Justia Iowa Supreme Court Opinion Summaries

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

Krisha Bowman, a single mother of three minor children, received Section 8 housing assistance for several years. The Des Moines Municipal Housing Agency (DMMHA) later discontinued Bowman's housing assistance based on five alleged occurrences of unreported income. A hearing officer found that Bowman's assistance had been properly terminated. The district court affirmed. The Supreme Court affirmed, holding (1) DMMHA's determination that Bowman had five occurrences of unreported income was supported by substantial evidence; (2) DMMHA's policy of treating a failure to report each child's Social Security benefits as a separate occurrence of unreported income did not violate the Fair Housing Act; and (3) DMMHA did not improperly fail to consider Bowman's mitigating circumstances before terminating her assistance. View "Bowman v. City of Des Moines Mun. Hous. Agency" on Justia Law

Evercom Systems provided telephone services to inmates in correctional facilities throughout the country. When Evercom billed a customer for collect calls he did not accept, the customer lodged a complaint to the Iowa Utility Board. The Board imposed a civil penalty for a "cramming" violation based on improper billing for collect telephone calls under Iowa Code 476.103 and Iowa Admin. Code r. 199-22.23. The district court reversed the agency's decision and imposition of the civil penalty, concluding that the Board misinterpreted the law and that no cram occurred. The court of appeals reversed the district court and reinstated the civil penalty. The Supreme Court vacated the court of appeals and affirmed the district court, holding that Evercom's actions did not constitute a cram under rule 199-22.23. Remanded for dismissal. View "Evercom Sys., Inc. v. Utils. Bd." on Justia Law

In this condemnation case, Plaintiffs brought an action against the Iowa Department of Transportation (IDOT) and the State. IDOT's motion to dismiss was granted. Subsequently, the district court granted summary judgment for the State, concluding that Plaintiffs' exclusive remedy was a mandamus action to compel condemnation proceedings. The court then dismissed the first action. Before the district court had entered its summary judgment ruling, Plaintiffs petitioned for writ of mandamus against IDOT in a second action. After the court granted summary judgment for the State, IDOT filed a motion for summary judgment, arguing that the dismissal of the first action barred Plaintiffs from bringing the second action under both claim and issue preclusion. The district court disagreed and granted Plaintiffs' requested writ of mandamus. Defendants appealed on the issue of claim preclusion. The Supreme Court affirmed, holding that when a court order dismissing an action reveals the court's intent to preserve a claim arising out of the same transaction that is pending in another lawsuit, the claim in the other lawsuit should be allowed to proceed. View "Lambert v. Dep't of Transp." on Justia Law

After Toby Welch was arrested for operating a vehicle while intoxicated, police officers requested a breath specimen to be used for chemical testing. Welch refused the request. After talking to his attorney, however, Welch told officers that he wanted to consent to the breath test. The officers declined the request, commenting that because Welch had already refused, it was too late to submit to the test. Based on his refusal to submit to chemical testing, the Iowa DOT revoked Welch's driver's license for one year. The DOT's administrative law judge sustained the revocation, and the reviewing officer affirmed. The district court affirmed the revocation. At issue on appeal was whether the "one refusal is determinative" rule set forth in Krueger v. Fulton should be abrogated in favor of a more flexible standard permitting a motorist's subsequent consent to cure a prior initial refusal to submit to chemical testing. The Supreme Court rejected Welch's appeal and upheld the revocation of his license, concluding that a rule treating the motorist's initial refusal as determinative was supported by Court precedents, was consistent with the general assembly's intent, and was easier for police and courts to administer. View "Welch v. Iowa Dep't of Transp." on Justia Law

Two corporations organized as multiple housing cooperatives appealed the classification of their real estate as commercial for property tax purposes to the Jasper County Board of Review. The board did not alter the classification of the properties, and the cooperatives appealed. The district court affirmed the board's determination, concluding that the cooperative was actually operating as a standard rental property. After granting the cooperatives' combined motion for amendment and enlargement of findings and for a new trial, the district court concluded the cooperatives had followed all proper corporate formalities and were set up exactly as prescribed by Iowa law. Accordingly, the court reversed its prior ruling and concluded the real estate should properly be classified as residential. The court of appeals affirmed. On review, the Supreme Court affirmed, holding (1) Iowa law requires property owned by residential cooperatives, properly organized under chapter Iowa Code chapter 499A, to be classified as residential and taxed at residential property rates; and (2) because the cooperatives were operating on a nonprofit basis, there was no basis for penetrating the corporate veil. View "Krupp Place 1 Co-op, Inc. v. Jasper County Board of Review" on Justia Law