Justia Iowa Supreme Court Opinion Summaries

Plaintiff, an employee of BNSF Railway Company, was injured due to the railroad’s negligence. Because of his injury, Plaintiff was no longer able to work at his job. Plaintiff, who was almost fifty-nine years old, sued BNSF under the Federal Employers’ Liability Act (FELA) seeking $755,000 in economic damages, claiming that he planned to work until he was sixty-six years old. BNSF, in turn, attempted to introduce evidence that Plaintiff was eligible to retire on full benefits at age sixty and that most railroad employees in Plaintiff’s position retire at age sixty. The district court excluded the railroad’s evidence based on its reading of the federal collateral source rule applicable to FELA cases. A jury subsequently awarded $1.25 million, including pain and suffering, to Plaintiff. The Supreme Court reversed and remanded for a new trial on damages, holding (1) when a railroad employee makes a claim of lost earning capacity based on a hypothetical retirement age, federal law does not bar the introduction of evidence as to when railroad employees in the plaintiff’s position typically retire; and (2) BNSF was improperly precluded from presenting this excluded statistical evidence, and the error was not harmless. View "Giza v. BNSF Ry. Co." on Justia Law

Plaintiff’s truck was stopped at a red light when it was struck by Defendant’s car. Defendant saw the red light but claimed she didn’t see Plaintiff’s car. Later testing confirmed that Defendant had suffered a stroke that caused a partial loss of vision. During a jury trial, the district court allowed Defendant’s treating neurologist to testify that the stroke preceded the accident and submitted the defense of sudden emergency. The jury found Defendant was not negligent. The court of appeals reversed and remanded for a new trial, concluding (1) the evidence supported a defense of legal excuse, but (2) the trial court erred in instructing the jury on sudden emergency. The Supreme Court vacated the decision of the court of appeals and affirmed the district court’s judgment, holding (1) the district court did not abuse its discretion in allowing Defendant’s medical expert to testify; (2) the evidence was sufficient to submit a legal excuse defense based on Defendant’s sudden medical emergency; and (3) any error in the wording of the sudden emergency instruction was harmless. View "Hagenow v. Schmidt" on Justia Law

Plaintiff was the mother of a fourteen-year-old special education student, D.E. D.E. was raped by M.F., a nineteen-year-old special education student after the two students left school early. The sexual assault took place after school hours and off campus. Plaintiff sued D.E.'s school district (Kennedy) for damages, alleging Kennedy breached a duty of reasonable care. After a trial, the jury found Kennedy was negligent in failing adequately to supervise D.E. and awarded $500,000 in damages. The district court denied Kennedy's posttrial motion for judgment notwithstanding the verdict, concluding that Kennedy waived error on its claim that any failure to call the police was not a factual cause of D.E.'s injuries. The Supreme Court affirmed, holding (1) Kennedy failed to preserve error in the district court on the duty and factual causation issues raised on appeal; and (2) whether D.E.'s injuries were within Kennedy's scope of liability was an issue for the jury. View "Mitchell v. Cedar Rapids Cmty. Sch. Dist." on Justia Law

Defendant, a financial advisor to Decedent, was sued by identified beneficiaries of Decedent’s signed written estate plan. The beneficiaries alleged that Defendant was negligent in the performance of his duties, and therefore, the beneficiaries did not receive what they were supposed to receive under the plan. The district court granted summary judgment in favor of Defendant, concluding that Defendant, a non-attorney, owed no duty to the beneficiaries. The Supreme Court (1) reversed the judgment entered against plaintiff Steve Bristol and his spouse, holding that Bristol was owed a duty by Defendant and that Bristol raised a genuine of material fact as to whether Defendant’s negligent performance of his agency responsibilities caused Bristol not to receive a specific devise set forth in Decedent’s will; and (2) affirmed the judgment with respect to the charitable recipient plaintiffs, as their damages were too speculative to establish damages. View "St. Malachy Roman Catholic Congregation of Geneseo, Ill. v. Ingram" on Justia Law

The parties in this case, William and Steven Burkhalter, were the sons of Louis Burkhalter. William challenged an unfavorable modification of Louis's revocable trust that occurred just before Louis's death, claiming (1) Steven unduly influenced Louis and tortiously interfered with the trust, and (2) Louis lacked the necessary testamentary intent when he made the modification. The district court directed a verdict for Steven on the tortious interference claim, and the jury returned a verdict for Steven on the testamentary capacity and undue influence claims. The court of appeals remanded the case for a new trial on the undue influence claim, concluding that the district court erroneously instructed the jury on undue influence, and the error prejudiced William. The Supreme Court vacated the decision of the court of appeals and reinstated the jury verdict on the undue influence claim, holding that the district court's instruction accurately reflected the law of undue influence and did not unduly emphasize the causation element of the undue influence claim. View "Burkhalter v. Burkhalter" on Justia Law

