Justia Iowa Supreme Court Opinion Summaries

Pursuant to an arbitration award, American Home paid workers’ compensation benefits to an employee injured in 2008. American did not file a notice before the arbitration that, pursuant to Iowa Code 85.21, it was paying the claim subject to a potential coverage issue. By 2013, American paid all the benefits owed under the arbitration award. In 2016, the employee sought to reopen the case. American then filed a section 85.21 notice seeking reimbursement of benefits paid to the employee, claiming that on the date of injury Liberty Mutual was providing the employer with workers’ compensation coverage.The workers’ compensation commissioner concluded that in order to be entitled to reimbursement, American was required to file section 85.21 notice before the arbitration proceeding and could not, years later, seek to be reimbursed. The district court reversed, reasoning that section 85.21 gave the commissioner broad power to order reimbursement, not time-limited in the statute. The court of appeals, agreeing with the commissioner, reversed. The Iowa Supreme Court agreed. The commissioner may require that insurance carriers obtain a section 85.21 reimbursement order before an evidentiary hearing in order to seek indemnity or contribution from another carrier. The procedural question is not controlled by the substantive provisions of section 85.21. The commissioner has simply established a rule of procedure for handling section 85.21 claims. View "American Home Assurance v. Liberty Mutual Fire Insurance Co." on Justia Law

The Supreme Court reversed the judgment of the district court affirming the decision of the workers' compensation commissioner denying Petitioner's petition for benefits for trauma-induced mental injuries she suffered on the job while working as emergency dispatcher, holding that because Petitioner established that her PTSD resulted from a manifest happening of a sudden traumatic nature from an unexpected cause or unusual strain, Petitioner was entitled workers' compensation benefits.Petitioner, a sixteen-year veteran of the county emergency dispatch system, sought benefits for the PTSD she suffered after taking a 911 call from a woman screaming over and over at a high pitch, "Help me, my baby is dead." The workers' compensation commissioner and district court denied benefits, concluding that the mother's call wasn't an "unexpected cause or unusual strain." The Supreme Court reversed, holding that Petitioner was entitled to benefits because she established that her PTSD resulted from a manifest happening of a sudden traumatic nature from an unexpected cause or unusual strain. View "Tripp v. Scott Emergency Communication Center" on Justia Law

The Supreme Court vacated the decision of the court of appeals reversing the judgment of the district court affirming the decisions of the administrative law judge (ALJ) and the Iowa Department of Transportation (DOT) that good cause existed to permit a franchiser to create dueling franchises in a geographic area under Iowa Code 322A.4, holding that the district court did not err in its judgment.At issue was whether, in considering if the establishment of an additional franchisee in a geographic area is in the public interest, the DOT must consider the investment and impacts across the entire geographic area of the existing franchisee. The ALJ and DOT concluded that the twenty-three county area where the additional franchisee would compete with the existing franchisee was the relevant geographic area to consider when determining the presence of good cause under section 322A.4. The court of appeals reversed, arguing that the relevant geographic area to consider was the entire seventy-one county area in which the existing franchise conducted business. The Supreme Court vacated the decision below and affirmed the trial court, holding that the proper focus was the area in which the existing franchisee and the proposed new franchise would be in direct competition. View "Sioux City Truck Sales, Inc. v. Iowa Department of Transportation" on Justia Law

The Supreme Court affirmed the decision of the district court affirming the conclusion of the workers' compensation commissioner that Claimant's rotator cuff injury was a scheduled shoulder injury rather than an unscheduled whole body injury under Iowa Code 85.34(2), holding that there was no error.Claimant sustained a work-related injury that was diagnosed as a "full thickness rotator cuff tear that has retracted to the level of the glenoid, severe AC arthrosis, tendonitis and tearing of the biceps tendon." In seeking permanent partial disability benefits, Claimant argued that her injury qualified as an unscheduled injury to the body as a whole, entitling her to industrial disability benefits. The commissioner concluded that Claimant's rotator cuff injury was a scheduled injury to the shoulder, and the district court affirmed. The Supreme Court affirmed, holding that the district court properly determined (1) Claimant's rotator cuff injury was a scheduled shoulder injury under Iowa Code 85.34(2)(n); and (2) substantial evidence supported the commissioner's finding that Claimant failed to prove her biceps tear resulted in a permanent disability to her arm under section 85.34(2)(m). View "Chavez v. MS Technology LLC" on Justia Law

