Justia Iowa Supreme Court Opinion Summaries

Articles Posted in Government & Administrative Law
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The Supreme Court affirmed the decision of the district court affirming the conclusion of the workers' compensation commissioner that Claimant's rotator cuff injury was a scheduled shoulder injury rather than an unscheduled whole body injury under Iowa Code 85.34(2), holding that there was no error.Claimant sustained a work-related injury that was diagnosed as a "full thickness rotator cuff tear that has retracted to the level of the glenoid, severe AC arthrosis, tendonitis and tearing of the biceps tendon." In seeking permanent partial disability benefits, Claimant argued that her injury qualified as an unscheduled injury to the body as a whole, entitling her to industrial disability benefits. The commissioner concluded that Claimant's rotator cuff injury was a scheduled injury to the shoulder, and the district court affirmed. The Supreme Court affirmed, holding that the district court properly determined (1) Claimant's rotator cuff injury was a scheduled shoulder injury under Iowa Code 85.34(2)(n); and (2) substantial evidence supported the commissioner's finding that Claimant failed to prove her biceps tear resulted in a permanent disability to her arm under section 85.34(2)(m). View "Chavez v. MS Technology LLC" on Justia Law

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The Supreme Court affirmed the decision of the district court affirming the declaratory order of the Iowa Department of Education interpreting a number of statutes and answering five questions posed by the Keystone Area Education Agency, holding that there was no error or abuse its discretion.The questions at issue concerned whether public agencies are required to release or excuse students to receive behavioral analysis therapy (ABA therapy) and, if so, under what circumstances. The Department's declaratory order determined, among other things, that the decision whether to excuse an absence for ABA therapy is generally up to the school district and that a public agency that does excuse attendance for therapy may violate federal law under some circumstances. The district court affirmed. The Supreme Court affirmed, holding (1) the Department had the authority to issue the declaratory order; and (2) the Department's declaratory order was supported by substantial evidence. View "Hills & Dales Child Development Center v. Iowa Department of Education" on Justia Law

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The Supreme Court affirmed in part and reversed in part the decision of the district court dismissing Appellants' petition for judicial review of the decision of the Iowa Public Information Board declining to order the disclosure of any records that had not previously been disclosed, holding that the district court erred in part.The open records requests at issue in this case stemmed from a 2015 incident in which a police officer responding to a 911 call about a domestic assault accidentally shot and killed one of the participants. The incident led to a civil lawsuit and also prompted the records requests. The family's attorney filed a complaint under the Iowa Public Information Board Act, but the Board declined to order disclosure of the requested records. The district court dismissed the family's attorney's petition for judicial review based on lack of standing and failure to exhaust administrative remedies. The Supreme Court held (1) the family's attorney exhausted administrative remedies by filing with complaint with the Board, but on judicial review, the attorney may only pursue open records requests that were actually raised before the Board and decided by it; and (2) the family's attorney did not have standing to seek the production of records that are now publicly available. View "Klein v. Iowa Public Information Board" on Justia Law

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The Supreme Court affirmed the order of the district court granting Employer's motion to dismiss a petition for judicial review as untimely, holding that the district court correctly dismissed Claimant's petition for judicial review.Claimant sustained a work injury and pursued workers' compensation benefits. The workers' compensation benefits ordered Employer to pay temporary total disability benefits related to Claimant's right extremity injury but rejected Claimant's claim that she had also sustained a right shoulder occupational injury. According to Iowa Code 17A.19(3), Claimant had thirty day to file a petition for judicial review. Claimant's attorney failed to file the petition by the deadline. When the attorney realized his oversight, Claimant filed a petition for judicial review. The district court dismissed the petition as untimely. The Supreme Court affirmed, holding that the district court did not err. View "Askvig v. Snap-On Logistics Co." on Justia Law

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The Supreme Court affirmed the order of the district court reversing the Iowa Board of Medicine declaratory order interpreting Iowa Code 272C.6(4)(a) as allowing the Board to publish statements of charges and press releases containing investigative information, holding that the district court did not err.The Board filed a statement of charges against Dr. Domenico Calcaterra accusing him of a "pattern of disruptive behavior and/or unethical or unprofessional conduct" and published the statement of charges against Dr. Calcaterra, along with a press release, on the Board's website. Several years after the parties reached a settlement, information about the allegations against Dr. Calcaterra remained available on the Board's website. Dr. Calcaterra filed a petition for declaratory order with the Board challenging that Board's ongoing dissemination of investigative information. The Board denied the challenge. The district court set aside the Board's order, holding that section 272.6(4)(a) prohibited the disclosure of the investigative information. The Supreme Court affirmed, holding that the Board incorrectly interpreted section 272C.6(4)(a) and that investigative information cannot be released to the public in a statement of charges or a press release when there has been no underlying final decision in the disciplinary proceeding. View "Calcaterra v. Iowa Board of Medicine" on Justia Law

