Justia Iowa Supreme Court Opinion Summaries

A husband and wife applied for life insurance policies from Farm Bureau Life Insurance Company and later sued Farm Bureau for its alleged negligence in failing to notify them of their HIV-positive status. Farm Bureau settled the negligence claims, sued its insurers for indemnity, and sued its insurance broker for breach of contract and negligence in failing to provide timely notice to the insurers. The district court granted summary judgment (1) in favor of the insurers on the ground that Farm Bureau had failed to give them timely notice of the applicants' liability claims, and (2) in favor of the broker after concluding that even if the insurers had been given timely notice of the applicants' tort claims against Farm Bureau, coverage for those claims would have been precluded under two separate exclusions. In this appeal, Farm Bureau challenged the judgment in favor of the broker. The Supreme Court affirmed, holding that the underwriting exclusion would have precluded coverage for the applicants' claims even if the insurers had been timely notified under the policy's notice requirement. View "Farm Bureau Life Ins. Co. v. Holmes Murphy & Assocs., Inc." on Justia Law

Chartis Insurance issued two workers' compensation insurance policies to Action Warehouse Company. Action, in turn, contracted with two tire companies to provide employees to operate tire warehouses owned by the companies and used exclusively to store the goods manufactured by the respective employers. Originally, Chartis classified the Action employees who staffed the warehouses under the National Council on Compensation Insurance (NCCI) classification code applicable to general warehouse employees. Later, Chartis retroactively and prospectively changed the employees' classification code to the code applicable to rubber tire manufacturing, resulting in a significantly higher premium. Action appealed. The NCCI Iowa workers' compensation appeals board ruled in favor of Chartis. The Iowa Insurance Commissioner reversed, and the district court affirmed. At issue before the Supreme Court was whether the Commissioner had the authority under Iowa Code 515A.1 to consider an as-applied challenge to a workers' compensation liability insurance rating schedule approved for use in accordance with Iowa law. The Supreme Court reversed, holding that the Commissioner did not have the authority to determine that a specific application of a plan approved under Iowa Code 515A.4 violated the statute's general purpose as outlined in section 515A.1 by being excessive, inadequate, or unfairly discriminatory. View "Chartis Ins. v. Iowa Ins. Comm'r" on Justia Law

Plaintiff and Defendant were brother and sister. Defendant was a longtime resident of Maryland. Plaintiff allegedly lived in Iowa in 2003. After Plaintiff obtained employment in Iraq in 2003, he opened a checking account in Des Moines and provided Defendant with checks that could be used to draw on the account to provide for the needs of his children and to pay the bills. Instead of using the checks as agreed, Plaintiff claimed Defendant used the checks to withdraw funds for her personal use. Plaintiff filed a lawsuit against Defendant in Iowa district court for breach of contract, conversion, bad faith, fraud, and breach of fiduciary duty. The district court dismissed the complaint for lack of personal jurisdiction over Defendant, finding that sufficient minimum contacts were lacking. The Supreme Court reversed, holding that Defendant was subject to personal jurisdiction in Iowa under the Calder v. Jones foreseeable effects test based on the claim of an intentional tort in Iowa. Remanded. View "Shams v. Hassan" on Justia Law

Steven Sheeder and Barlett Grain Co. entered into oral agreements for the sale of grain. The parties later confirmed the agreement with a signed, written document containing an arbitration clause that was not part of the oral agreements. After Bartlett requested adequate assurance of performance and Sheeder did not provide such assurance, thus repudiating the contracts, Bartlett filed a complaint against Sheeder with the National Grain Feed Association (NGFA). Sheeder failed to sign an arbitration contract as required by NGFA arbitration rules, and NGFA entered a default judgment for Bartlett for breach of contract. Bartlett subsequently filed an application for confirmation of the arbitration award. The district court denied the application, concluding that there was no enforceable agreement between the parties to arbitrate. The Supreme Court reversed, holding (1) Bartlett and Sheeder entered into written agreements to arbitrate because the parties' oral agreements were modified by signed writings including agreements to arbitrate; and (2) the written agreements between Sheeder and Bartlett were not unconscionable. View "Barlett Grain Co. v. Sheeder" on Justia Law

