Justia Iowa Supreme Court Opinion Summaries

Articles Posted in Contracts
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The Supreme Court reversed the district court's grant of summary judgment in favor of Plaintiff in this real estate dispute, holding that Plaintiff offered sufficient evidence to survive Defendants' motion for summary judgment.A few months after purchasing a home Plaintiff discovered water in the basement. Plaintiff later sued the sellers, her real estate agent, the seller's real estate agent, and a home inspector, alleging that they had misrepresented the condition of the house. The district court granted summary judgment for Defendants based on Plaintiff's failure to designate an expert on causation and damages. The court of appeals affirmed. The Supreme Court vacated the opinion of the court of appeals and reversed the summary judgment, holding that expert testimony was not required for Plaintiff to survive Defendants' motion for summary judgment on either causation or damages. View "Putman v. Walther" on Justia Law

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The Supreme Court affirmed the ruling of the district court that the contractual default interest rate applied in this dispute over the redemption of farmland and affirmed the court of appeals' decision requiring timely full payment of the amount necessary, holding that remand was required in this case.An attorney representing an investor underpaid the amount necessary to redeem farmland by at least $1,798 below the minimum owed. After concluding that the redemption was timely the district court resolved the parties' dispute over the interest rate by ruling that the contract default rate of twenty-one percent controlled, not the 4.25 percent nondefault rate. The court of appeals affirmed the twenty-one percent interest rate but concluded that the attempted redemption was untimely. The Supreme Court affirmed the judgment of the court of appeals and declined to grant equitable relief, holding that the court of appeals correctly held that the attempted redemption failed as untimely. View "Great Western Bank v. Clement" on Justia Law

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In this case arising from finance agreements related to the purchase from a third-party vendor of multimedia systems for Defendants' waiting rooms, the Supreme Court affirmed the rulings and judgments of the district court in favor of an Iowa corporation, holding that the district court did not err.NCMIC Finance Corporation and Defendants - hundreds of optometrists, dentists, and their professional associations - entered into finance agreements related to multimedia systems for their waiting rooms. After Defendants stopped making payments under the finance agreements, Defendants brought putative class actions seeking a declaration that the finance agreements were unenforceable. NCMIC then assigned its interests in the finance agreements to PSFS 3 Corporation, who, in turn, filed cases against Defendants seeking to enforce the terms of the finance agreements. The cases were consolidated, and the district court entered judgment for PSFS 3 and awarded damages. The Supreme Court affirmed, holding that there was no error or abuse of discretion. View "PSFS 3 Corp. v. Seidman" on Justia Law

Posted in: Contracts
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The Supreme Court affirmed the ruling of the district court against Defendant and in favor of Plaintiff finding breach of contract and breach of implied covenant of good faith and fair dealing, holding that the district court erred.Defendant, a managed care organization, entered into a contract with Plaintiff, a dentist, to deliver dental services to Medicaid participants as a member of Defendant's network. Defendant later sent Plaintiff a "notice of non-renewal" of the provider contract. Plaintiff sued, and the district court ruled that the provider contract did not allow Defendant to terminate Plaintiff through non-renewal of the provider contract. At issue was whether Defendant properly ended a provider contract that automatically renewed for successive one-year terms by sending a notice of non-renewal. The Supreme Court affirmed, holding that the district court correctly determined that Defendant possessed no right to terminate by non-renewal. View "Colwell v. MCNA Insurance Co." on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the district court concluding that Plaintiffs were not entitled to relief on their contract claim and that Defendant was entitled to a verdict on its counterclaim for breach of contract, holding that judgment was improperly granted on Defendant's counterclaim.Plaintiffs, the owners of a 1931 Chevy, brought this lawsuit against Defendant, a company in the business of restoration of antique vehicles, arguing that Defendant violated certain provisions of the Motor Vehicle Service Trade Practices Act (MVSTPA), Iowa Code chapter 537B and breached its contract with Plaintiffs. Defendant filed a counterclaim alleging breach of contract. The district court concluded that there were no violations of the MVSTPA, that Plaintiffs were not entitled to relief on their contract claim, and that Defendant was entitled to damages on its counterclaim. The Supreme Court reversed the judgment in favor of Defendant on the counterclaim, holding that Defendant violated several provisions of Iowa Code chapter 537B and therefore may not seek to enforce the terms of a contract that was unlawfully formed, but Plaintiffs did not establish actual damages arising from the alleged damages. View "Poller v. Okoboji Classic Cars, LLC" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals reversing in part the ruling of the district court that Plaintiff was the prevailing party entitled to fees, holding that when a plaintiff recovers less at trial than the amount of a rejected offer to confess judgment, Iowa Code 677.10.bars recovery of the plaintiff's attorney fees incurred after the offer.The parties litigated claims over the breach of a farm lease entitling the "prevailing party" to recover reasonable attorney fees. Plaintiff's presuit demand was $190,564, and Defendant made a pretrial offer to confess judgment for $75,000. Plaintiff rejected the offer. The case proceeded to trial, and the jury awarded Plaintiff just over $41,000. Both sides sought attorney fees, and the district court granted them to Plaintiff. The court of appeals reversed in part, holding that a plaintiff recovering less than the amount of the offer to confess cannot recover postoffer attorney attorney fees that are taxed as costs under Iowa Code 625.25. The Supreme Court affirmed, holding (1) prevailing party contractual fees are considered "costs" when determining the effect of an offer to confess judgment; and (2) Iowa Code sections 677.10 and 625.22 operated together to preclude recover of Plaintiff's attorney fees incurred after it rejected the offer to confess judgment. View "NCJC, Inc. v. WMG, L.C." on Justia Law