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The Supreme Court affirmed the district court's order sustaining a subpoena served on a state agency for various categories of information related to a potential transaction, holding that the subpoena was not invalid.The agency in this case (Agency) and a state institution (Institution) overseen by the Agency contacted Rob Sand, the Iowa Auditor of State (Auditor Sand), to discuss a transaction that was expected to create a multi-billion dollar obligation for the Agency. Auditor Sand requested information on the potential investors involved in the transaction, but the Agency refused to provide the information, asserting that it was confidential. Auditor Sand then served a subpoena on the Agency requesting thirteen categories of documents related to the transaction. The district court entered an order sustaining the subpoena. The Supreme Court affirmed, holding that, even though Auditor Sand was not actually engaged in an audit, the subpoena was valid. View "Sand v. Doe" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the district court upholding the ruling of the Property Assessment Appeal Board (PAAB) concluding that bins that primarily hold raw material until it is needed in the manufacturing process do not themselves constitute "machinery," holding that some, but not all, of the ingredient bins qualify for a tax exemption.At issue was when bins for holding ingredients qualify for a tax exemption as machinery used in manufacturing establishments under Iowa Code 427A.1(1)(e). The court of appeals disagreed with the PAAB's interpretation of the statute, finding that bins that are integrated into the manufacturing process and used for temporary storage of ingredients fell within the statutory exemption. The Supreme Court vacated the court of appeals' decision and reversed in part the district court's judgment, holding (1) customized overhead bins within a building where feed is manufactured constitute part of a continuous piece of machinery within that building; and (2) two large stand-alone corn silos, while connected by an underground conveyor to the feed manufacturing facility, do not meet the definition of machinery. View "Stateline Cooperative v. Iowa Property Assessment Appeal Board" on Justia Law

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In this case arising out of the discontinuance of the City of Mt. Union, the Supreme Court affirmed the decision of the district court dismissing Plaintiffs' claim against the City Development Board, holding that the district court correctly concluded that a petition for judicial review under Iowa Code chapter 17A was Plaintiffs' exclusive remedy against the Board.Dan and Linda Johnson obtained a default judgment against the City, which had then been discontinued, for defamation, and presented it for payment to the Board, a state agency that supervises the discontinuance of cities. The Board approved the default judgment as a valid administrative claim. Plaintiffs petitioned for judicial review and filed this lawsuit seeking a declaratory judgment. The district court granted summary judgment for Plaintiffs and against the Johnsons in the declaratory judgment action but dismissed Plaintiffs' claim against the Board. The court of appeals reversed the dismissal of the Board. The Supreme Court vacated the court of appeals' decision in part, holding that Iowa Code 368.22 expressly makes chapter 17A "the exclusive means" of judicial review of the Board's actions. View "Marek v. City Development Board of State of Iowa" on Justia Law

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The Supreme Court reversed the order of the district court denying Defendants' motion for summary judgment and holding that the City of Davenport's mayor was required to show cause to remove an appointee from the Davenport Civil Rights Commission, holding that the law imposed no obligation on the mayor to show cause for the appointee's removal from the commission.Mayor Frank Klipsch entered an order removing Commissioner Nicole Bribriesco-Ledger from the Davenport Civil Rights Commission before her term had expired. Bribriesco-Ledger brought this action claiming that Klipsch had no authority to remove her absent a showing of cause. Defendants - Klipsch and the City of Davenport - filed a motion for summary judgment, which the trial court denied. The Supreme Court reversed, holding that removal from office under Iowa Code 372.15 does not require that the removal be for cause. View "Bribriesco-Ledger v. Klipsch" on Justia Law

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The Supreme Court vacated the decision of the court of appeals affirming the decision of the district court concluding that the county board of adjustment legally granted an area variance to certain property owners, holding that the board of adjustment acted illegally in granting the variance from the county zoning ordinance.The Board of Adjustment of Cerro Gordo County granted the application for a variance filed by Gregory and Lea Ann Saul that allowed them to construct a pergola twenty-one inches from the property line. The local ordinance required a six-foot setback. The district court concluded that the board acted legally in granting the variance. The court of appeals affirmed. The Supreme Court vacated the judgment of the court of appeals and reversed the district court, holding that the Sauls did not meet their burden to establish unnecessary hardship. View "Earley v. Board of Adjustment of Cerro Gordo County" on Justia Law