Justia Iowa Supreme Court Opinion Summaries

Chicago Central and Pacific Railroad Company (CCP) voluntarily performed repairs on a drainage improvement. When its request for reimbursement for those repairs was denied by the Calhoun County Board of Supervisors, the party responsible for keeping drainage district improvements in repair, CCP filed a petition for an appeal. The district court dismissed CCP's petition and entered judgment in favor of the Board, concluding that the CCP was liable for the costs of repair. The court of appeals affirmed. the Supreme Court vacated the court of appeals and affirmed the district court, albeit on a different basis, holding (1) under the statutory scheme enacted by the legislature, the Board has the duty to keep improvements in repair, but it also has the discretion to decide how to fulfill that duty; and (2) because CCP's suit essentially asked the Court to remove the Board's discretion while leaving its responsibilities intact, the suit was not permitted by law, and the district court properly dismissed the action. View "Chicago Cent. & Pac. R.R. Co. v. Bd. of Supervisors" on Justia Law

NextEra Energy Resources, LLC appealed the Iowa Utility Board's decision to grant advance ratemaking principles to MidAmerican Energy Company for a proposed wind generation facility. The district court affirmed the Board. The Supreme Court affirmed, holding (1) the Board properly interpreted and applied Iowa Code 476.53; (2) substantial evidence supported the Board's findings; (3) Iowa Code 476.43 was not applicable to this ratemaking proceeding; and (4) section 476.53 as applied to a rate-regulated public utility that may compete in the wholesale energy market did not violate the Equal Protection clauses of the Iowa or U.S. Constitutions or the Commerce Clause of the U.S. Constitution. View "Nextera Energy Res., LLC v. Iowa Utils. Bd." on Justia Law

In this case the Supreme Court considered whether an area education agency (AEA) acted lawfully when it approved for submission to the voters a petition that proposed a consolidation of two community school districts, Preston and East Central. East Central sought to block the measure from being placed before the voters, asserting (1) the AEA approval of the petition for submission to the voters was legally flawed because the AEA failed to comply with a statutory requirement that it develop a plan for the AEA district, and (2) the AEA failed to make a required statutory finding that the consolidation proposed in the petition was in conformity with the plan. The district court rejected the claims. The Supreme Court affirmed, concluding that the AEA acted lawfully in approving submission of the petition to the voters, as (1) the AEA was not required to develop a specific plan of merger between the two school districts prior to approval of submission of a citizen petition to the voters of the districts; and (2) by approving the submission of the issue to the voters, the AEA made an implied finding that all the statutory requisites were met. View "E. Central Cmty. Sch. Dist. v. Miss. Bend Area Educ. Agency" on Justia Law

Employee sought workers compensation benefits after receiving two injuries at her place of employment. While working for Employer, Employee received a salary increase of $1000. Although Employee received a salary increase of $1000 per month for more than a year, Employer claimed the increase was supposed to have been $1000 per year. The deputy commissioner calculated a weekly compensation rate based on the $1000 per month raise Employer actually paid Employee. The district court reversed and instead used the $1000 per year figure Employer claimed was accurate. The court of appeals reversed and determined that the $1000 per month raise should be included in the calculation of Employee's compensation rate. The Supreme Court vacated the court of appeals and remanded the case for a factual determination as to Employer's claim that it accidentally overpaid Employee $916 per month. View "Burton v. Hilltop Care Ctr." on Justia Law

The Employment Appeal Board (Board) denied Willie Hall's application for unemployment insurance benefits. Hall filed a petition for judicial review. The district court affirmed the decision of the Board and assessed costs against Hall. The court of appeals affirmed. The Supreme Court reversed the portion of the judgment as it related to court costs, holding (1) pursuant to Iowa Code 96.15(2), any individual claiming benefits shall not be charged fees of any kind, including court costs, in a proceeding under the statute by a court or an officer of the court; and (2) therefore, the district court erred by requiring that Hall pay court costs. View "Hall v. Employment Appeal Bd." on Justia Law