Posted in: Contracts
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The Supreme Court affirmed the judgment of the court of appeals reversing the order of the district court insofar as it modified the rent rates, duration, and for-profit subleasing rights in certain farm leases entered into by a ward's conservator, holding that the court of appeals did not err.After entering into written leases with members of Marvin Jorgensen's family members, Marvin's court-appointed conservator filed a motion seeking direction on whether the farm leases were appropriate. The district court concluded that the leases were inconsistent with Marvin's past practices and reformed them to provide a discount. The court of appeals reversed the ruling as to the reformation of the conservator's farm leases with Marvin's daughter. The Supreme Court affirmed, holding that the court correctly modified the rent rates, duration and for-profits subleasing rights in the daughter's leases. View "In re Guardianship & Conservatorship of Marvin M. Jorgensen" on Justia Law

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The Supreme Court affirmed the judgment of the district court dismissing Appellant's cause of action for unjust enrichment against the State, holding that the district court correctly dismissed the matter as an unlawful collateral attack on Appellant's criminal conviction.Appellant pleaded guilty to speeding in a construction zone. Appellant later filed a lawsuit challenging the authority of Iowa Department of Transportation (IDOT) officers to issue traffic citations and contesting the payments the State collected from fines resulting from convictions on unauthorized IDOT-issued citations. The district court held (1) the IDOT officers, at the time, lacked authority to stop Defendant's vehicle; and (2) Appellant's unjust enrichment claim was an improper collateral attack on his conviction, warranting dismissal. The Supreme Court affirmed, holding that the district court correctly concluded that Appellant's unjust enrichment claim was an improper collateral attack on his speeding ticket conviction. View "Rilea v. State" on Justia Law

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The Supreme Court affirmed the decision of the district court granting Defendants' motion for summary judgment and dismissing Plaintiff's claims for negligent misrepresentation, fraudulent misrepresentation, and breach of contract, holding that Plaintiff's claims were subject to the two-year statute of limitations set forth in Iowa Code 614.1(9) and were untimely.On Defendants' motion for summary judgment, the district court held that Plaintiff's causes of action arose out of patient care and were barred by section 614.1(9), the two-year statute of limitations governing malpractice action. The Supreme Court affirmed, holding that each of Plaintiff's allegations originated from representations regarding patient care and the patient care Defendants provided, and therefore, Plaintiff's claims were untimely under section 614.1(9). View "Kostoglanis v. Yates" on Justia Law

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The Supreme Court affirmed the ruling of the district court granting summary judgment in favor of a finance company in this contract dispute, holding that the contract was properly ratified despite any allegation of forgery.Natalya Rodionova Medical Care (NRMC) allegedly entered into a financing agreement with GreatAmerica Financial Services Corporation for the leasing of telephone and copier products. Pursuant to the agreement, NRMC made monthly payments totaling seven months worth of installments but then attempted to cancel the finance agreement. When NRMC discontinued further payments GreatAmerica sued for breach of contract and unjust enrichment. In its answer NRMC alleged that the finance agreement appeared to be signed by NRMC's sole shareholder but that the signature was a forgery. The district court granted summary judgment for GreatAmerica, reasoning that NRMC ratified the contract through its conduct regardless of who signed the contract. The Supreme Court affirmed, holding that NRMC's failure to reject goods over a seven-month period and its payment of periodic invoices amounted to a ratification. View "GreatAmerica Financial Services Corp. v. Natalya Rodionova Medical Care, P.C." on Justia Law

Posted in: Contracts