Justia Iowa Supreme Court Opinion Summaries

In this real estate dispute, some of the defendants filed a motion for sanctions, alleging Defendant brought the action to harass, cause unnecessary delay, and needlessly increase the cost of litigation. The district court ordered sanctions against Plaintiff's counsel for $1,000. The court of appeals affirmed the sanctions, ordering them payable to the jury and witness fund. The Supreme Court affirmed in part and vacated in part the court of appeals, holding (1) the district court did not abuse its discretion in fixing the amount of the sanction at $1,000; (2) the court abused its discretion by ordering the sanction be paid to the jury and witness fund; and (3) given Rule 1.413(1)'s preference of compensating victims, the district court should enter an order requiring Plaintiff's counsel to pay the sanction in equal sums to the defendants who sought the sanction as partial reimbursement of the legal fees they incurred in defending against the unfounded claims brought against them. Remanded. View "Rowedder v. Anderson" on Justia Law

After the State filed a child in need of assistance (CINA) petition, the juvenile court issued a temporary removal order removing Child from Mother's custody and placing her in foster care. Once the CINA proceeding was dismissed, Mother sued the State and two employees of the Iowa Department of Human Services (DHS) under 42 U.S.C. 1983 and the Iowa Tort Claims Act (ITCA), alleging the DHS social workers wrongfully removed Child from her custody and negligently failed to protect Child from abuse. The district court granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding (1) a social worker is entitled to absolute immunity when the social worker functions in the role of a prosecutor or ordinary witness; (2) a social worker is entitled to qualified immunity when acting in the role of a complaining witness, and for his or her investigatory acts; (3) alleged injured parties cannot maintain an action against a social worker under the ITCA where the alleged parties fail to exhaust the available administrative remedy prior to filing an action in court and where the basis of the complaint is that the social worker engaged in conduct functionally equivalent to misrepresentation or deceit. View "Minor v. State" on Justia Law

Defendant, an alleged embezzler, entered an Alford plea to first-degree theft and entered a deferred judgment on that charge. The subrogated insurer (EMCC) of Defendant's employer brought a civil action against Defendant to recover $66,749 it paid on the theft loss. The district court entered summary judgment in favor of EMCC in that amount, concluding that Defendant's Alford plea precluded her from denying the theft or the amount. Defendant appealed, contending her deferred judgment should have no res judicata effect in the civil case. The Supreme Court affirmed the district court's summary judgment establishing Defendant's liability to EMCC for damages of $10,000 based on issue preclusion and reversed the summary judgment in excess of $10,000, holding (1) the victim of a crime or the victim's subrogated insurer may invoke the doctrine of issue preclusion in a civil action based on the defendant's Alford plea regardless of whether the defendant successfully complies with the conditions for the deferred judgment on the criminal charge; but (2) the preclusive effect of Defendant's Alford plea is limited to $10,000, the minimum amount required to support a charge of first-degree theft, and genuine issues of material fact precluded summary judgment in excess of $10,000. View "Employers Mut. Cas. Co. v. Haaften" on Justia Law

This case presented the question of whether an individual who made voluntary expenditures based on a mother's fraudulent representation that the individual had fathered her child has a cause of action against the mother for recovery of those payments. The district court granted the mother's motion to dismiss the action. The Supreme Court reversed the district court, holding that such a cause of action may be pursued because it is consistent with traditional concepts of common law fraud, there is no prevailing public policy reason against recognizing such a cause of action, and Iowa's statutes do not speak to the issue. Remanded. View "Dier v. Peters" on Justia Law

At issue in this case was whether a subcontractor that properly performs electrical work on a jobsite, then locks up the work and transfers control to the property owner, owes a duty of care to an employee of the owner electrocuted six days later when the owner fails to deenergize the work site in contravention of various warnings and regulations. The district court granted summary judgment to the subcontractor, holding that the subcontractor owed no duty to the employee because it did not have control of the switchgear box when the employee was injured. The court of appeals reversed. The Supreme Court vacated the court of appeals and affirmed the district court, holding that, under the circumstances, the subcontractor owed no duty of care to the employee. View "McCormick v. Nikkel & Assocs." on Justia Law

