Justia Iowa Supreme Court Opinion Summaries

Plaintiff, an agricultural supply company, was delivering its own products in a semi-trailer when the semi-trailer wrecked and spilled fertilizers and chemicals, contaminating several hundred cubic yards of soil. Plaintiff suffered a loss of almost $1 million due to the environmental remediation and for the value of the trailer and its contents. Plaintiff had been leasing the semi-tractor and its driver from another source at the time of the accident. Plaintiff, on behalf of itself and its insurer, filed suit against the lessors and their driver, alleging negligence and breach of contract. The district court granted summary judgment in favor of Defendants, concluding that the terms of the lease and Iowa Code 325B.1 barred any recovery by Plaintiff. The Supreme Court reversed, holding (1) section 325B.1 governs relations between authorized motor carriers and shippers and does not apply to the lease in this dispute because Plaintiff is a private carrier rather than a motor carrier; (2) the indemnification provisions in the lease are valid and enforceable; and (3) the anti-subrogation rule limits potential recovery in this case. View "United Suppliers, Inc. v. Hanson" on Justia Law

Plaintiff filed a tort claim with the state appeal board for wrongful death, alleging that the Iowa Department of Transportation’s negligent maintenance of a highway caused her husband’s death. The appeal board took no action on the claim for more than six months. Plaintiff finally withdrew the claim and filed suit in the district court, both individually and as administrator of her deceased husband’s estate. The district court dismissed the suit, concluding that Plaintiff had failed to exhaust administrative remedies before filing suit as administrator of the estate. The Supreme Court reversed, holding that Plaintiff exhausted her administrative remedies and properly presented her claim to the appeal board. View "McFadden v. Dep’t of Transp." on Justia Law

A fire severely damaged a restaurant that was owned by Plaintiffs. Plaintiffs made a claim to Defendant, the insurer of the restaurant, but Defendant denied the majority of the claim. Plaintiffs filed a breach-of-contract action against Defendant to recover under the insurance policy. A jury returned a verdict for Plaintiffs in the amount of $236,902. Defendant paid this amount plus interest and costs. Three months after judgment was entered, Plaintiffs filed this action against Defendant for “bad faith,” alleging that Defendant lacked an objectively reasonable basis for denying the claim. The district court granted Defendant’s motion for summary judgment, finding that the bad-faith action was barred by claim preclusion. The court of appeals reversed. The Supreme Court vacated the judgment of the court of appeals and affirmed the district court’s grant of summary judgment to Defendant, holding that, under the circumstances of this case, the final judgment in the breach-of-contract suit barred the later tort action for bad faith. View "Villarreal v. United Fire & Cas. Co." on Justia Law

Kevin Bryant, a salesperson at an auto dealership, was in the passenger seat of a car when Lori Parr, who was testing driving the car, made an illegal left turn, and the car was struck by a car driven by Robert Rimrodt. Bryant filed this lawsuit against Parr and Rimrodt, alleging that their negligence caused his personal injuries. The jury returned a special verdict finding Parr ninety-five percent at fault and Bryant five percent at fault. The jury initially awarded Bryant nearly $17,000 in past medical expenses but zero for pain and suffering. The parties agreed that the verdict was inconsistent, and the jury was instructed to resume deliberations to resolve the inconsistency. The jury subsequently awarded one dollar for pain and suffering but left the rest of the verdict unchanged. The court of appeals affirmed, concluding that the one dollar award remedied any inconsistency. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the district court, holding that the award of one dollar for pain and suffering was inconsistent with the award of nearly $17,000 for medical expenses incurred for the diagnosis and treatment of pain, and the inconsistency required a new trial. Remanded for a new trial on damages. View "Bryant v. Rimrodt" on Justia Law

Plaintiff was injured when he crashed his moped at a work site. Plaintiff sued Defendant, a contractor, alleging that his injuries were caused by the contractor’s negligence at the site. After a trial, the jury returned a verdict for Defendant, finding that Defendant was negligent but that his negligence was not the cause of Plaintiff’s damages. The court of appeals reversed and ordered a new trial, concluding that substantial evidence did not support the verdict. The Supreme Court vacated the judgment of the court of appeals and affirmed the judgment of the district court, holding (1) substantial evidence supported the jury verdict; (2) the jury’s answers to the verdict interrogatories were consistent with each other, and the jury’s verdict was consistent; (3) assuming the district court should have granted a directed verdict finding Plaintiff negligent, any such error was harmless; and (4) the district court did not abuse its discretion when it refused to grant Plaintiff’s motion for a new trial on the grounds that the verdict failed to administer substantial justice. View "Crow v. Simpson" on Justia Law

