Justia Iowa Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the district court concluding that the Iowa Department of Human Services (DHS) was entitled to a detailed accounting and all of the residual funds The Center for Special Needs Trust Administration, Inc. had retained from Steven Muller's trust subaccount, holding that the district court erred.The Center for Special Needs Trust Administration, Inc. acted as trustee over a pooled special needs trust subaccount for the benefit of Muller. After Muller died, the Center retained all residual funds in his trust subaccount. DHS sought judicial intervention to obtain a detailed accounting of the retained funds. The district court decided in favor of DHS and ordered the Center to pay DHS all of the funds it had retained from the subaccount. The Supreme Court reversed, holding that the Center provided an adequate accounting, and therefore, the district court lacked authority to grant the relief it provided to remedy the Center's alleged failure to account for the retained funds. View "In re Medical Assistance Pooled Special Needs Trust of Steven Muller" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment for the Center for Special Needs Trust Administration, Inc., as trustee of a polled special needs trust held for the benefit of Scott Hewitt, and dismissing this action brought by the Iowa Department of Human Services (DHS) claiming it was entitled to a detailed accounting, holding that the trustee provided an adequate accounting.Title XIX of the Social Security Act required that the funds remaining in Hewitt's trust subaccount when he died must first be used to reimburse the state for its Medicaid expenditures. DHS filed a petition to invoke jurisdiction over the irrevocable trust, claiming that it was entitled to a detailed accounting to ensure that the funds retained by by the pooled special needs trust were used for a proper purpose. The district court granted summary judgment for the Center, concluding that no further accounting was required absent evidence that the Center breached its duties as trustee. The Supreme Court affirmed, holding that DHS was not entitled to relief on its claims of error. View "In re Medical Assistance Pooled Special Needs Trust Of Scott Hewitt" on Justia Law

The Supreme Court reversed the judgment of the district court denying Appellant's petition for judicial review of an order of the Iowa Utilities Board approving a regulated public utility's emissions plan and budget, holding that the Board erred in failing to consider certain intervenors' evidence in determining whether the "Emissions Plan and Budget" (EPB) met the statutory requirements.The utility submitted an EPB - its initial plan and budget and subsequent updates - requesting approval for operations and maintenance expenditures associated with emissions controls previously approved at four coal-fueled power plants. The Board granted several motions to intervene in the contested case proceeding, including three environmental parties. Prior to the contested case hearing, the Board approved the utility's EPB. The environmental parties petitioned for judicial review, and the district court affirmed. The Supreme Court reversed, holding that the Board erred in rejecting the evidence brought by the intervening parties that the retirement of coal-fueled electric power generated facilities was more cost effective than the utility's plan and budget as outside the scope of Iowa Code 476.6 and thus not relevant. View "Environmental Law & Policy Center v. Iowa Utilities Bd." on Justia Law

The Supreme Court affirmed as modified the judgment of the district court denying Defendants' motion to dismiss Plaintiffs' claims of open records violations, holding that Iowa's Open Records Act, Iowa Code chapter 22, may permit Plaintiffs to pursue claims based on untimeliness and that the district court did not err in granting Defendants' motion to dismiss.In 2020 and 2021, Plaintiffs requested public records from Defendants. Plaintiffs brought this suit in December 2021, and in January 2022, Defendants provided responsive records. Defendants filed a motion to dismiss, arguing that the timeliness claims were moot. The district court denied the motion. The Supreme Court affirmed as modified, holding (1) most of the claims concerning production of already-produced records were moot; and (2) with some qualifications, Plaintiffs could pursue claims that Defendants violated chapter 22 through delays in responding to Plaintiffs' open records requests. View "Belin v. Reynolds" on Justia Law

The Supreme Court affirmed the rulings of the district court and court of appeals that the workers' compensation commissioner erred in granting Employer's motion for summary judgment and dismissing Employee's review-reopening petition, holding that Employee was permitted to pursue a claim for a permanent injury in a review-reopening proceeding despite an earlier adjudication that her injury was not permanent.Employee was injured during the course and work of her employment. Employee filed a petition seeking workers' compensation for a permanent disability, but the deputy commissioner refused to order additional benefits beyond those that Employer had already paid. Employee filed a petition for review-reopening with the workers' compensation commission. The commission determined that Employee's claim for permanent disability benefits was barred by principles of res judicata. The district court reversed, and the court of appeals affirmed. The Supreme Court affirmed, holding that the agency erred in dismissing Employer's review-reopening petition. View "Green v. North Central Iowa Regional Solid Waste Authority" on Justia Law