Employee sought workers compensation benefits after receiving two injuries at her place of employment. While working for Employer, Employee received a salary increase of $1000. Although Employee received a salary increase of $1000 per month for more than a year, Employer claimed the increase was supposed to have been $1000 per year. The deputy commissioner calculated a weekly compensation rate based on the $1000 per month raise Employer actually paid Employee. The district court reversed and instead used the $1000 per year figure Employer claimed was accurate. The court of appeals reversed and determined that the $1000 per month raise should be included in the calculation of Employee's compensation rate. The Supreme Court vacated the court of appeals and remanded the case for a factual determination as to Employer's claim that it accidentally overpaid Employee $916 per month. View "Burton v. Hilltop Care Ctr." on Justia Law

Plaintiffs sued a surgeon, alleging negligent performance of a pancreaticoduodenectomy, and a hospital, contending it negligently granted credentials to the surgeon. The district court entered judgment in favor of Defendants after concluding that the tort of negligent credentialing was a viable claim in Iowa. Plaintiffs appealed, contending the district court applied the wrong standard of care in adjudicating Plaintiffs' claim of negligent credentialing against the hospital. The Supreme Court affirmed, holding (1) the district court applied the standard of care advocated by Plaintiffs; and (2) substantial evidence supported the district court's conclusion that the hospital did not breach the standard of care. View "Hall v. Jennie Edmundson Memorial Hosp." on Justia Law

Employee injured his shoulder while working for Employer. Employer offered Employee light-duty work in Des Moines, which was 387 miles from Employee's residence. Employee declined Employer's offer to perform light-duty work, and as a result, Employer suspended Employee's workers' compensation benefits. Employee filed a workers' compensation claim. The workers' compensation commissioner concluded (1) Employer improperly suspended temporary disability benefits where Employer failed to offer Employee suitable work because the job was located a great distance from Employee's residence; and (2) Employee experienced a sixty percent industrial disability. The district court reversed in part, concluding that Employer offered Employee suitable work and thus, Employee forfeited his right to benefits during his period of refusal. The Supreme Court reversed in part, holding (1) the commissioner did not err in finding Employer failed to offer Employee suitable work; and (2) the commissioner's findings with respect to the extent of Employee's industrial disability were supported by substantial evidence. View "Neal v. Annett Holdings, Inc." on Justia Law

Employee filed a petition with the state workers' compensation commissioner, alleging that he suffered an injury to his shoulder while working for Employer and that his injury caused a permanent disability. The workers' compensation commissioner concluded that Employee failed to prove his claimed permanent disability was causally related to his work injury. The district court and court of appeals affirmed. The Supreme Court affirmed, holding (1) because an award for partial permanent disability for an unscheduled injury under Iowa Code 85.34(2)(u) is determined by industrial disability, rather than by functional impairment, the commissioner used the correct standard to determine the causal relation between the work injury and the alleged disability; and (2) furthermore, substantial evidence supported the commissioner's findings. View "Westling v. Hormel Foods Corp." on Justia Law

This case involved a dispute between Insured and Insurer regarding underinsured motorist benefits. The district court denied Insurer's motion for summary judgment and entered judgment in favor of Insured with interest running from the date Insured filed his action against Insurer. Insured filed a motion to modify the judgment, asking the court to amend the judgment to start the running of interest from the date Insured filed his action against the original tortfeasors. The district court granted the motion and modified the judgment. The court of appeals affirmed. The Supreme Court (1) found that the order denying Insurer's motion for summary judgment was not reviewable; (2) vacated the court of appeals; (3) affirmed the district court's judgment required Insurer to pay its underinsured motorist limit to Insured; and (4) reversed the part of the judgment awarding interest from the date Insured filed the original action against the tortfeasors, holding that Insured failed to timely file his posttrial motion and that the district court erred when it considered the motion. Remanded. View "Estes v. Progressive Classic Ins. Co." on Justia Law