Justia Iowa Supreme Court Opinion Summaries

Plaintiff, an agricultural supply company, was delivering its own products in a semi-trailer when the semi-trailer wrecked and spilled fertilizers and chemicals, contaminating several hundred cubic yards of soil. Plaintiff suffered a loss of almost $1 million due to the environmental remediation and for the value of the trailer and its contents. Plaintiff had been leasing the semi-tractor and its driver from another source at the time of the accident. Plaintiff, on behalf of itself and its insurer, filed suit against the lessors and their driver, alleging negligence and breach of contract. The district court granted summary judgment in favor of Defendants, concluding that the terms of the lease and Iowa Code 325B.1 barred any recovery by Plaintiff. The Supreme Court reversed, holding (1) section 325B.1 governs relations between authorized motor carriers and shippers and does not apply to the lease in this dispute because Plaintiff is a private carrier rather than a motor carrier; (2) the indemnification provisions in the lease are valid and enforceable; and (3) the anti-subrogation rule limits potential recovery in this case. View "United Suppliers, Inc. v. Hanson" on Justia Law

The Regional Utility Service Systems Commission (RUSS) brought a breach of contract action against the City of Mount Union. The district court entered judgment in favor of RUSS. The clerk of court subsequently issued a writ of general execution commanding the county sheriff to levy on all bank accounts held by the City at Iowa State Bank in Mount Union. The City filed a motion to quash the garnishment on the grounds that the bank account was exempt from execution under Iowa Code 627.18. The district court denied the motion to quash and claim of exemption. The Supreme Court reversed, holding that the bank account was exempt under section 627.18 because the general funds in the account were “necessary and proper for carrying out the general purpose” for which the City was organized. View "Reg’l Util. Serv. Sys. v. City of Mount Union" on Justia Law

A fire severely damaged a restaurant that was owned by Plaintiffs. Plaintiffs made a claim to Defendant, the insurer of the restaurant, but Defendant denied the majority of the claim. Plaintiffs filed a breach-of-contract action against Defendant to recover under the insurance policy. A jury returned a verdict for Plaintiffs in the amount of $236,902. Defendant paid this amount plus interest and costs. Three months after judgment was entered, Plaintiffs filed this action against Defendant for “bad faith,” alleging that Defendant lacked an objectively reasonable basis for denying the claim. The district court granted Defendant’s motion for summary judgment, finding that the bad-faith action was barred by claim preclusion. The court of appeals reversed. The Supreme Court vacated the judgment of the court of appeals and affirmed the district court’s grant of summary judgment to Defendant, holding that, under the circumstances of this case, the final judgment in the breach-of-contract suit barred the later tort action for bad faith. View "Villarreal v. United Fire & Cas. Co." 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 Iowa Department of Economic Development (IDED) and Ghost Player, LLC executed a contract for tax credits under which Ghost Player believed it would receive certain tax credits for a documentary film it produced. CH Investors, LLC was a third-party beneficiary to the contract. The IDED declined to issue the contracted tax credit for some of the investments and expenditures of Ghost Player. Ghost Player and CH Investors subsequently filed a breach of contract action against the IDED. The district court dismissed the action on the grounds that Ghost Player failed to exhaust its remedies under the Iowa Administrative Procedure Act. The Supreme Court affirmed, holding that the district court (1) was without authority to hear the case because the IDED actions in this case required Ghost Player to exhaust its administrative remedies prior to filing a case in district court; and (2) correctly found the process used by the IDED in processing the claim did not offend due process principles under the State or the Federal Constitutions. View "Ghost Player, LLC v. State" on Justia Law

This case involved three small school districts, Northeast Community School District, East Central Community School District, and Preston Community School District. In 2010, the school boards of Northeast and East Central entered into a whole grade sharing agreement. Thereafter, citizens from Preston and East Central voted to reorganize their districts and merge the districts together into a new school district called Easton Valley Community School District (Easton). The Easton school board subsequently sent a notification of cancellation of the agreement to the superintendent of Northeast, claiming that when East Central ceased to exist the agreement was null. Northeast filed a petition for declaratory action and mandamus and then amended its petition alleging repudiation of the agreement. The district court granted summary judgment for Easton, concluding (1) the agreement and the reorganization were valid but that the two were in direct conflict, and (2) the East Central school board did not have the ability to bind Easton as its successor corporation. The Supreme Court reversed, holding that the agreement could bind the reorganized school district. View "Northeast Cmty. Sch. Dist. v. Easton Valley Cmty. Sch. Dist." on Justia Law

Plaintiff, a limited liability company, contracted with Defendant, a utility bill review consultant. After Defendant reviewed four utility bills and informed Plaintiff it was entitled to a substantial refund for sales tax overpayments, Plaintiff terminated the contract. Plaintiff filed a petition for declaratory judgment requesting a determination that it had no remaining contractual obligation to Defendant. Defendant counterclaimed for breach of contract. The district court granted summary judgment for Plaintiff, concluding that Plaintiff’s liability under the contract was limited to services Defendant provided prior to termination, and no payment was owed to Defendant until Plaintiff actually received a refund. The Supreme Court reversed, holding that Defendant had a viable claim for breach of contract. Remanded. View "Shelby County Cookers, LLC v. Utility Consultants Int’l, Inc." on Justia Law

Tenant leased certain property from Landlord. Landlord filed a petition for a declaratory judgment seeking a ruling that it could have reasonable access to the property to show it to prospective buyers. The district court found the lease to be unambiguous and granted summary judgment to Tenant, concluding that Tenant could exclude Landlord from showing the property until ninety days remained in the term of the lease. The Supreme Court reversed the judgment of the district court, holding that lease provisions that gave Landlord the right to sell the property at any time during the lease term encompassed the right to access the property temporarily at reasonable times to show the property to prospective buyers. View "Alta Vista Props., LLC vs. Mauer Vision Ctr., PC" on Justia Law

In 1991, Husband and Wife were married in Florida. Later that year, the couple signed a postnuptial agreement expressly providing that Florida law would apply. The agreement contained a provision stating that Wife waived all claims against Husband’s estate upon his death, including her elective share. In 2005, the couple moved to Iowa. After Husband died in 2012, Wife claimed her spousal elective share under Iowa law. The agreement was enforceable under Florida law, but Wife argued that the agreement could not be enforced in Iowa because it would violate Iowa’s public policy against postnuptial agreements waiving a spouse’s elective share. The district court denied relief based on the choice of law provision in the agreement. The Supreme Court affirmed, holding that Florida law applied to the enforceability of Wife’s waiver of her spousal elective share contained in the agreement. View "Hussemann v. Hussemann " on Justia Law

John Corrado and his company (collectively, Corrado) and Life Investors Insurance Company of America (LICA) entered into a settlement agreement following a dispute. The agreement purported to bear Corrado's signature, but Corrado challenged the signatures' validity. The U.S. district court granted summary judgment to LICA, concluding that Corrado ratified the parties' contract. The U.S. court of appeals reversed. On remand, the district court found the settlement agreement authenticated. The Iowa Supreme Court answered a certified question of law by holding that if a party receives a copy of an executed contract with that party's signature thereon, even where it is not known who applied the party's signature to the contract or whether the signature was authorized, and the party does not challenge the signature or otherwise object to the contract and accepts benefits and obligations under the contract for at least six years, then the party has ratified the contract and is therefore bound by its terms. View "Life Investors Ins. Co. of Am. v. Estate of Corrado" on Justia Law