact questions existed as to whether the consumer fraud was an "occurrence" under the CGL policy, whether the jury's award was for "property damage," and whether the intentional acts exclusion applied. The Iowa Court of Appeals affirmed the district court's decision, noting the lack of evidence about the underlying dispute beyond the verdict form and jury instructions.The Iowa Supreme Court reviewed the case and concluded that the consumer fraud involved in the underlying action is not a covered "occurrence" under the CGL policy and that the alleged harm does not include covered "property damage" as defined in the policy. The court vacated the decision of the Court of Appeals, reversed the district court's ruling, and remanded the case for entry of summary judgment in favor of Columbia. The court emphasized that defective workmanship or failure to complete construction does not constitute an "occurrence" under a CGL policy and that the damages sought were not for "property damage" as contemplated by the policy. View "Dostart v. Columbia Insurance Group" on Justia Law

Lance and Tracy Degeneffe entered into a roofing contract with Home Pride Contractors, Inc. to repair their roof, gutters, and siding after wind and hail damage. Home Pride completed the repairs and billed the Degeneffes, who refused to pay, leading Home Pride to hire an attorney to collect the debt. The Degeneffes sued Home Pride, alleging that its prior counsel engaged in harassing and abusive collection efforts in violation of the Iowa Consumer Credit Code (ICCC).The Iowa District Court for Boone County reviewed cross motions for summary judgment. Home Pride argued it was not subject to the ICCC as it did not extend credit or lend money to its customers. The Degeneffes argued that the roofing contract was a consumer credit sale subject to the ICCC and that Home Pride’s conduct was harassing and abusive under the ICCC. The district court denied Home Pride’s motion and granted the Degeneffes’ motion in part, establishing that the roofing contract constituted a consumer credit sale subject to the ICCC, but left the question of whether Home Pride’s conduct was harassing and abusive for trial.The Iowa Supreme Court reviewed the case to determine whether the roofing contract was a consumer credit sale subject to the ICCC. The court concluded that Home Pride did not grant credit to the Degeneffes, as the contract required full payment upon completion of the work, and the 1.5% monthly interest charge for late payment did not constitute an extension of credit. The court reversed the district court’s entry of partial summary judgment in favor of the Degeneffes and remanded the case for entry of summary judgment in favor of Home Pride. View "Degeneffe, v. Home Pride Contractors, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court denying Exile Brewing Company's attempt to intervene in the underlying probate matter and striking Exile's motion to vacate, dismiss, and close two estates seeking to pursue certain claims, holding that the probate court did not err in denying the request to intervene and close the estates.During the 1950s and '60s, Ruth Bisignano owned and operated a popular bar in Des Moines. In 2012, Exile named one of its craft beers "Ruthie" and used Ruth's image. Ruthie died in 1993, and her estate was closed that year. Her husband Frank Bisignano died three years later, and his estate was closed in 1999. In 2020, Plaintiff successfully filed petitions to reopen both estates. Subsequently, as administrator of Frank's estate, Plaintiff sued Exile alleging common law appropriation and other claims. Exile filed a motion to vacate, dismiss, and close both estates, arguing that the probate court lacked statutory jurisdiction to reopen the estates. The probate court denied the motion, concluding that Exile had no right to intervene in the probate proceedings. The Supreme Court affirmed, holding that the probate court correctly determined that Exile was an interloper with no ability to challenge the estates' reopening. View "In re Estate of Bisignano" on Justia Law