The Supreme Court affirmed the decision of the district court affirming the declaratory order of the Iowa Department of Education interpreting a number of statutes and answering five questions posed by the Keystone Area Education Agency, holding that there was no error or abuse its discretion.The questions at issue concerned whether public agencies are required to release or excuse students to receive behavioral analysis therapy (ABA therapy) and, if so, under what circumstances. The Department's declaratory order determined, among other things, that the decision whether to excuse an absence for ABA therapy is generally up to the school district and that a public agency that does excuse attendance for therapy may violate federal law under some circumstances. The district court affirmed. The Supreme Court affirmed, holding (1) the Department had the authority to issue the declaratory order; and (2) the Department's declaratory order was supported by substantial evidence. View "Hills & Dales Child Development Center v. Iowa Department of Education" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the district court dismissing Appellants' petition for judicial review of the decision of the Iowa Public Information Board declining to order the disclosure of any records that had not previously been disclosed, holding that the district court erred in part.The open records requests at issue in this case stemmed from a 2015 incident in which a police officer responding to a 911 call about a domestic assault accidentally shot and killed one of the participants. The incident led to a civil lawsuit and also prompted the records requests. The family's attorney filed a complaint under the Iowa Public Information Board Act, but the Board declined to order disclosure of the requested records. The district court dismissed the family's attorney's petition for judicial review based on lack of standing and failure to exhaust administrative remedies. The Supreme Court held (1) the family's attorney exhausted administrative remedies by filing with complaint with the Board, but on judicial review, the attorney may only pursue open records requests that were actually raised before the Board and decided by it; and (2) the family's attorney did not have standing to seek the production of records that are now publicly available. View "Klein v. Iowa Public Information Board" on Justia Law

The Supreme Court affirmed the order of the district court granting Employer's motion to dismiss a petition for judicial review as untimely, holding that the district court correctly dismissed Claimant's petition for judicial review.Claimant sustained a work injury and pursued workers' compensation benefits. The workers' compensation benefits ordered Employer to pay temporary total disability benefits related to Claimant's right extremity injury but rejected Claimant's claim that she had also sustained a right shoulder occupational injury. According to Iowa Code 17A.19(3), Claimant had thirty day to file a petition for judicial review. Claimant's attorney failed to file the petition by the deadline. When the attorney realized his oversight, Claimant filed a petition for judicial review. The district court dismissed the petition as untimely. The Supreme Court affirmed, holding that the district court did not err. View "Askvig v. Snap-On Logistics Co." on Justia Law

The Supreme Court affirmed the order of the district court reversing the Iowa Board of Medicine declaratory order interpreting Iowa Code 272C.6(4)(a) as allowing the Board to publish statements of charges and press releases containing investigative information, holding that the district court did not err.The Board filed a statement of charges against Dr. Domenico Calcaterra accusing him of a "pattern of disruptive behavior and/or unethical or unprofessional conduct" and published the statement of charges against Dr. Calcaterra, along with a press release, on the Board's website. Several years after the parties reached a settlement, information about the allegations against Dr. Calcaterra remained available on the Board's website. Dr. Calcaterra filed a petition for declaratory order with the Board challenging that Board's ongoing dissemination of investigative information. The Board denied the challenge. The district court set aside the Board's order, holding that section 272.6(4)(a) prohibited the disclosure of the investigative information. The Supreme Court affirmed, holding that the Board incorrectly interpreted section 272C.6(4)(a) and that investigative information cannot be released to the public in a statement of charges or a press release when there has been no underlying final decision in the disciplinary proceeding. View "Calcaterra v. Iowa Board of Medicine" on Justia Law

The Supreme Court affirmed the district court's order sustaining a subpoena served on a state agency for various categories of information related to a potential transaction, holding that the subpoena was not invalid.The agency in this case (Agency) and a state institution (Institution) overseen by the Agency contacted Rob Sand, the Iowa Auditor of State (Auditor Sand), to discuss a transaction that was expected to create a multi-billion dollar obligation for the Agency. Auditor Sand requested information on the potential investors involved in the transaction, but the Agency refused to provide the information, asserting that it was confidential. Auditor Sand then served a subpoena on the Agency requesting thirteen categories of documents related to the transaction. The district court entered an order sustaining the subpoena. The Supreme Court affirmed, holding that, even though Auditor Sand was not actually engaged in an audit, the subpoena was valid. View "Sand v. Doe" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court upholding the ruling of the Property Assessment Appeal Board (PAAB) concluding that bins that primarily hold raw material until it is needed in the manufacturing process do not themselves constitute "machinery," holding that some, but not all, of the ingredient bins qualify for a tax exemption.At issue was when bins for holding ingredients qualify for a tax exemption as machinery used in manufacturing establishments under Iowa Code 427A.1(1)(e). The court of appeals disagreed with the PAAB's interpretation of the statute, finding that bins that are integrated into the manufacturing process and used for temporary storage of ingredients fell within the statutory exemption. The Supreme Court vacated the court of appeals' decision and reversed in part the district court's judgment, holding (1) customized overhead bins within a building where feed is manufactured constitute part of a continuous piece of machinery within that building; and (2) two large stand-alone corn silos, while connected by an underground conveyor to the feed manufacturing facility, do not meet the definition of machinery. View "Stateline Cooperative v. Iowa Property Assessment Appeal Board" on Justia Law