Douglas Moad was driving his truck within the course of his employment with Employer when his truck was struck by an oncoming vehicle. Douglas died from his injuries. Employer maintained workers' compensation services with Dakota Truck Underwriters (DTU), a South Dakota corporation with its principal place of business in South Dakota. Employer also maintained motorist liability coverage with Northland Insurance Company (Northland). Douglas and his wife Sharon maintained insurance coverage with Property and Casualty Insurance Company of Hartford (Hartford). Sharon filed a petition seeking damages from Northland and Hartford for uninsured motorist benefits. DTU filed a notice of subrogation lien, asserting that it was entitled to reimbursement from any proceeds obtained by Sharon as a result of the damages action. Sharon reached a settlement agreement with Northland and Hartford. The district court approved the settlement and granted Sharon's motion to extinguish DTU's lien, concluding that in the event DTU's untimely filing of notice of its lien did not bar its interest, Iowa law applied and barred DTU's recovery. The Supreme Court reversed, holding that the district court utilized the wrong standard in resolving the conflict of laws question. View "Moad v. Dakota Truck Underwriters, Risk Admin. Servs., Inc." on Justia Law

A husband and wife applied for life insurance policies from Farm Bureau Life Insurance Company and later sued Farm Bureau for its alleged negligence in failing to notify them of their HIV-positive status. Farm Bureau settled the negligence claims, sued its insurers for indemnity, and sued its insurance broker for breach of contract and negligence in failing to provide timely notice to the insurers. The district court granted summary judgment (1) in favor of the insurers on the ground that Farm Bureau had failed to give them timely notice of the applicants' liability claims, and (2) in favor of the broker after concluding that even if the insurers had been given timely notice of the applicants' tort claims against Farm Bureau, coverage for those claims would have been precluded under two separate exclusions. In this appeal, Farm Bureau challenged the judgment in favor of the broker. The Supreme Court affirmed, holding that the underwriting exclusion would have precluded coverage for the applicants' claims even if the insurers had been timely notified under the policy's notice requirement. View "Farm Bureau Life Ins. Co. v. Holmes Murphy & Assocs., Inc." on Justia Law

Plaintiff filed a wrongful discharge suit against the State. The State moved to dismiss the action for failure to exhaust administrative remedies as required by the Iowa Tort Claims Act (Act). The district court granted the motion, holding that the claim was a tort subject to the Act. After an unsuccessful appeal, Plaintiff filed her lawsuit in district court a second time. The district court held that Plaintiff failed to comply with the statute of limitations and dismissed the second lawsuit. The Supreme Court reversed, holding that Plaintiff properly complied with the savings clause of the statute of limitations under the Act once the district court determined the Act provided the exclusive remedy for her claim. Remanded. View "Rivera v. Woodword Res. Ctr." on Justia Law

Plaintiff and Defendant were brother and sister. Defendant was a longtime resident of Maryland. Plaintiff allegedly lived in Iowa in 2003. After Plaintiff obtained employment in Iraq in 2003, he opened a checking account in Des Moines and provided Defendant with checks that could be used to draw on the account to provide for the needs of his children and to pay the bills. Instead of using the checks as agreed, Plaintiff claimed Defendant used the checks to withdraw funds for her personal use. Plaintiff filed a lawsuit against Defendant in Iowa district court for breach of contract, conversion, bad faith, fraud, and breach of fiduciary duty. The district court dismissed the complaint for lack of personal jurisdiction over Defendant, finding that sufficient minimum contacts were lacking. The Supreme Court reversed, holding that Defendant was subject to personal jurisdiction in Iowa under the Calder v. Jones foreseeable effects test based on the claim of an intentional tort in Iowa. Remanded. View "Shams v. Hassan" on Justia Law

Plaintiff sued Defendant, a bar, for injuries sustained when he was assaulted in the bar's parking lot. The district court granted summary judgment in favor of the bar, finding as a matter of law that the assault in the parking lot and Plaintiff's resulting injury were not foreseeable to the bar. The court of appeals reversed, holding that Defendant owed Plaintiff a duty and that Plaintiff had raised questions of fact as to foreseeability related to the issues of breach of duty and scope of liability. The Supreme Court affirmed, holding (1) the district court erred in concluding that Defendant, as a matter of law, could not have breached its duty of reasonable care; (2) a reasonable fact finder could conclude that Plaintiff's harm was within the appropriate scope of liability for Defendant; and (3) genuine issues of material fact remained regarding each element of Plaintiff's negligence claim, and summary judgment was therefore inappropriate. Remanded. View "Hoyt v. Gutterz Bowl & Lounge LLC" on Justia Law