Employee injured his shoulder while working for Employer. Employer offered Employee light-duty work in Des Moines, which was 387 miles from Employee's residence. Employee declined Employer's offer to perform light-duty work, and as a result, Employer suspended Employee's workers' compensation benefits. Employee filed a workers' compensation claim. The workers' compensation commissioner concluded (1) Employer improperly suspended temporary disability benefits where Employer failed to offer Employee suitable work because the job was located a great distance from Employee's residence; and (2) Employee experienced a sixty percent industrial disability. The district court reversed in part, concluding that Employer offered Employee suitable work and thus, Employee forfeited his right to benefits during his period of refusal. The Supreme Court reversed in part, holding (1) the commissioner did not err in finding Employer failed to offer Employee suitable work; and (2) the commissioner's findings with respect to the extent of Employee's industrial disability were supported by substantial evidence. View "Neal v. Annett Holdings, Inc." on Justia Law

Employee filed a petition with the state workers' compensation commissioner, alleging that he suffered an injury to his shoulder while working for Employer and that his injury caused a permanent disability. The workers' compensation commissioner concluded that Employee failed to prove his claimed permanent disability was causally related to his work injury. The district court and court of appeals affirmed. The Supreme Court affirmed, holding (1) because an award for partial permanent disability for an unscheduled injury under Iowa Code 85.34(2)(u) is determined by industrial disability, rather than by functional impairment, the commissioner used the correct standard to determine the causal relation between the work injury and the alleged disability; and (2) furthermore, substantial evidence supported the commissioner's findings. View "Westling v. Hormel Foods Corp." on Justia Law

Members of the Old Order Groffdale Conference Mennonite Church are forbideen from driving tractors unless their wheels are equipped with steel cleats. A Mitchell County road protection ordinance forbade driving such vehicles on the highways. Matthew Zimmerman was cited for operating his tractor in violation of the ordinance. Zimmerman moved to dismiss the citation on the ground that his federal and state constitutional rights to free exercise of religion had been violated. The district court overruled Zimmerman's motion to dismiss, concluding that the ordinance (1) was both neutral and generally applicable, and (2) survived strict scrutiny. The Supreme Court reversed, holding that the ordinance as applied to church members violated the free exercise clause of the First Amendment where the ordinance (1) was not of general applicability because it contained exemptions that were inconsistent with its stated purpose of protecting Mitchell County's roads, and (2) did not survive strict scrutiny because it was not the least restrictive means of serving what was claimed to be a compelling governmental interest in road protection. Remanded for an order of dismissal. View "Mitchell County v. Zimmerman" on Justia Law

Employee injured her right ankle when she slipped and fell during the course of her employment. Employer later terminated Employee's employment. Employee filed a claim with the workers' compensation commission seeking benefits as a result of her alleged injuries. The commissioner ruled in favor of Pease, concluding that she suffered an injury to the body as a whole and that her work injury was a substantial contributory factor in her state of depression. The commissioner awarded Pease permanent total disability, accrued benefits, and reimbursement for medical expenses. The district court affirmed the commissioner's findings of fact with respect to the causation of Employee's mental and physical injuries and held that substantial evidence supported the commissioner's findings regarding disability. The court of appeals reversed the award, finding substantial evidence did not support the commissioner's findings on causation. The Supreme Court vacated the court of appeals and affirmed the district court, holding that the commissioner's findings of fact were supported by substantial evidence. View "Cedar Rapids Cmty. Sch. Dist. v. Pease" on Justia Law

Plaintiff, City of Riverdale, spent sixteen months in district court litigating wither Defendants, several individuals, were entitled to view security camera video of a confrontation with the mayor over earlier records requests at the city clerk's counter. The mayor filed a declaratory judgment action at the advice of a junior attorney even though a senior partner attorney earlier advised the mayor to produce the recordings. The trial court ordered the City to turn over a copy of the videotape and awarded Defendants attorney fees. The court of appeals vacated the fee award because the district court made no finding of bad faith on the part of the City. The Supreme Court vacated the court of appeals and affirmed the district court, holding (1) Iowa Code 22.10(3)(c) required the City to pay Defendants' reasonable attorney fees because the district court found the City violated the statute by withholding the video; and (2) the district court did not err by implicitly rejecting the City's good-faith, reasonable delay defense notwithstanding the City's reliance on advice of legal counsel. Remanded. View "City of Riverdale v. Diercks" on Justia Law