The Supreme Court affirmed the order of the trial court on interlocutory appeal denying Defendants' remand for a jury in this argument over the requirement that civil enforcement actions brought by the attorney general "shall be by equitable proceedings," holding that the requirement was enforceable and did not violate the jury right preserved by Iowa Const. art. I, 9.The attorney general commenced this action alleging that Defendants had violated the Iowa Consumer Fraud Act (CFA), Iowa Code 714.16, and the Older Iowans Act (OIA), Iowa Code 714.16A, by engaging in false and deceptive conduct and unfair practices in the "sale and advertisement of stem cell and exosome therapy in Iowa." Defendants answered and demanded a jury, but the attorney general moved to strike the jury demand because subsection 714.16(7) requires that civil actions "shall be by equitable proceedings." The district court granted the motion to strike, and Defendants applied for interlocutory review. The Supreme Court affirmed, holding that the district court did not err in striking Defendants' jury demand. View "State ex rel., Attorney General" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing Plaintiff’s two-count petition, holding that the district court erred in holding that a seller of auction services of certain machinery is entitled to summary judgment on a claim brought by a buyer of those services under the Door-to-Door Sales Act (DDSA), Iowa Code chapter 555A.Plaintiff brought this action claiming a violation of the DDSA and seeking a declaratory judgment challenging the underlying sales contract because of an invalid execution by a third party and because of fraud in the inducement. The district court granted summary judgment in favor of Defendant, concluding, among other things, that the DDSA does not apply to a contract for auction services, such as the contract in this case. The Supreme Court reversed, holding (1) Defendant was not entitled to summary judgment on the DDSA claim where Defendant presented no evidence that Plaintiff’s purpose in purchasing the auction services was not “primarily for personal, family, or household purposes”; and (2) because the declaratory judgment count had allegations beyond the DDSA the district court erred in dismissing this count of the petition. View "Morris v. Steffes Group, Inc." on Justia Law

Plaintiffs filed a class action alleging that the fees Defendant charged for providing copies of their medical records and billing statements were excessive in violation of Iowa Code 622.10(6). Defendant filed a motion to dismiss for failure to state a claim, alleging that section 622.10(6) did not apply to it because it was not a provider under the statute. The district court denied the motion to dismiss. The Supreme Court affirmed, holding (1) an entity that acts as a provider’s agent in fulfilling records requests covered by section 622.10(6) cannot charge more for producing the requested records than the provider itself could legally charge; and (2) the well-pleaded facts in the petition indicated that Defendant acted as an agent of the providers by fulfilling the records requests on their behalf, and therefore, the district court was correct in denying Defendant’s motion to dismiss Plaintiffs’ petition. View "Young v. Healthport Technologies, Inc." on Justia Law

Plaintiffs filed a class action alleging that the fees Defendant charged for providing copies of their medical records and billing statements were excessive in violation of Iowa Code 622.10(6). Defendant filed a motion to dismiss for failure to state a claim, alleging that section 622.10(6) did not apply to it because it was not a provider under the statute. The district court denied the motion to dismiss. The Supreme Court affirmed, holding (1) an entity that acts as a provider’s agent in fulfilling records requests covered by section 622.10(6) cannot charge more for producing the requested records than the provider itself could legally charge; and (2) the well-pleaded facts in the petition indicated that Defendant acted as an agent of the providers by fulfilling the records requests on their behalf, and therefore, the district court was correct in denying Defendant’s motion to dismiss Plaintiffs’ petition. View "Young v. Healthport Technologies, Inc." on Justia Law

Plaintiffs, former customers of West Bank, filed a multiple-count proposed consumer class action lawsuit against the Bank challenging one-time nonsufficient funds fees the Bank charged when Plaintiffs used their debit cards to create overdrafts in their checking account. Plaintiffs alleged usury claims and sequencing claims. The district court denied the Bank’s motions for summary judgment on the usury and sequencing claims but granted summary judgment on the Bank’s motion for summary judgment on Plaintiffs’ usury claim arising under the Iowa Ongoing Criminal Conduct Act. In a companion case issued today, the Supreme Court concluded that the district court erred in denying the Bank’s motions for summary judgment except as to the good-faith claim involving the sequencing of overdrafts. Likewise, the Court here found that the district court also erred in certifying the class action on all claims except for Plaintiffs' good-faith sequencing claim. View "Legg v. West Bank" on Justia Law