Justia Iowa Supreme Court Opinion Summaries

Sally Splittgerber suffered a fall while walking on a city sidewalk, leading to a personal injury lawsuit against the owner of the adjacent property, the lessee of that property (Bankers Trust), and the City of Des Moines. The plaintiffs alleged that these parties were negligent in maintaining the uneven sidewalk. After settling the claims, Bankers Trust sought contribution from the City for the settlement payment, arguing that the City, not the property owner or lessee, was responsible for maintaining the sidewalk.The district court, relying on the precedent set in Madden v. City of Iowa City, granted summary judgment in favor of the City. The court held that the City could impose liability on abutting landowners for damages resulting from other types of failures to maintain sidewalks, beyond just snow and ice removal. Bankers Trust appealed this decision, asking the Supreme Court of Iowa to overrule the Madden decision.The Supreme Court of Iowa agreed with Bankers Trust, stating that the Madden decision was wrongly decided. The court found that the City's attempt to shift costs and liability to abutting landowners for sidewalk maintenance and accidents beyond what the state statute allows was in direct conflict with the legislature's express determination about where such burdens reside. The court noted that the statute only permits cities to require abutting landowners to repair sidewalks if the city first notifies the landowners by certified mail that a repair is necessary, and only permits cities to hold abutting landowners liable for damages if they fail to remove snow and ice from the sidewalk.The court overruled the Madden decision, reversed the district court's summary judgment ruling, and remanded the case for further proceedings consistent with this opinion. View "Bankers Trust Company v. City Of Des Moines" on Justia Law

The plaintiff, Ron Myers, suffered a leg injury after slipping on a diving board at a city pool in Cedar Falls, Iowa. He sued the City of Cedar Falls, alleging that the diving board lacked a slip-resistant surface required by state regulations. The City moved for summary judgment, arguing that it was immune from liability under Iowa Code section 670.4(1)(l), which grants immunity to operators of municipal swimming pools unless there is a "knowing" violation of regulations. The district court granted the City's motion, concluding that Myers failed to establish a "knowing" violation of the regulations.Myers appealed the decision, and the case was transferred to the court of appeals. The court of appeals reversed the district court's decision, finding that there were factual questions about the condition of the diving board that precluded summary judgment. The City then sought further review from the Supreme Court of Iowa.The Supreme Court of Iowa accepted the City's invitation to overrule a previous decision, Sanon v. City of Pella, which had interpreted the "criminal offense" exception to immunity for operators of municipal swimming pools under Iowa Code section 670.4(1)(l) to include violations of agency regulations. The court found that Sanon was "egregiously wrong" and had caused ongoing problems. The court held that the legislature did not make violating swimming pool regulations a criminal offense, and therefore, the City was immune from liability under Iowa Code section 670.4(1)(l). The court vacated the decision of the court of appeals and affirmed the district court's summary judgment. View "Myers v. City of Cedar Falls" on Justia Law

In this case, a private citizen, Robert Teig, appealed a summary judgment granted to city officials in his lawsuit alleging violations of the Iowa Open Records Act. Teig had requested job applications and other documents related to the City of Cedar Rapids' hiring processes for a new city clerk and city attorney. The City refused many of Teig's requests, citing attorney-client privilege and the Act's confidentiality provisions as reasons for withholding several documents.The district court granted the City's motion for summary judgment, leading to Teig's appeal. He argued that job applications submitted to governmental bodies are not confidential under chapter 22, municipalities cannot claim attorney-client privilege in the context of an open records request, search and retrieval fees are not authorized by chapter 22, the defendants unreasonably delayed fulfilling certain requests, and the district court should have granted him leave to submit additional interrogatories in the ensuing litigation.The Supreme Court of Iowa affirmed in part and reversed in part the district court's decision. The court held that documents subject to attorney-client privilege are protected from disclosure under chapter 22 and that chapter 22 authorizes municipalities or governmental bodies to charge search and retrieval fees. However, the court found that while job applications are generally protected from disclosure, that protection extends only to persons "outside of government." Therefore, the City was obligated to disclose those applications submitted by current employees of the City, although it properly withheld external applications. The court also found that the district court failed to address Teig’s claims of undue delay related to billing records. The case was remanded for further proceedings. View "Teig v. Chavez" on Justia Law

