Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed the district court's grant of summary judgment for an insurer on the grounds that the plaintiff's contractual assignment was unenforceable, holding that a residential contractor acting as an unlicensed public adjuster cannot enforce its postloss contractual assignment of insurance benefits against the homeowner's insurer.Iowa Code 103A.71(5) declares void contracts entered into by residential contractors who perform public adjuster services without the license required under Iowa Code 522C.4. The contractor in this case represented homeowners as an assignee of their insurance claim for hail damage to their home. The district court concluded that the contractor's contractual assignment was invalid under section 103A.71(5) because the contractor acted as an unlicensed public adjuster. The Supreme Court affirmed, holding that the district court did not err in ruling that the contractor acted as an unlicensed public adjuster and that the assignment contract was unenforceable and void under Iowa law. View "33 Carpenters Construction, Inc. v. State Farm Fire & Casualty Co." on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the district court's grant of summary judgment in favor of Cincinnati Insurance Company in this insurance dispute, holding that, for the reasons set forth in 33 Carpenters Construction, Inc. v. State Farm Life & Casualty Co., __ N.W.2d __ (Iowa 2020), an assignment contract entered into by a residential contractor acting as an unlicensed public adjuster is void under Iowa Code 103A.71(5).After a hailstorm and windstorm damaged Gregg Whigham's residence, Whigham and 33 Carpenters Construction, Inc. entered into an agreement under which 33 Carpenters would repair the damage in exchange for Wigham's insurance proceeds. A 33 Carpenters representative and Whigham then signed an assignment of claim and benefits. Later, 33 Carpenters sued Whigham's insurer, Cincinnati, claiming that Cincinnati breached the insurance policy by failing to by 33 Carpenters all benefits due and owing under the policy that had been assigned to it. The district court granted summary judgment to Cincinnati, concluding that the purported assignment of Whigham's insurance claim was invalid. The Supreme Court affirmed, holding that because 33 Carpenters was operating as an unlicensed public adjuster, the assignment contract was unenforceable. View "33 Carpenters Construction, Inc. v. Cincinnati Insurance Co." on Justia Law

In this breach of contract action involving the repurchase of all of a limited liability company's (LLC) member's membership interests, the Supreme Court reversed in part the district court's determination that the LLC was entitled to specific performance under the parties' agreement and granting the LLC's request for attorney fees, holding that the award of attorney fees was in error.The LLC member and the LLC executed an agreement whereby the LLC would buy back all of the member's membership interests. Five days later, the member attempted to revoke his offer to sell his interests. The LLC filed a breach of contract claim seeking specific performance as well as attorney fees under the contract. The district court held that the member had breached the agreement, ordered specific performance under the agreement, and granted the LLC's request for attorney fees. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) correctly determined that the contract was a valid and binding agreement and that the LLC was entitled to specific performance as the remedy for the member's breach of the agreement; but (2) erred in awarding attorney fees. View "Homeland Energy Solutions, LLC v. Retterath" on Justia Law

The Supreme Court affirmed the order of the district court dismissing this action presenting the question of what must be shown to avoid the effects of a contractual forum-selection clause, holding that fraud in general is not sufficient and must relate specifically to the forum-selection clause itself.This case involved an alleged scheme to inflate the purchase price of a general aviation jet aircraft. Plaintiffs argued that Defendants fraudulently misrepresented the acquisition price of the aircraft and failed to disclose the true acquisition price. Defendants filed a motion to dismiss, asserting, in part, improper venue based on the forum-selection clause in the purchase agreement. The district court dismissed the case without prejudice based on improper venue. The Supreme Court affirmed, holding that because Plaintiffs did not allege fraud with respect to the forum-selection clause in the written contract, Plaintiffs' general allegations of fraud in the inducement were insufficient to avoid enforcement of the forum-selection clause of the purchase agreement. View "Karon v. Elliott Aviation" on Justia Law

