Justia Iowa Supreme Court Opinion Summaries

Plaintiff filed a tort claim with the state appeal board for wrongful death, alleging that the Iowa Department of Transportation’s negligent maintenance of a highway caused her husband’s death. The appeal board took no action on the claim for more than six months. Plaintiff finally withdrew the claim and filed suit in the district court, both individually and as administrator of her deceased husband’s estate. The district court dismissed the suit, concluding that Plaintiff had failed to exhaust administrative remedies before filing suit as administrator of the estate. The Supreme Court reversed, holding that Plaintiff exhausted her administrative remedies and properly presented her claim to the appeal board. View "McFadden v. Dep’t of Transp." on Justia Law

Employee strained his back while working for Employer. Two years later, Employer notified Employee that it would no longer pay for his medical care, believing that the two-year statute of limitations for workers’ compensation benefits had expired. Employee sought benefits from the Iowa Workers’ Compensation Commission. The deputy commissioner ruled that the two-year statute of limitations in Iowa Code 85.26 barred Employee’s claim and that, even though Employee filed a workers’ compensation proceeding within thirty days after receiving the notice from Employer, the discovery rule did not apply in this case. The district court reversed. The Supreme Court affirmed, holding that the discovery rule applied under the circumstances presented in this case. View "Baker v. Bridgestone/Firestone" on Justia Law

Petitioners petitioned for judicial review of a decision by the City Development Board approving the annexation of certain land. The district court affirmed. Petitioners filed a notice of appeal and a motion for extension of time to appeal, claiming that the annexation was improper. The Board filed a motion to dismiss the appeal as untimely filed. At issue before the Supreme Court was whether the time to file a notice of appeal in an electronically filed case begins on the day the notice of filing is electronically submitted or on the day the court order from which the appeal is taken has been electronically filed. The Supreme Court dismissed this appeal, holding (1) the notice of appeal from a final judgment or order of the district court must be filed within thirty days of the date the judgment or order was electronically filed, rather than the date of the notice of filing; and (2) the notice of appeal in this case was untimely filed. View "Concerned Citizens of Southeast Polk Sch. Dist. v. City Dev. Bd. of Iowa" on Justia Law

After an investigation, the Iowa Department of Natural Resources (DNR) determined that the release of sweet corn silage runoff from Appellant’s farming operation caused fish kill on the Winnebago River. The DNR submitted a restitution assessment to Appellant, which included a restitution amount of $61,794. After a contested hearing, an administrative law judge issued a proposed decision that affirmed the restitution assessment. The Natural Resource Commission affirmed. The district court reversed and struck the restitution assessment. On remand, the Commission reduced the restitution assessment to Appellant as a result of the fish kill to $5298. Appellant then applied for an award of attorney fees pursuant to Iowa Code 625.29. The district court denied the motion, finding that three exceptions to the requirement to award attorney fees applied. The court of appeals reversed, concluding that none of the exceptions found in section 625.29(1) applied to Appellant’s case to preclude an award of attorney fees and that the district court should have found Appellant was the prevailing party under the statute. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding that the State’s role in this case was primarily adjudicative, precluding an award of attorney fees. View "Brandstad v. State ex rel. Nat. Res. Comm’n" on Justia Law

The Workers’ Compensation Core Group of the Iowa Association for Justice filed a petition for declaratory order with the Workers’ Compensation Commissioner seeking a determination whether Iowa Code 85.25(2) mandates that employers or insurance carriers defending workers’ compensation claims must immediately provide copies of surveillance videos, photographs, and reports concerning a claimant’s physical or mental condition relative to the claim. The Commissioner concluded that section 85.27(2) overrides the work product immunity, thus requiring the disclosure of surveillance materials upon request from a claimant before the claimant is deposed. The district court affirmed. The Supreme Court reversed, holding that section 85.27(2) does not affect privileges and protections related to the litigation process such as the work product doctrine because the statute is limited to health-care-related privileges such as the physician-patient privilege. Remanded. View "Iowa Ins. Inst. v. Core Group of the Iowa Ass’n for Justice" on Justia Law

