Justia Iowa Supreme Court Opinion Summaries

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

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 Bank filed three motions for summary judgment asking the district court to dismiss all of Plaintiffs’ usury 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. The Bank filed this interlocutory appeal on the district court’s denial of its motions for summary judgment. The Supreme Court affirmed in part and reversed in part, holding that the district court erred in denying the Bank’s motions for summary judgment except as to Plaintiffs’ claim based on a potential breach of the express duty of good faith in the sequencing of postings of bank card transactions. Remanded. View "Legg v. West Bank" on Justia Law

Patron won 185 credits, or $1.85, while playing a penny slot machine at a Casino. However, at the same time, a message appeared on the screen stating, “Bonus Award - $41797550.16.” The Casino refused to pay the alleged bonus, claiming that the slot machine game malfunctioned, and therefore, the bonus award displayed on the screen was not valid. The Patron filed suit against the Casino, asserting breach of contract, estoppel, and consumer fraud. The district court granted summary judgment to the Casino on all three counts. The Supreme Court affirmed, holding (1) the rules of the game formed a contract between the Patron and the Casino, and the Patron was not entitled to the bonus under those rules; (2) the Patron failed to prove the necessary elements of either promissory or equitable estoppel; and (3) the Patron failed to present proof of an ascertainable loss sufficient to warrant recovery on her consumer fraud claim. View "McKee v. Isle of Capri Casinos, Inc." on Justia Law

The Attorney General brought an action against Corporation, which sold memberships in buying programs giving members the option to purchase various goods and services at discounted rates, alleging violations of the Buying Club Membership Law (BCL) and the Iowa Consumer Fraud Act (CFA) and seeking civil penalties for consumer frauds committed against the elderly. The district court concluded (1) many of Corporation's marketing and sales practices violated the BCL and CFA; (2) Corporation did not commit consumer frauds against the elderly; and (3) application of the BCL to Corporation's solicitation practices did not violate the dormant Commerce Clause. The court awarded more than $25 million in consumer reimbursement, civil penalties, and attorney fees. The Supreme Court affirmed in part, reversed in part, and modified, holding (1) Corporation's telemarketing and Internet practices violated the CFA; (2) Corporation's solicitations and its memberships offering one or more discount features were subject to the terms of the BCL; (3) application of the BCL to Corporation's solicitations did not violate the dormant Commerce Clause; (4) affirmed the reimbursement award for BCL violations as modified; and (5) reversed the ruling that the State was not entitled to civil penalties for consumer frauds committed by the elderly.View "State ex rel. Miller v. Vertrue, Inc." on Justia Law