Emilio Puente, a police officer for the City of Iowa City, resigned from his position and later attempted to rescind his resignation. When the City rejected his attempt, Puente filed an action with the Civil Service Commission of Iowa City (Commission) for review of the City’s refusal to reinstate him. The Commission dismissed Puente's complaint, agreeing with the City that it was untimely. Puente then filed a petition for judicial review in the Johnson County District Court, which was dismissed for lack of jurisdiction. The court concluded that Puente’s “petition for judicial review” was not a “notice of appeal” as required by Iowa Code § 400.27.The Iowa Court of Appeals affirmed the district court's decision. The court of appeals relied on the differences between a chapter 17A proceeding and an appeal under section 400.27 to conclude that the petition for judicial review could not be deemed a notice of appeal. The court of appeals noted that the two are initiated differently, have different venue provisions and service requirements, and have different standards and scopes of review.The Supreme Court of Iowa reversed the lower courts' decisions. The Supreme Court found that Puente had substantially complied with the requirements for filing a notice of appeal from the Commission’s decision to the district court. The court noted that Puente's petition sought "judicial review" of the Commission’s decision, identifying the Commission as a “respondent” rather than a “defendant.” The court concluded that Puente's reference to the wrong Code provision for venue did not mean he failed to substantially comply with the correct Code provision. The court vacated the decision of the court of appeals, reversed the district court judgment dismissing Puente’s appeal from the Commission’s decision, and remanded for further proceedings. View "Puente v. Civil Service Commission of Iowa City" on Justia Law

In this case, the Supreme Court of Iowa was asked to determine who should bear the costs of a technology vendor hired to review a large volume of emails seized under a search warrant for potential attorney-client privileged communications. The emails belonged to a criminal defendant, Craig Juan Merrill, who was charged with multiple counts of ongoing criminal conduct, theft, assault, and misconduct in office. The search warrant stipulated that the seized materials would be reviewed by the district court to ensure no attorney-client privileged materials were inadvertently handed over to the prosecution.However, due to the large volume of emails and technical difficulties, the district court was unable to complete the review and decided to hire a technology vendor to assist. The question of who should bear the costs of this vendor became a point of contention. The district court initially ordered the prosecution to pay the costs, but left open the possibility that the costs could be taxed to the defendant at the conclusion of the case.The State of Iowa filed a petition for writ of certiorari with the Supreme Court of Iowa, arguing that the district court acted illegally in assessing the costs of the privilege review against the prosecution. The State contended that the judicial branch should bear the costs, as the vendor was effectively acting as a special master to assist the court.The Supreme Court of Iowa sustained the writ, ruling that the judicial branch should be responsible for the costs of the technology vendor. The court reasoned that the district court had voluntarily assumed the responsibility of conducting the initial privilege review and, when it was unable to do so, it was compelled to employ a third-party vendor. Under these unique circumstances, the court concluded that the judicial branch must bear the costs of the vendor it employed. View "State of Iowa v. Iowa District Court For Emmet County" on Justia Law

The case revolves around Lori Randolph, who was injured after falling down stairs in a rental property owned by Aidan, LLC. Randolph sued Aidan, alleging negligence in failing to provide safe stairs. Aidan, in turn, filed a third-party claim against Sioux City, asserting that a city employee had inspected the property and declared it compliant with the municipal code. Aidan claimed that the city was negligent in hiring, retaining, or supervising the unqualified inspector, and thus, should indemnify Aidan for any damages owed to Randolph. Sioux City moved to dismiss Aidan’s claim, arguing it was immune under Iowa Code section 670.4(1)(j).The district court denied Sioux City's motion to dismiss Aidan's claim. Sioux City and Randolph requested interlocutory review, which was granted. The Supreme Court of Iowa was tasked with reviewing the denial of Sioux City's motion for the correction of errors at law.The Supreme Court of Iowa reversed the district court's decision. The court held that Sioux City was immune from Aidan's claim under Iowa Code section 670.4(1)(j). The court reasoned that Aidan's claim for negligent hiring was "based upon" the negligence of Sioux City's employee in inspecting the stairs. Therefore, the claim fell within the scope of the immunity provided by section 670.4(1)(j). The court remanded the case for further proceedings, including the dismissal of Aidan's claim against Sioux City. View "Randolph v. Aidan, LLC" on Justia Law