Plaintiffs, farmers, purchased a Farm-Guard insurance policy from First Maxfield Mutual Insurance Association. Grinnell Mutual Reinsurance Company (Grinnell Mutual) reinsured the policy. Two years later, 535 of the hogs Plaintiffs were raising suffocated to death in Plaintiffs' building. Plaintiffs filed a claim with Grinnell Mutual to recover under the policy, but Grinnell Mutual denied the claim. Plaintiffs sued Grinnell Mutual for breach of contract. Both parties filed motions for summary judgment. The district court denied Grinnell Mutual's motion and granted Plaintiffs' motion based on the reasonable expectation doctrine. The court of appeals affirmed on alternative grounds, concluding the insurance policy was ambiguous and construing the ambiguity in favor of Plaintiffs. The Supreme Court reversed, holding (1) the policy was not ambiguous, and as a matter of law, the policy did not provide coverage; and (2) as a matter of law, the doctrine of reasonable expectations did not apply here. Remanded with instructions to enter judgment in favor of Grinnell Mutual. View "Boelman v. Grinnell Mut. Reinsurance Co." on Justia Law

This case involved a district court's denial of coverage under a fire insurance policy. A husband and wife had an insurance policy on their home. The policy included an intentional loss exclusion, voiding coverage when any insured intentionally causes a loss or damage. The district court denied coverage because the husband attempted suicide by pouring gasoline on himself and his home and lit himself on fire. The Supreme Court affirmed, holding (1) a coinsured who sets fire to the insured dwelling in order to commit suicide has the requisite intent to "cause a loss" under the policy; (2) under the language of the policy, the innocent coinsured spouse, who did not participate in the intentional acts of the other coinsured, cannot recover due to the intentional loss exclusion; and (3) the innocent coinsured cannot recover under the recently amended Iowa standard fire policy in Iowa Code 515.109. View "Postell v. Am. Family Ins. Co." on Justia Law

Plaintiffs purchased a home along the Cedar River. At the time, they were told, incorrectly, that the property was not in a special flood hazard area and that flood insurance would not be required as a condition of their loan. Plaintiffs received the same erroneous information when they refinanced their loan to pay for remodeling. Years later, their loan servicer was advised that the property actually was in a special flood hazard area. However, this information was not passed along to Plaintiffs until after their home had flooded and it was too late to buy flood insurance. Plaintiffs brought suit against the lender as well as the loan servicer. The district court granted summary judgment to Defendants. The Supreme Court (1) reversed in part, finding a claim could potentially exist based on Restatement (Second) of Torts, 551(2); and (2) affirmed the remainder of the district court's judgment. Remanded. View "Bagelmann v. First Nat'l Bank" on Justia Law

In this breach of contract case, the Supreme Court considered whether the district court erred in denying Defendant's motion for a new trial based on several rulings by the district court that Defendant claimed materially affected his rights and denied him a fair trial. The district court refused Defendant's request to exclude exhibits disclosed by Plaintiff the day before trial in violation of the district court's pretrial scheduling order. Additionally, the district court refused the request to declare a mistrial when Plaintiff testified to certain matters in violation of the district court's stipulated ruling on a motion in limine and denied Defendant's motion for a directed verdict. The court of appeals reversed and remanded for a new trial because it concluded the district court abused its discretion in admitting the exhibits into evidence. The Supreme Court vacated the court of appeals and affirmed the district court, holding that Defendant had not shown the district court committed any error in its decisions during the trial that substantially prejudiced Defendant's rights to a fair trial. Thus, Defendant was not entitled to a new trial. View "Fry v. Blauvelt " on Justia Law

At issue in this case was (1) whether a life insurance agent owes a duty of care to the intended beneficiary of a life insurance policy, and (2) whether a life insurance agent can be liable for negligent misrepresentation when he provides information to the insured and the intended beneficiary regarding the beneficiary designation listed on the life insurance policy. The district court granted summary judgment in favor of the agent. The court of appeals affirmed. The Supreme Court reversed, holding (1) a life insurance agent owes a duty of care to an intended beneficiary of a life insurance policy; (2) a life insurance agent can be liable for negligent misrepresentation; and (3) genuine issues of material fact existed in this case, and therefore, summary judgment should not have been granted. Remanded. View "Pitts v. Farm Bureau Life Ins. Co." on Justia Law

At issue in this appeal was whether to judicially invalidate an insurance contract requirement that the insured file her lawsuit for underinsured motorist coverage (UIM) within two years of her auto accident. Plaintiff argued the deadline was unenforceable because, although she was still experiencing pain two years after the accident, only later did she discover the full extent of her injuries and realize her claim exceeded the other driver's liability limits. Plaintiff filed this UIM action against her insurer (Defendant) nearly six years after the accident. The district court granted Defendant's motion for summary judgment enforcing the contractual deadline as reasonable. The court of appeals reversed, holding the two-year limitation period was unreasonable under the circumstances. The Supreme Court vacated the court of appeals and affirmed the district court, holding that the two-year UIM insurance policy deadline was enforceable as a matter of law because it matched the two-year statute of limitations in Iowa Code 614.1(2) for personal injury actions. View "Robinson v. Allied Prop. & Cas. Ins. Co." on Justia Law