Justia Iowa Supreme Court Opinion Summaries

Chartis Insurance issued two workers' compensation insurance policies to Action Warehouse Company. Action, in turn, contracted with two tire companies to provide employees to operate tire warehouses owned by the companies and used exclusively to store the goods manufactured by the respective employers. Originally, Chartis classified the Action employees who staffed the warehouses under the National Council on Compensation Insurance (NCCI) classification code applicable to general warehouse employees. Later, Chartis retroactively and prospectively changed the employees' classification code to the code applicable to rubber tire manufacturing, resulting in a significantly higher premium. Action appealed. The NCCI Iowa workers' compensation appeals board ruled in favor of Chartis. The Iowa Insurance Commissioner reversed, and the district court affirmed. At issue before the Supreme Court was whether the Commissioner had the authority under Iowa Code 515A.1 to consider an as-applied challenge to a workers' compensation liability insurance rating schedule approved for use in accordance with Iowa law. The Supreme Court reversed, holding that the Commissioner did not have the authority to determine that a specific application of a plan approved under Iowa Code 515A.4 violated the statute's general purpose as outlined in section 515A.1 by being excessive, inadequate, or unfairly discriminatory. View "Chartis Ins. v. Iowa Ins. Comm'r" on Justia Law

Employee was injured while working for Employer and was awarded permanent partial disability benefits. Employee subsequently petitioned to review-reopen his workers' compensation claim, seeking additional workers' compensation benefits, seeking reimbursement for additional postarbitration medical expenses, requesting a determination of the amount of workers' compensation benefits still owed by Employer and its insurer, and asking the court to decide whether the workers' compensation commissioner needed to enter an additional order compelling payment to enforce an arbitration award for the unpaid benefits. The district court (1) rejected Employee's petition for review as untimely; (2) affirmed denial of reimbursement for some of Employee's medical expenses; and (3) did not provide the requested calculation but ruled that a compel-payment order was unnecessary because Employee could seek a judgment to enforce the award. The Supreme Court (1) reversed as to the statute of limitations for a petition for review-reopening; and (2) affirmed as to the judgment regarding which medical expenses were causally connected to the work-related injury. Remanded to the district court for it to remand the matter to the commissioner with directions to decide the issues regarding the amount still owed to Employee by Employer and its insurer under the arbitration award. View "Coffey v. Mid Seven Transp. Co." on Justia Law

Employee, who was injured while working for Employer, sought enforcement of an arbitration award he received from the workers' compensation commissioner against Employer and Employer's insurer. Employee requested the district court to determine the amount Employer and its insurer (collectively, Appellees) owed him under the arbitration award in light of Employee's claim that Appellees failed to pay all of the medical benefits, mileage reimbursements, and interest due under the arbitration decision. Appellees claimed a credit against any amount they owed Employee due to his third-party settlements. After a hearing, the district court declined to answer the issues raised by the parties and declined to determine the amount still owed to Employee under the arbitration decision, concluding that addressing the issues in Employee's petition required the district court to exceed its authority. The Supreme Court reversed and remanded to the district court for the court to remand the matter to the commissioner with directions to decide the issues Employee raised in his petition for judgment. View "Coffey v. Mid Seven Transp. Co." on Justia Law

Plaintiffs, farmers, purchased a Farm-Guard insurance policy from First Maxfield Mutual Insurance Association. Grinnell Mutual Reinsurance Company (Grinnell Mutual) reinsured the policy. Two years later, 535 of the hogs Plaintiffs were raising suffocated to death in Plaintiffs' building. Plaintiffs filed a claim with Grinnell Mutual to recover under the policy, but Grinnell Mutual denied the claim. Plaintiffs sued Grinnell Mutual for breach of contract. Both parties filed motions for summary judgment. The district court denied Grinnell Mutual's motion and granted Plaintiffs' motion based on the reasonable expectation doctrine. The court of appeals affirmed on alternative grounds, concluding the insurance policy was ambiguous and construing the ambiguity in favor of Plaintiffs. The Supreme Court reversed, holding (1) the policy was not ambiguous, and as a matter of law, the policy did not provide coverage; and (2) as a matter of law, the doctrine of reasonable expectations did not apply here. Remanded with instructions to enter judgment in favor of Grinnell Mutual. View "Boelman v. Grinnell Mut. Reinsurance Co." on Justia Law

This case involved a district court's denial of coverage under a fire insurance policy. A husband and wife had an insurance policy on their home. The policy included an intentional loss exclusion, voiding coverage when any insured intentionally causes a loss or damage. The district court denied coverage because the husband attempted suicide by pouring gasoline on himself and his home and lit himself on fire. The Supreme Court affirmed, holding (1) a coinsured who sets fire to the insured dwelling in order to commit suicide has the requisite intent to "cause a loss" under the policy; (2) under the language of the policy, the innocent coinsured spouse, who did not participate in the intentional acts of the other coinsured, cannot recover due to the intentional loss exclusion; and (3) the innocent coinsured cannot recover under the recently amended Iowa standard fire policy in Iowa Code 515.109. View "Postell v. Am. Family Ins. Co." 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

At issue in this case was (1) whether a life insurance agent owes a duty of care to the intended beneficiary of a life insurance policy, and (2) whether a life insurance agent can be liable for negligent misrepresentation when he provides information to the insured and the intended beneficiary regarding the beneficiary designation listed on the life insurance policy. The district court granted summary judgment in favor of the agent. The court of appeals affirmed. The Supreme Court reversed, holding (1) a life insurance agent owes a duty of care to an intended beneficiary of a life insurance policy; (2) a life insurance agent can be liable for negligent misrepresentation; and (3) genuine issues of material fact existed in this case, and therefore, summary judgment should not have been granted. Remanded. View "Pitts v. Farm Bureau Life Ins. Co." on Justia Law

At issue in this appeal was whether to judicially invalidate an insurance contract requirement that the insured file her lawsuit for underinsured motorist coverage (UIM) within two years of her auto accident. Plaintiff argued the deadline was unenforceable because, although she was still experiencing pain two years after the accident, only later did she discover the full extent of her injuries and realize her claim exceeded the other driver's liability limits. Plaintiff filed this UIM action against her insurer (Defendant) nearly six years after the accident. The district court granted Defendant's motion for summary judgment enforcing the contractual deadline as reasonable. The court of appeals reversed, holding the two-year limitation period was unreasonable under the circumstances. The Supreme Court vacated the court of appeals and affirmed the district court, holding that the two-year UIM insurance policy deadline was enforceable as a matter of law because it matched the two-year statute of limitations in Iowa Code 614.1(2) for personal injury actions. View "Robinson v. Allied Prop. & Cas. Ins. Co." 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

The Employment Appeal Board (Board) denied Willie Hall's application for unemployment insurance benefits. Hall filed a petition for judicial review. The district court affirmed the decision of the Board and assessed costs against Hall. The court of appeals affirmed. The Supreme Court reversed the portion of the judgment as it related to court costs, holding (1) pursuant to Iowa Code 96.15(2), any individual claiming benefits shall not be charged fees of any kind, including court costs, in a proceeding under the statute by a court or an officer of the court; and (2) therefore, the district court erred by requiring that Hall pay court costs. View "Hall v. Employment Appeal Bd." on Justia Law