Justia Iowa Supreme Court Opinion Summaries

Articles Posted in Contracts
by
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

by
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

by
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

by
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
by
The Supreme Court affirmed the district court's judgment dismissing this case on the pleadings, except for slander of title, holding that slander of title was adequately alleged.Debtor brought this case against Bank, alleging breach of contract, breach of the implied duties of good faith and fair dealing, fraud, and slander of title. The district court granted Bank's motion to dismiss, ruling that the contract and fraud claims were time-barred, rejecting Debtor's discovery rule and equitable estoppel arguments, and concluding that the slander of title claim failed to allege publication to a third party. The court of appeals reversed and reinstated all claims. The Supreme Court vacated the decision of the court of appeals in part and affirmed the district court's judgment except as to the slander of title claim, holding (1) the contract, good faith, and fraud claims were time-barred, and the equitable estoppel argument failed as a matter of law; and (2) the slander of title claim was adequately alleged. View "Benskin, Inc. v. West Bank" on Justia Law

Posted in: Banking, Contracts
by
The Supreme Court affirmed the ruling of the district court entering judgment for Defendant, holding that Plaintiff's present challenge to the judgment was already conclusively resolved in his prior appeal.While the jury was deliberating, the parties agreed with limit their risks with a deal that put caps on what Plaintiff would receive and what Defendant would pay. The jury returned a verdict for Defendant. The district court dismissed the case consistent with the verdict. The Supreme Court affirmed the district court's order that entered judgment for Defendant. Thereafter, Defendant refused to pay the amount agreed upon, and so Plaintiff filed a motion to enforce the agreement. The district court denied Plaintiff's motion to enforce the agreement. Plaintiff appealed. The Supreme Court affirmed, holding that Plaintiff made no attack on the judgment that couldn't have been raised in the prior appeal. View "Freer v. DAC, Inc." on Justia Law

Posted in: Contracts
by
The Supreme Court affirmed the ruling of the district court dismissing an employee's gross negligence claim against a coemployee, holding that settlement documents submitted to and approved by the workers' compensation commissioner extinguished the employee's gross negligence claim.Plaintiff, an employee of Lutheran Services in Iowa (LSI) was attacked by one of LSI's clients, causing injuries. Plaintiff filed a workers' compensation claim against LSI and its workers' compensation carrier. The parties settled, and the two settlement documents were approved by the Iowa Workers' Compensation Commissioner. Plaintiff subsequently filed a petition in district court seeking to recover damages from Defendant, Plaintiff's supervisor when he worked at LSI, on a theory of gross negligence. Defendant moved to dismiss the action, relying on release language in the settlement documents. The district court granted summary judgment for Defendant on both contract and statutory grounds. The court of appeals reversed, concluding that a settlement with the commissioner did not release a common law claim of gross negligence against a coemployee. The Supreme Court vacated the court of appeals' judgment and affirmed the district court's summary judgment, holding that the district court properly ruled that, as a matter of contract, the language in the terms of settlement extinguished Plaintiff's gross negligence claim. View "Terry v. Dorothy" on Justia Law

by
The Supreme Court affirmed the judgment of the district court dismissing Plaintiff's claims for violations of a municipal civil rights ordinance and the Iowa Civil Rights Act (ICRA) and breach of contract, holding that the ICRA does not contain authorization for a municipality to enact law that would be binding between two private parties in state court.Plaintiff claimed that he was discriminated against in his education on the basis of age and disability. The district court dismissed all of Plaintiff's claims, concluding that it had no jurisdiction over the local ordinance claims, that the ICRA claims were barred because they were based on the same conduct, and that Plaintiff did not have a viable breach of contract claim. The Supreme Court affirmed, holding (1) the general assembly did not confer jurisdiction on Iowa state courts to hear claims by private parties arising under municipal civil rights ordinances; and (2) the district court did not err in its resolution of Plaintiff's ICRA and breach of contract claims. View "Petro v. Palmer College of Chiropractic" on Justia Law

by
In this case brought by a tenant against her landlord and a neighboring tenant alleging breach of the lease's no-pets provision the Supreme Court reversed the judgment of the district court dismissing the case, holding that the landlord's accommodation of an emotional support dog was not reasonable.Plaintiff moved into an apartment building because of its no-pets policy. Afterwards, another tenant requested a reasonable accommodation to have his emotion support animal (ESA), a dog, with him on the apartment premises. The landlord allowed the ESA and tried to accommodate the two tenants, but Plaintiff still suffered from allergic attacks. Plaintiff sued, alleging breach of the lease and interference with the quiet enjoyment of her apartment. The landlord asserted in its defense that its waiver of the no-pets policy was a reasonable accommodation that it was required to grant under the Iowa Civil Rights Act (ICRA). The small claims court concluded that the landlord's accommodations were reasonable. The district court dismissed the case. The Supreme Court reversed and remanded the case, holding (1) the landlord's accommodation of the ESA was not reasonable because Plaintiff had priority in time and the dog's presence posed a direct threat to her health; and (2) Plaintiff was entitled to recover on her claims. View "Cohen v. Clark" on Justia Law

by
The Supreme Court reversed the judgment of the district court ruling that Plaintiffs' claim seeking contract damages was barred by the limitations period set forth in Iowa Code 614.17A, holding that the district court erred in granting summary judgment.John and Dessie Rottinghaus filed a claim in the Estate of Sandra Franken, alleging that the Estate sold certain real estate in violation of their right of first refusal to purchase the real estate. The executor disallowed the claim and moved for summary judgment, claiming that section 614.17A barred the Rottinghauses' claim. The district court granted the motion for summary judgment, concluding that the statute of limitations precluded the Rottinghauses' claim for damages. The Supreme Court reversed, holding (1) section 614.17A applies only to actions seeking to recover or establish an interest in or claim to real estate filed against the holder of the record title; and (2) neither the merger doctrine, the statute of frauds, the indirect effect of section 614.17A, nor the statute of limitations in section 614.1(5) barred the Rottinghauses' damages action. View "In re Estate of Franken" on Justia Law