Employee was injured while working for Employer. Employee filed a workers’ compensation claim and submitted a report from a physician from whom she received an examination that was not authorized by Employer. The deputy workers’ compensation commissioner concluded that Employee suffered a permanent partial disability to her back and taxed as a cost against Employer the expense of the examination and report under the administrative rule governing the assessment of costs in a hearing. The district court affirmed, holding that the reimbursement was proper. The court of appeals reversed, concluding that the reimbursement would be inconsistent with Iowa Code 85.39. The Supreme Court affirmed, holding that the commissioner may not tax the fees of a physician arising from the evaluation of an employee done outside the process set forth in section 85.39 as “costs incurred in the hearing” when the employee submits a written report of the evaluation at the hearing. View "Des Moines Area Reg’l Transit Auth. v. Young" on Justia Law

In 2013, the General Assembly appropriated funds for the operation of the Iowa Juvenile Home (IJH) in Toledo for the 2014 fiscal year, but five months into 2014, the Iowa Department of Human Services (DHS) decided to close the home. Plaintiffs - two state senators, two state representatives, and the president of a labor organization representing employees at the IJH - sued Defendants - the Governor and the director of DHS - seeking, inter alia, a determination that Defendants’ refusal to spend appropriated funds to continue operating the IJH was unconstitutional. The district court entered a temporary injunction preventing closure of the IJH. While Defendants’ appeal was pending, the General Assembly declined to fund ongoing operations of the IJH for the 2015 fiscal year. The Supreme Court reversed the district court and remanded with instructions to dismiss the case, holding that the case was moot because the Legislature was no longer appropriating funds for the operation of the IJH. View "Man v. Branstad" on Justia Law

In 2006, Appellant was injured while working at Wal-Mart. In 2009, Appellant was injured while working at Warren Properties. Appellant filed a complaint against Warren Properties to recover compensation for her 2009 injury. The deputy workers’ compensation commissioner awarded benefits based on a finding of two successive injuries to the back and a shoulder injury and applied the full-responsibility rule with no apportionment for the preexisting disability. The workers’ compensation commissioner affirmed. The district court affirmed in part and reversed in part, holding that the commissioner erred in failing to apportion Appellant’s preexisting disability that arose from the 2006 injury when calculating the benefits owed by Warren Properties for the 2009 injury. The court remanded to the case for a determination as to whether the 2009 injury resulted in any new back disability. The Supreme Court affirmed in part, reversed in part, and remanded, holding that an employer who is liable to compensate an employee for a successive unscheduled work injury is not liable to pay for the preexisting disability that arose from employment with a different employer or from causes unrelated to employment if the employee’s earning capacity was not evaluated both before and after the successive injury. Remanded. View "Warren Props. v. Stewart" on Justia Law

In 2012, the Iowa City Board of Review reclassified eighteen properties from commercial to residential for property tax purposes because the properties had recently been organized as multiple housing cooperatives. Two Iowa corporations organized the cooperatives under chapter 499A of the Iowa Code. The City of Iowa City appealed, arguing that the Board’s reclassification was improper because two natural persons, not two corporations, must organize multiple housing cooperatives under the Code. The City also argued that the organizers did not properly organize the cooperatives because each cooperative had more apartment units than members and section 499A.11 requires a one-to-one ratio. The district court granted summary judgment in favor of the Board and the intervening housing cooperatives. The Supreme Court affirmed, holding (1) two Iowa corporations may organize a multiple housing cooperative under chapter 499A; and (2) the Code does not require a one-apartment-unit-per-member ownership ratio for a multiple housing cooperative to be properly organized. View "City of Iowa City v. Iowa City Bd. of Review" on Justia Law

Dolphin Residential Cooperative, Inc. owned an apartment complex in Iowa City that consisted of twenty-two buildings comprising four hundred residential units. The Iowa City assessor classified the multiunit apartment buildings as commercial property for tax assessment purposes. Dolphin challenged this classification, arguing that because it was a multiple housing cooperative, organized under chapter 499A of the Iowa Code, the property should have been classified as residential property. The Iowa City Board of Review denied Dolphin’s request to reclassify the property, determining that because Dolphin was not properly organized under chapter 499A, Dolphin failed the organizational test for residential cooperatives adopted by the Supreme Court in Krupp Place 1 Coop, Inc. v. Board of Review. On appeal, the district court granted summary judgment in favor of Dolphin, concluding that Dolphin met the organizational test set forth in Krupp and ordering the Board to reclassify the subject property as residential property for tax assessment purposes. The Supreme Court reversed, holding that Dolphin was not properly established under section 499A.1(1), and therefore, the district court erred when it granted summary judgment to Dolphin and denied summary judgment to the Board. View "Dolphin Residential Coop., Inc. v. Iowa City Bd. of Review" on Justia Law