The Supreme Court affirmed in part and vacated in part the decision of the court of appeals affirming the judgment of the district court modifying a judgment for civil conspiracy following a jury trial, holding that the district court did not abuse its discretion in granting the motion to amend the judgment.Jeffrey Anderson commenced an action against Dean and Carol Anderson and Anderson Tooling, Inc. (ATI) alleging, among other claims, tortious discharge. Dean, Carol, and ATI filed several counterclaims. ATI sued Lori and brought a claim against Lori and Fabrication & Construction Services Inc. (FabCon) for, among other claims, conspiracy. Damages against Jeff totaled $772,297.72. The district court subsequently granted ATI's motion to modify the judgment to make Lori and FabCon jointly and severally liable for the $772,297.72 judgment. As relevant to this appeal, the court of appeals reversed the district court's order imposing joint and several liability on Lori and FabCon, determining that a conspiracy did not exist for Lori and FabCon to join. The Supreme Court vacated the court of appeals's judgment in part, holding that the district court did not abuse its discretion in granting the motion to amend the judgment. View "Anderson v. Anderson Tooling, Inc." on Justia Law

The Supreme Court affirmed the district court's grant of summary judgment dismissing this action filed by a public employee union seeking to enforce a collective bargaining agreement entered into with the Iowa Board of Regents, holding that the Public Employment Relations Board (PERB) acted within its statutory authority in promulgating Iowa Admin. Code R. 621-6.5(3), which has the force of law, and that the district court correctly applied rule 621-6.5(3) to hold the parties had no enforceable collective bargaining agreement (CBA) without the Board's vote to ratify it.The Board moved for summary judgment on the union's action to enforce the CBA, relying on rule 621-6.5, which requires the Board to meet to vote to accept a tentative voluntary agreement ratified by the union before the contract becomes effective. The union argued that the agency rule was invalid because it imposed a ratification requirement not included in Iowa Code 20.17(4). The district court upheld the validity of the agency rule and dismissed the union's enforcement action. The Supreme Court affirmed, holding (1) rule 621-6.5(3) is valid; and (2) therefore, no enforceable agreement was reached without the requisite vote by the Board to approve the CBA. View "Service Employees International Union, Local 199 v. State" 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

The Supreme Court affirmed in part and reversed in part the judgment of the district court dismissing Plaintiff’s unjust enrichment, quantum meruit, and promissory estoppel claims, holding that the district court erred in granting Defendants’ motion for summary judgment on the promissory estoppel claim.Plaintiff, a farmer, sued Defendants, his neighbor’s heirs, claiming that he and the decedent entered into an option contract to purchase farmland that Plaintiff leased from he decedent and upon which Plaintiff had made substantial improvements. After the farm was sold, Plaintiff brought this action claiming that Defendants breached an option contract to sell him the property. Alternatively, Plaintiff alleged various equitable theories of promissory estoppel, quantum meruit, and unjust enrichment. A jury found in favor of Plaintiff on his contract claim, but the district court granted Defendants’ motion for directed verdict and refused to order a new trial on Plaintiff’s alternative equitable theories. The court of appeals remanded the case for further proceedings on the equitable claims. On remand, the district court granted Defendants’ motion for summary judgment on the remaining equitable claims. The Supreme Court reversed in part, holding that Plaintiff’s promissory estoppel claim survived summary judgment. View "Kunde v. Estate of Arthur D. Bowman" on Justia Law

Retaliatory discharge claims are not categorically reserved for at-will employees.A state administrative law judge (ALJ) brought suit alleging wrongful termination in violation of public policy after she was terminated for giving unfavorable testimony about the director of her division to the Iowa Senate Government Oversight Committee. The ALJ’s employment was covered by a collective bargaining agreement (CBA). The State filed a motion to dismiss, asserting that the common law claim of wrongful discharge is reserved for at-will employees. The district court agreed and dismissed the case. The court of appeals reversed, concluding that the ALJ’s status as a CBA-covered employee did not preclude her wrongful-discharge claim. The Supreme Court affirmed, holding that the common law tort of retaliatory discharge against public policy is generally available to contract employees. View "Ackerman v. State" on Justia Law

Retaliatory discharge claims are not categorically reserved for at-will employees.A state administrative law judge (ALJ) brought suit alleging wrongful termination in violation of public policy after she was terminated for giving unfavorable testimony about the director of her division to the Iowa Senate Government Oversight Committee. The ALJ’s employment was covered by a collective bargaining agreement (CBA). The State filed a motion to dismiss, asserting that the common law claim of wrongful discharge is reserved for at-will employees. The district court agreed and dismissed the case. The court of appeals reversed, concluding that the ALJ’s status as a CBA-covered employee did not preclude her wrongful-discharge claim. The Supreme Court affirmed, holding that the common law tort of retaliatory discharge against public policy is generally available to contract employees. View "Ackerman v. State" on Justia Law