Justia Iowa Supreme Court Opinion Summaries

On July 22, 2014, the Muscatine County District Court issued an administrative order prescribing a formal procedure through which persons protected by orders of protection entered in criminal proceedings may seek to have them modified or terminated. The Muscatine County Attorney subsequently initiated an original proceeding in the Supreme Court seeking a writ of certiorari, contending that the administrative order exceeded the district court’s authority because it allowed victims in criminal cases to circumvent the County Attorney’s office and directly seek a modification or termination of no-contact orders in criminal cases. The Supreme Court issued a writ of certiorari. The Court then annulled the writ, holding that the administrative order was well within the district court’s authority, as the challenged order did not establish a right to modification or termination of no-contact orders in criminal cases but, rather, simply created a procedure for seeking such relief. View "Ostergren v. Iowa Dist. Court for Muscatine County" on Justia Law

Grady Billick sought workers’ compensation benefits for a series of work-related injuries. Roberts Dairy, Billick’s current employer, contended that its liability for Billick’s industrial disability should be apportioned because Billick was previously compensated for his losses of earning capacity arising from previous injuries through settlements with previous employers. The Workers’ Compensation Commissioner concluded that Roberts’s liability for permanent partial disability benefits could not be apportioned under the circumstances of this case. The district court reversed, concluding that the Commissioner misapprehended the relevant statutes. The Supreme Court reversed, holding that there was no error in the Commissioner’s interpretation of the relevant statutes. View "Roberts Dairy v. Billick" 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

Kevin Fink filed a petition requesting alternate medical treatment for knee injuries allegedly sustained during the course of his employment with Denison Municipal Utilities (DMU). The workers’ compensation commissioner sent DMU a notice providing that DMU was required to file a first report of injury pursuant to Iowa Code 86.12. When DMU failed to file the first report of injury, the deputy commissioner assessed $1,000 against DMU. The district court reversed the $1,000 assessment, concluding that the deputy commissioner incorrectly interpreted section 86.12 as authorizing the commissioner to demand DMU to file a first report of injury, that the first report of injury was not required by section 86.11, and therefore, the record lacked substantial evidence to support the assessment against DMU. The Supreme Court reversed, holding (1) in this case, DMU was required to file a first report of injury; and (2) the deputy commissioner’s decision that DMU failed to make a sufficient showing of good cause to avoid the $1,000 assessment pursuant to section 86.12 was supported by substantial evidence. View "Denison Mun. Utils. v. Iowa Workers’ Comp. Comm’r" on Justia Law

In 2006, Cable One, Inc., which offers cable television and internet access, began offering Voice over Internet Protocol (VoIP) service to its residential customers in Sioux City. In 2008 and 2009, the Iowa Department of Revenue determined that Cable One should be assessed based on the value of its telephone operating property in the state. Cable One appealed, arguing that it was not a telephone company subject to taxation under Iowa Code chapter 433 because VoIP is not the equivalent of telephone service. An administrative law judge (ALJ) in the Iowa Department of Inspections and Appeals entered summary judgment in favor of Cable One, concluding that the company did not fit the “historical context of a ‘telephone company.’” The Iowa State Board of Tax Review agreed with the ALJ that Cable One was not subject to assessment under chapter 433. The district court affirmed. The Supreme Court reversed, holding (1) wiring that was originally installed for cable television purposes but is now also used to provide VoIP service is a “telephone line”; and (2) therefore, Cable One, which operates these lines, is subject to central assessment for property tax purposes as a telephone company. View "Kay-Decker v. Iowa State Bd. of Tax Review" on Justia Law

The Workers’ Compensation Commission found Employee to be totally and permanently disabled under the odd-lot doctrine and denied Employer and its Insurer (collectively, Employer) certain credits for disability payments previously received by Employee from other sources. The district court affirmed the Commission’s finding that Employee was totally and permanently disabled but reversed on the credit issue. The court of appeals reversed, holding (1) substantial evidence did not support the Commission’s award of permanent total benefits, and (2) the Commission was correct in its decision concerning the credits. On further review, the Supreme Court (1) affirmed the district court’s finding that substantial evidence supported the Commission’s findings that Employee was totally and permanently disabled under the odd-lot doctrine; and (2) reversed the district court’s judgment regarding the issues concerning the credit due Employer. View "Gits Mfg. Co. v. Frank" on Justia Law