The case involves a dispute between the Terrace Hill Society Foundation (THSF) and the Terrace Hill Commission (the Commission) over the ownership and control of a collection of property and historical artifacts displayed at the Governor's official residence, Terrace Hill. THSF filed a petition seeking a declaration that it was the sole owner of the collection and an injunction granting it the right to access, itemize, insure, maintain, and preserve the collection. The Commission and its chairperson, Kristin Hurd, moved to dismiss the suit, arguing that it was barred by the doctrine of sovereign immunity and that Hurd could not provide the requested relief.The district court denied the motion to dismiss with respect to the Commission, finding that the factual allegations in the petition, when viewed in the light most favorable to THSF, were sufficient to overcome the State's immunity from suit. The court reasoned that the Commission had willingly accepted possession of THSF's property and retained it after the expiration of a 1996 agreement between the parties. However, the court granted the motion to dismiss with respect to Hurd and dismissed the claims against her without prejudice.On appeal, the Supreme Court of Iowa affirmed the district court's decision. The court held that the State can impliedly or constructively waive its immunity from suit when it voluntarily creates certain legal relationships that subject it to liability. The court found that THSF's amended petition alleged sufficient facts to plead a voluntary bailment, a legal relationship sounding in contract, which impliedly waived the State's sovereign immunity. The court also affirmed the dismissal of the claims against Hurd without prejudice, rejecting her argument that the claims should have been dismissed with prejudice. The case was remanded for further proceedings. View "Terrace Hill Society Foundation v. Terrace Hill Commission" on Justia Law

The case revolves around the Kirkwood Institute's request for public records from the Office of the Auditor of State in Iowa. The Institute sought emails between the Auditor's office and two investigative reporters. The Auditor's office withheld ten email chains, citing Iowa Code § 11.42 and § 22.7(18), which protect certain types of information. Kirkwood sued, arguing that the Auditor's office failed to show that these exceptions applied to the withheld emails. Additionally, Kirkwood claimed that the Auditor's office failed to disclose an eleventh email chain that had been quoted in a reporter's blog.The district court granted summary judgment in favor of the Auditor's office, holding that the ten email chains were exempt from production and that no violation occurred with the late turnover of the eleventh email chain. Kirkwood appealed this decision.The Supreme Court of Iowa affirmed in part, reversed in part, and remanded the case. The court found that there was a factual issue as to whether the delay in producing the eleventh email was reasonable. It also found that the district court erred in granting summary judgment on the Auditor's office's withholding of nine emails under § 11.42, as it was not immediately apparent that these emails were received in the course of an audit or examination. However, the court affirmed the district court's decision regarding the tenth email withheld under § 22.7(18), agreeing that it fell within the exception created in this statute. View "Kirkwood Institute, Inc. v. Sand" on Justia Law

The case involves William and Mary Goche, LLC; Global Assets, LLC; and Joseph Goche (collectively “Goche”), who own land in three different drainage districts in Kossuth County. The Kossuth County Board of Supervisors administers these districts. Goche alleged that the board of supervisors administered the districts in a way that specifically caused him harm. He brought a suit against the board of supervisors, current and former supervisors, and engineering firm Bolton & Menk, Inc., asserting claims for breach of fiduciary duty and seeking punitive damages for the defendants’ alleged breaches.The defendants moved to dismiss the claims, arguing that they owed no fiduciary duty to Goche as an individual landowner within the drainage districts. The district court granted the motions, leading to Goche's appeal. However, in the appeal, Goche abandoned his breach of fiduciary duty claims and instead contended that he is entitled to proceed against the defendants on a standalone cause of action for punitive damages.The Supreme Court of Iowa disagreed with Goche's argument. The court clarified that punitive damages are a form of damages available to a plaintiff incidental to a recognized cause of action and not a freestanding cause of action. The court also noted that Goche conceded that the defendants owed him no fiduciary duty in the administration of the drainage districts or in providing engineering services to the districts. Therefore, the court affirmed the judgment of the district court, dismissing Goche's claims. View "William and Mary Goche, LLC v. Kossuth County Board of Supervisors in their capacity as Trustees of Drainage Districts 4, 18, and 80" on Justia Law

The Supreme Court of Iowa reviewed a case where a plaintiff, James Penny, brought a lawsuit against the City of Winterset and a police officer, Christian Dekker, for damages caused by a collision. Officer Dekker was responding to an emergency call and had his overhead lights and siren on. He was traveling northbound and James Penny was traveling westbound when their vehicles collided at an intersection. As a result of the collision, Penny sustained several injuries. The district court granted summary judgment in favor of the defendants, concluding that the police officer's conduct was not reckless. However, the Court of Appeals reversed this decision.On further review, the Supreme Court of Iowa found that Officer Dekker's conduct did not rise to the level of recklessness under Iowa law, affirming the district court's grant of summary judgment. The court noted that while Officer Dekker did not come to a complete stop at the stop sign, he was not required to do so under Iowa Code section 321.231(3)(a) if he slowed down to a speed "necessary for safe operation." The court concluded that while it may have been negligent for Officer Dekker not to have perceived the lights to his right as coming from Penny's vehicle rather than a farmhouse, this failure did not rise to the level of recklessness. Thus, the court vacated the decision of the Court of Appeals and affirmed the district court's judgment. View "Penny v. City of Winterset" on Justia Law