Justia Iowa Supreme Court Opinion Summaries

A physician (Dr. Lindaman) participating in a child abuse assessment of a three-week-old infant (E.N.) treated E.N.’s broken arm and told the investigator for the Iowa Department of Human Services (DHS) that the father’s story of how the injury occurred was plausible. The investigator allowed E.N. to go home with E.N.’s parents. Three weeks later, E.N. suffered massive brain injuries while being cared for by his father. The father was subsequently found guilty of child endangerment. E.N.’s adoptive parents later filed this action individually and on behalf of E.N., alleging that Dr. Lindaman negligently failed to detect and report the child abuse and that Mercy Medical Center-Des Moines was vicariously liable for Dr. Lindaman’s negligence. Defendants moved for summary judgment, asserting that Dr. Lindaman participated in the DHS assessment in good faith and was therefore immune from liability under Iowa Code 232.73. The district court denied summary judgment. The Supreme Court reversed, holding that because undisputed facts established that Dr. Lindaman participated in good faith in the DHS assessment, Defendants were entitled to good-faith immunity under section 232.73. Remanded for the entry of summary judgment in favor of Defendants. View "Nelson v. Lindaman" on Justia Law

Wellmark, Inc., an Iowa-based health insurer that belongs to the national Blue Cross and Blue Shield (BCBS) network, contracted with health care providers in Iowa to provide services at certain reimbursement rates. Wellmark agreed to make those rates available both to self-insured Iowa plans that it administers and to out-of-state BCBS affiliates when those entities provide coverage for services provided in Iowa. Plaintiffs, a number of Iowa chiropractors, sued Wellmark, claiming that Wellmark had abused monopoly power in violation of the Iowa Competition Law. The Supreme Court affirmed the district court’s dismissal of some of the chiropractors’ antitrust claims and remanded on Plaintiffs’ remaining claims. On remand, Plaintiffs stipulated that their remaining antitrust claims regarding the agreements between Wellmark and both the self-insuring employers and the out-of-state BCBS affiliates were being asserted on a per se theory. The district court rejected Plaintiffs’ per se theories and entered summary judgment for Wellmark. The Supreme Court affirmed, holding that Wellmark’s arrangements with the self-insured employers and out-of-state BCBS licensees did not amount to per se violations of Iowa antitrust law. View "Mueller v. Wellmark, Inc." on Justia Law

In 2013, a child-in-need-of-assistance (CINA) petition was filed alleging that three minor children were in need. The guardian ad litem subsequently subpoenaed Mother’s therapist to testify at the CINA adjudicatory hearing regarding her mental health counseling of Mother. Thomas filed a motion to quash the subpoena, arguing that the information sought was confidential where Mother declined to waive the patient-psychotherapist privilege. The juvenile court concluded that Thomas must testify at the hearing. Thomas appealed, and the Supreme Court treated the appeal as a petition for writ of certiorari. The Supreme Court annulled the writ and remanded, holding that Iowa Code 232.96(5)’s statutory exception to the psychotherapist privilege in CINA adjudicatory hearings controlled in this CINA proceeding, and the juvenile court’s order enforcing the subpoena requiring Thomas to testify did not violate the confidentiality afforded mental health treatment under the Health Insurance Portability and Accountability Act (HIPAA). View "In re Interest of A.M." on Justia Law

At issue in this case was whether a mother who serves as the guardian for her intellectually disabled adult son must obtain court approval before arranging a vasectomy for him. Maria Kennedy was the legal guardian of Stuart Kennedy, a twenty-one-year-old man with intellectual disabilities who lived in a group home. In 2013, Stuart filed a petition to terminate the guardianship. Maria, in turn, petitioned for appointment of an involuntary conservator for Stuart. Concerned that Stuart was having sex with his coworker, Maria took Stuart to the doctor’s office to get a vasectomy. Stuart’s attorney subsequently filed a further petition to terminate or modify the guardianship because Maria had forced Stuart to undergo sterilization. After a combined hearing on the petitions, the probate court (1) declined to terminate Stuart’s guardianship, (2) found Maria did not violate Iowa Code 633.635(2)(b) by arranging for Stuart’s vasectomy without court approval, and (3) ordered Maria’s appointment as Stuart’s conservator. The Supreme Court (1) held that section 633.635(2) required Maria to get prior court approval for Stuart’s vasectomy; but (2) affirmed the guardianship and conservatorship orders entered by the probate court. View "In re Guardianship & Conservatorship of Kennedy" on Justia Law

The Iowa Board of Nursing and Iowa Department of Public Health (collectively, Defendants) enacted rules allowing advanced registered nurse practitioners (ARNPs) to supervise radiologic technologists using fluoroscopy machines. Several physician associates brought this action against Defendants to invalidate the rules. Two nursing associations intervened to defend the rules. The district court invalidated the rules, concluding that Defendants exceeded their authority in promulgating the rules. The Supreme Court reversed, holding (1) the Board's application of law to fact was not irrational, illogical, or wholly unjustifiable; (2) the rules fell within the authority of the Board and Department; and (3) the other challenges to the rules failed. Remanded. View "Iowa Med. Soc'y v. Iowa Bd. of Nursing" on Justia Law

