Justia Iowa Supreme Court Opinion Summaries

At issue here was sex offenders serving prison time on a "revocation of release" from a "special sentence" under Iowa Code 903B.2 and whether the maximum time incarcerated was reduced by "earned-time credit" or "jail-time credit." Kris Kolzow began serving his ten-year special sentence released on parole. A parole violation prompted his detention for five and one-half months awaiting a parole-revocation hearing. The administrative parole judge ordered Kolzow to prison "to serve a period not greater than two years" as required by section 903B.2. The Iowa Department of Corrections (IDOC) refused to shorten Kolzow's prison time with earned-time credit or jail-time credit. The district court ruled that both credits applied to reduce the maximum two-year period served in prison on the revocation of release. The Supreme Court affirmed the ruling awarding Kolzow jail-time credit and reversed the ruling awarding him earned-time credit, holding (1) IDOC need not apply earned-time credit to shorten the period incarcerated on a revocation of release; and (2) an offender serving a special sentence under section 903B.2 is entitled to jail-time credit against the maximum periods for revocation of release for each day he is detained awaiting his parole-revocation hearing. View "Kolzow v. State" on Justia Law

Roger Ennenga was arrested for failing to stop his vehicle when police attempted to pull him over and for possession of methamphetamine. The State failed to file a trial information within forty-five days, and Ennenga's counsel did not file a motion to dismiss. Thereafter, Ennenga's counsel allowed him to plead guilty. At issue before the Supreme Court on Ennenga's application for postconviction relief was whether an indictment must be filed in order to be "found" for the purposes of Iowa R. Crim. P. 2.33, which requires the court to dismiss a prosecution if an indictment or trial information is not "found" within forty-five days of the defendant's arrest, and whether failing to ensure an indictment is timely filed amounts to the breach of an essential duty by an accused's counsel. The Court reversed the district court, holding that counsel breached an essential duty in failing to file a motion to dismiss the untimely trial information, and that counsel's failure resulted in prejudice to Ennenga by his plea of guilty. Remanded. View "Ennenga v. State" 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

Philip Vaughan and Arleen Wentworth divorced pursuant to a divorce decree that ordered Philip to pay child support until the couple's child, Allison, turned twenty-two if Allison continued a course of higher education. Philip later initiated the present proceeding, asserting that his child support obligation terminated when Allison reached eighteen. Arleene filed a cross-petition asking that Philip be required to pay the statutory maximum of postsecondary education subsidy under Iowa Code 598.21F. After both parties stipulated to certain facts, the litigation focused on whether the court should order Philip to also pay a postsecondary education subsidy and, if so, in what amount. The district court concluded that good cause existed for a postsecondary education subsidy and ordered both parents to pay the statutory maximum of one-third of the remaining cost of Allison's education. The court of appeals affirmed. Philip appealed. The Supreme Court (1) affirmed the determination that good cause existed for payment of a modest postsecondary education subsidy; but (2) reduced the amount awarded by the district court, holding that there was good cause to require Philip to provide a modest postsecondary education in this case. View "In re Marriage of Vaughan" on Justia Law

After a jury trial, Defendant Kenneth Madsen was convicted of two counts of sexual abuse in the second degree and one count of lascivious acts with a child. Madsen appealed, arguing (1) the district court erred in failing to suppress his confessions because his confessions were involuntary under the constitutional totality-of-the-circumstances test due to the detective's threat to make him late for work and promise that if Madsen confessed he could keep his name out of the newspaper and put the matter behind him; and (2) his counsel was ineffective for not attempting to suppress his confession under the common law evidentiary test for promises of leniency. The Supreme Court affirmed in part and reversed in part, holding (1) Madsen's trial counsel breached an essential duty by failing to move to suppress Madsen's confessions under the evidentiary test; (2) the interrogating officer made promises of leniency that required suppression of part of Madsen's confession, but Madsen's self-incriminating statements made before those promises remained admissible; and (3) Madsen was entitled to a new trial on one count of second-degree sexual abuse, but his two remaining convictions were affirmed based on lack of prejudice. View "State v. Madsen" on Justia Law

Plaintiffs, students or parents of students who attended Iowa public schools, filed a petition contending that Iowa's educational system was inadequate and urging the courts to impose additional public school standards, stating that such action was both constitutionally and statutorily required. Plaintiffs named as defendants the State, Governor, Department of Education, and Director of the Department. The district court dismissed Plaintiffs' petition, concluding (1) Plaintiffs had stated claims for relief under the equal protection and due process clauses, but their constitutional claims presented a nonjusticiable political question; and (2) their statutory claim under Iowa Code 256.37 failed because that provision did not afford a private right of action. The Supreme Court affirmed, holding (1) Plaintiffs' challenges were properly directed to Plaintiffs' elected representatives, rather than the courts; but (2) Plaintiffs did not state claims for relief under the Iowa Constitution or section 256.37. View "King v. State" 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

As part of an order approving the final report of the executor of the estate of Loren S. Bockwoldt, the district court approved extraordinary attorney fees for Pete Wessels and the law firm of Stanley, Lande and Hunter (SLH), attorneys for the estate. The extraordinary services contained in the application filed by Wessels and SLH were primarily for the defense of an earlier application for fees for extraordinary services that Wessels provided to the estate. The court also approved expenses. The court found that these attorney fees and expenses were for necessary and extraordinary services to the estate pursuant to Iowa Code 633.199. The court of appeals reversed, holding that attorney fees may not be awarded for litigating an application for attorney fees under chapter 633. The Supreme Court vacated the court of appeals and affirmed the district court in part and reversed in part, holding (1) extraordinary attorney fees may be awarded for defending a fee application in district court and on appeal; but (2) the case must be remanded for a hearing to determine the amount of fees to be awarded to SLH. View "In re Estate of Bockwoldt" 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

Defendant Anthony Polk confessed in a jailhouse interview to firing his handgun at the scene of a gang-related shooting that left two men with gunshot wounds. Polk filed a motion to suppress his conviction, contending that the interrogating police officer baited him into talking after Polk had invoked his Fifth Amendment right to remain silent and made improper promises of leniency that suggested by talking to police Polk could get a better deal and spend less time away from his children. The district court denied Polk's motion and convicted Polk of several weapon-related crimes. The Supreme Court reversed Polk's convictions and sentences, holding that the interrogating officer's promises of leniency rendered Polk's confession inadmissible, and therefore, the district court erred in denying Polk's motion to suppress. View "State v. Polk" on Justia Law