Susan Heathcote and Carrie La Seur served on the Environmental Protection Commission during a period of time when the Commission considered the adoption of rules to prevent the degradation of Iowa’s water resources. In 2009, the Commission voted to approve two antidegradation rules and procedures, which were approved by the EPA. Plaintiffs sought to overturn the rule and regulation, alleging that Heathcote was disqualified to vote because she engaged in activities in her employment in support of the rule and that La Seur was disqualified to serve on the Commission at the time she voted because she had moved to Montana and lost her status as an elector in Iowa. The district court granted summary judgment to the Commission regarding both Heathcote’s and La Seur’s participation. The Supreme Court affirmed, holding (1) the nature of rulemaking does not disqualify a Commission member from voting to adopt rules she personally and professionally supported; and (2) the disqualification of a Commission member did not invalidate the action taken by the Commission when the disqualification did not undermine the integrity of the process and the public interest supported validating the rule despite the disqualification. View "Iowa Farm Bureau Fed’n v. Envtl. Prot. Comm’n" on Justia Law

Plaintiff was injured when she crashed on her bicycle while riding on a sidewalk abutting the grounds of the University of Iowa in Iowa City. Plaintiff filed a negligence action against the City, claiming that an alleged defect in the sidewalk caused the accident. The City filed a motion to add the State as a third-party defendant, citing the City’s ordinance requiring an abutting property owner to maintain the sidewalk in a safe condition. The district court granted the motion. The City then filed a cross-claim against the State seeking contribution. The district denied the State’s motion to dismiss the City’s cross-claim, concluding (1) the City’s contribution claim was not excluded from the Iowa Tort Claims Act (ITCA) and adequately pled a claim under the ITCA; and (2) an ordinance can establish a duty, the breach of which supports a negligence claim. The Supreme Court affirmed, holding (1) the City’s ordinance was not preempted by Iowa Code 364.12(2); (2) the potential imposition of indemnity under the ordinance does not give rise to an unlawful tax; and (3) the City’s claim against the State was within the scope of ITCA for purposes of waiver of sovereign immunity. View "Madden v. City of Iowa City" on Justia Law

The Iowa Utilities Board (IUB) allowed an independent transmission company, ITC Midwest, to use the pay-and-go procedure of Iowa Code 476.27, the railroad-crossing statute, to run electrical power lines across a railroad at three locations, at the objection of the Hawkeye Land Company. Hawkeye Land owned the railroad-crossing easement but did not own or operate a railroad. An administrative law judge (ALJ) upheld the use of the pay-and-go procedure and denied compensation beyond the $750 standard per crossing fee the utility pays to the owner of the railroad right-of-way under the crossing statute. After concluding that it had interpretive authority over the crossing statute, the IUB issued a final order that reached the same conclusions as the ALJ. The district court affirmed on judicial review. The Supreme Court reversed, holding (1) the IUB lacked interpretive authority over the terms of the crossing statute; and (2) the crossing statute applied to Hawkeye Land, but because ITC Midwest was not a public utility, it was not allowed to use the pay-and-go procedure. View "Hawkeye Land Co. v. Iowa Utils. Bd." on Justia Law

After Appellant drove her car off the road and destroyed a mailbox, Appellant gave a urine sample that tested positive for controlled substances. Based on the test results, the Iowa Department of Transportation revoked Appellant’s license for 180 days. Appellant contested her revocation, asserting that the prescription-drug defense under Iowa Code 321J.2(11) applied in her case. An administrative law judge denied the appeal, finding that the evidence in this case established the elements of the statutory prescription-drug defense but that the prescription-drug defense did not apply in administrative license revocation proceedings. The district court affirmed. The Supreme Court reversed, holding that the prescription-drug defense is available in license revocation proceedings. View "Bearinger v. Iowa Dep’t of Transp." on Justia Law