Appellant pleaded guilty to first-degree harassment. While Appellant was incarcerated for the offense, the State sought to have him committed as a sexually violent predator (SVP) under Iowa Code 229A. A jury found Appellant was an SVP, and Appellant was ordered for commitment. The Supreme Court remanded the case. On retrial, the jury against concluded Appellant was an SVP, and Appellant was again ordered committed. The Supreme Court affirmed, holding (1) Appellant failed to meet his burden to show by a preponderance of the evidence that he was prejudiced by his counsel's advise to sign a speedy trial waiver; (2) Appellant was not prejudiced by his trial counsel's failure to adequately argue the trial should have been bifurcated to protect Appellant's due process rights; and (3) the prosecution did not misstate the evidence during trial. View "In re Detention of Blaise" on Justia Law

After Defendant was twice arrested and convicted of sexual offenses, proceedings were commenced for Defendant's commitment as a sexually violent predator. After a jury trial, Defendant was committed to the Civil Commitment Unit for Sexual Offenders (CCUSO). In 2010, Defendant submitted a petition seeking a final hearing on whether he should be discharged from the CCUSO or placed in a transitional release program. Thereafter, the State submitted its notice of annual review for 2011 asserting there was no evidence of any change in Defendant's mental abnormality constituting a ground for his discharge. Defendant subsequently filed a petition requesting a final hearing on his 2011 annual review and his claims for either discharge or placement in the transitional release program. The district court concluded Defendant failed to demonstrate by a preponderance of the evidence that he was entitled to a final hearing on either discharge or placement in a transitional release program. The Supreme Court affirmed, holding that the district court did not err in its judgment. View "Taft v. Dist. Court" on Justia Law

Respondent was incarcerated with an approaching release when the State filed a petition alleging Respondent was a sexually violent predator (SVP) under Iowa's civil commitment statute. After a jury trial, Respondent was found to be an SVP. The primary issue on appeal was whether the State properly waited until the conclusion of Respondent's overall prison term to bring an SVP proceeding, when Respondent received consecutive sentences for a sexual abuse offense and a burglary/arson offense, with the sentence for burglary/arson to be served after the sentence for the sexual abuse offense. The Supreme Court reversed, holding (1) a person receiving consecutive sentences, one of which is for a sexually violent offense, is "presently confined" within the meaning of the civil commitment statute, and thus, an SVP petition is timely filed if it is filed before the respondent's anticipated release from prison, as long as the current term of imprisonment includes a sentence for a sexually violent offense; (2) sufficient evidence supported the jury's verdict that Respondent was an SVP; but (3) it was error to admit expert testimony on the State's procedure for selecting persons against whom SVP proceedings are filed. View "In re Detention of Stenzel" on Justia Law

After Appellant's emergency hospitalization, a district court concluded that B.B. was seriously mentally impaired. Appellant was subsequently involuntarily committed. During the pendency of the appeal, Appellant was released to outpatient treatment at the University of Nebraska Medical Center (UNMC). Because the court file indicated Appellant was no longer a patient at UNMC, the State filed a motion to discharge and terminate the proceedings. The district court granted the motion, terminated the proceedings, and discharged Appellant from court-ordered treatment and placement. At issue on appeal was whether Appellant's appeal was moot when Appellant had been released and the proceedings terminated. The Supreme Court affirmed the judgment of the district court, holding (1) this appeal was not moot, as a person adjudicated seriously mentally impaired and involuntarily committed suffers adverse collateral consequences; and (2) substantial evidence supported the conclusion that Appellant was seriously mentally impaired. View "In re B.B." on Justia Law

In this putative class action, Plaintiffs were doctors of chiropractic who alleged they had been victimized by the discriminatory practices of Iowa's largest health insurer, Wellmark, Inc. The district court (1) granted Wellmark's motion to dismiss claims brought under Iowa's insurance regulatory statutes because no private cause of action was provided therein; (2) granted Wellmark's motion for summary judgment on Plaintiffs' antitrust claims based on the "state action" exemption found in Iowa Code 553.6(4); (3) granted summary judgment on claims alleging Wellmark breached its obligations under a judicially approved national class action settlement in Love v. Blue Cross Blue Shield Ass'n; and (4) granted summary judgment on several specific antitrust claims. The Supreme Court (1) reversed in part, holding that the district court erred in granting summary judgment on Plaintiffs' antitrust claims based on the state action exemption, as the record failed to establish the challenged conduct fell within the exemption; and (2) otherwise affirmed. Remanded. View "Mueller v. Wellmark, Inc." on Justia Law