In 2010, two teenage boys drowned at the Pella Aquatics Center. Plaintiffs, the parents of the children, filed a claim for negligence against the City of Pella under the state-created danger doctrine. The district court granted summary judgment for the City on all of Plaintiffs’ negligence claims with one exception, concluding that the City was entitled to immunity under Iowa Code 670.4(12). The court denied summary judgment on that part of the claim in which the parents alleged that the City’s employee’s acts constituted the criminal offense of involuntary manslaughter. The Supreme Court reversed in part, holding (1) Plaintiffs adequately alleged that the City violated administrative rules constituting criminal offenses under the Iowa Code, and if the City violated these rules, is was not entitled to immunity; and (2) Plaintiffs must prove by a preponderance of the evidence that the City’s acts or omissions constituted involuntary manslaughter to remove it from the immunity granted by section 670.4(1). View "Sanon v. City of Pella" on Justia Law

Plaintiffs, Joseph and Suzanna Sanford, filed suit against a beach resort for damages resulting from an injury Joseph received during an assault committed by James Lawler when all the parties were guests of the resort. James was staying at the resort with his parents and siblings, and James’s father assumed responsibility for the cost of the family stay at the resort. As relevant to this appeal, Plaintiffs asserted dramshop liability claims against the resort. The district court granted summary judgment for the resort, concluding that no sale took place because James did not provide any consideration for the alcoholic beverages served to him. The Supreme Court reversed, holding that the district court erred in interpreting the word “sold” in Iowa Code 123.92(1)(a) to only apply to direct sales, as third-party beneficiaries fall within the rubric of a sale for purposes of section 123.92(1)(a), and the sale in this case encompassed the entirety of the contracted goods and services. View "Sanford v. Lawler" on Justia Law

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

Plaintiff brought a tort action against, among other defendants, a fellow university student (Defendant), claiming monetary damages for his injury. Plaintiff’s damage claim included damages for mental pain and mental disability. Defendant requested Plaintiff to provide him with a release, waiving Plaintiff’s privilege to his mental health records and allowing the student to access the mental health records pertaining to Plaintiff’s treatment for anger management while he was in elementary school. Plaintiff refused. The district court ordered Plaintiff to sign an unrestricted patient’s waiver for records, concluding that Plaintiff waived his privilege to his mental health records by putting his mental well-being at issue in this case and that Defendant’s request did not violate Plaintiff’s constitutional right to privacy. The Supreme Court reversed on interlocutory review upon adopting a protocol balancing a patient’s right to privacy in his or her mental health records against a tortfeasor’s right to present evidence relevant to the injured party’s damage claims. Remanded to the district court to allow the parties to present the appropriate evidence called for by this protocol and to apply the protocol before deciding if Defendant should sign a patient’s waiver. View "Fagen v. Grand View Univ." on Justia Law

An Iowa plaintiff sued a nonresident corporation (Defendant) for unfair competition and civil conspiracy. Defendant filed a motion to dismiss for lack of personal jurisdiction. The district court denied the motion, concluding that general jurisdiction was established because Defendant’s passive website held Defendant out as having a manufacturing facility in Sioux Center, Iowa. In fact, the Sioux Center facility was owned and operated by a separate Iowa defendant that supplied the product to Defendant. The Supreme Court affirmed the order denying Defendant’s motion to dismiss but on an alternative ground, holding (1) the district court erred by exercising general jurisdiction over Defendant based solely on the inaccurate statement on Defendant’s website, as there was no proof that Defendant was “essentially at home” in Iowa to establish general jurisdiction; but (2) the totality of Defendant’s contacts with Iowa were sufficient to subject it to specific jurisdiction on claims related to those contacts. View "Sioux Pharm, Inc. v. Summit Nutritionals Int’l, Inc." on Justia Law