The Supreme Court affirmed the judgment of the district court denying the state auditor's application to enforce a subpoena against the Iowa Communities Assurance Pool (ICAP), holding that ICAP is not a governmental subdivision over which the state auditor has statutory authority.To facilitate a reaudit of ICAP, a local government risk pool organized as an unincorporated nonprofit association under Iowa Code 670.7, the state auditor issued a subpoena to ICAP for certain financial records. Because ICAP supplied some, but not all, of the requested records the state auditor applied to the district court to enforce the subpoena and obtain the remainder of the documents. The district court denied the application, concluding that ICAP was not subject to the state auditor's authority because it was not a "governmental subdivision" within the meaning of Iowa Code 11.1(1)(c) and thus was not subject to the state auditor's authority. View "Auditor of State v. Sand" on Justia Law

The Supreme Court reversed the decisions of the district court and employment appeal board affirming the decision of the department of workforce development denying Appellant's claim for unemployment benefits, holding that Appellant's claims on appeal were unavailing.Appellant, an apprentice electrician, attended a week-long training as part of his apprenticeship curriculum, and his employer didn't pay him for that week. Appellant filed a claim for unemployment benefits under Iowa Code 96.4(3), arguing that he met the statute's criteria that he be able to work, available for work, and actively seeking work. The department of workforce development denied the claim, and the employment appeal board and district court affirmed. The Supreme Court affirmed, holding that the board's decision that Appellant had not established his eligibility for benefits was not an erroneous interpretation of the law, unsupported by substantial evidence in the record, or an abuse of the board's discretion. View "Dornath v. Employment Appeal Bd." on Justia Law

The Supreme Court held that the Iowa Public Employee Relations Board (PERB) and the district court misinterpreted Iowa Code 20.32 by extending broader bargaining rights to nontransit employees in the same bargaining unit as public transit employees, holding that the plain meaning of the statute protects only transit employees, not nontransit employees in the same bargaining unit.The City of Ames sought guidance as to whether section 20.32 requires broader bargaining rights for nontransit employees in the same bargaining unit. PERB concluded that broader bargaining rights must be extended under the statute to nontransit employees in a bargaining unit consisting of at least thirty percent transit employees, and the district court affirmed. The Supreme Court reversed, holding that the City was not required to provide broader bargaining rights to nontransit employees, regardless of the percentage of transit employees in the bargaining unit. View "City of Ames v. Iowa Public Employment Relations Bd." on Justia Law

The Supreme Court vacated the decision of the court of appeals reversing the order of the district court granting summary judgment in favor of Wapello County in this property dispute, holding that the district court correctly concluded that the parties' agreement allowed the County to remove a group of vehicles on Landowners' property.Landowners were operating a vehicle repair and salvage business on residential property in Wapello County when the County notified Landowners of its' intent to clean up the alleged nuisance. The parties entered into a settlement agreement, under which Landowners agreed to allow the County to enter the property to remove any remaining "derelict vehicles" to the "satisfaction of the County" at the expiration of ninety days. At the conclusion of the ninety-day period, the County had the vehicles remaining on the property removed. Landowners brought this lawsuit, alleging breach of the agreement. The district court granted summary judgment for the County. The Supreme Court affirmed, holding (1) an objective standard applied to the County's determination of its satisfaction under the agreement; and (2) the removal of the vehicles did not breach that objective standard. View "McNeal v. Wapello County" on Justia Law

The Supreme Court affirmed in part and vacated in part the decision of the court of appeals affirming the decision of the Iowa Department of Transportation (DOT) to rescind Petitioner's license under Iowa Code 322.3(12), holding that there was substantial evidence to revoke the motor vehicle dealer license.Petitioner, who owned and operated a vehicle dealership, pleaded guilty to one count of structuring transactions to avoid mandatory reporting requirements in violation of 31 U.S.C. 5324(a)(1) and (3) and was sentenced to a term of probation. The DOT then revoked Petitioner's Motor Vehicle Dealer License for a period of five years because of the structuring conviction. The district court upheld the revocation, stayed enforcement of the license revocation until the completion of the appeal, and tolled the entirety of the five-year revocation period. The court of appeals upheld the license revocation but determined that the district court lacked the authority to toll the five-year license revocation period. The Supreme Court held (1) there was substantial evidence to revoke the motor vehicle dealer license; and (2) the revocation period shall be extended by the length of the stay. View "Carreras v. Iowa Department of Transportation, Motor Vehicle Division" on Justia Law