Justia Iowa Supreme Court Opinion Summaries

The Iowa Right to Life Committee (IRTL) filed a complaint in the U.S. district court, alleging, inter alia, that Iowa's campaign finance laws unconstitutionally imposed political committee status on corporations whose major purpose was something other than nominating or electing candidates. The district court certified two questions to the Supreme Court. At issue before the Court was whether a corporation must form a political committee under Iowa law if it wants to spend more than $750 advocating the election or defeat of Iowa candidates. The Court answered that a corporation like IRTL may engage in express advocacy without forming a political committee because a corporation making independent expenditures aggregating over $750 in a calendar year becomes an "independent expenditure committee" within the meaning of Iowa Code 68A.404 but not a "political committee" within the meaning of Iowa Code 68A.102(18) or a "permanent organization" within the meaning of Iowa Code 68A.402(9). View "Iowa Right to Life Comm., Inc. v. Tooker" on Justia Law

The State charged Anthony Rodriguez with second-degree sexual abuse, willful injury, and domestic abuse assault. Ultimately, the district court dismissed the case due to a speedy trial rights violation. The court of appeals reversed. At issue on appeal was whether the State was entitled to an independent psychiatric evaluation of Rodriguez, a request the district court had denied. The Supreme Court affirmed the court of appeals and reversed the district court, holding (1) when a defendant puts at issue his mental capacity to knowingly, intelligently, or voluntarily waive his Miranda rights, the State is entitled to obtain an independent psychiatric evaluation of the defendant; (2) in order to protect the defendant's constitutional right against self-incrimination in these cases, the safeguards found in State v. Craney regarding the expert's testimony following the evaluation are applicable; and (3) the expert should not disclose to the State the same matters about which Craney prohibits an expert from testifying. Remanded. View "State v. Rodriguez" on Justia Law

Employer placed a security camera in his workplace to monitor Employee. Employer later installed the camera in the bathroom. Employee and her co-worker discovered the camera and brought suit against Employer for invasion of privacy. Specifically, the employees alleged that Employer's actions fell under the intrusion upon seclusion alternative of the invasion-of-privacy tort. The district court granted Employers' motion for summary judgment, finding insufficient evidence supporting the element of intrusion. The court of appeals reversed. The Supreme Court affirmed the court of appeals and reversed the district court order granting summary judgment in favor of Employer based on the reasoning in Koeppel v. Speirs. Remanded. View "Miller v. Speirs" on Justia Law

Employer secretly installed surveillance equipment in a workplace bathroom. Employee filed a claim for damages against Employer for invasion of privacy and sexual harassment. The district court granted summary judgment for Employer on both claims, holding, inter alia, that although Employer intended to view Employee in the bathroom, the tort of invasion of privacy required proof the equipment had worked and Employer had viewed the plaintiffs. The court of appeals reversed, finding the evidence of intrusion was sufficient to survive summary judgment. The Supreme Court granted further review on the issue involving invasion of privacy and affirmed, holding that the district court erred in granting Employer's motion for summary judgment where an electronic invasion occurs under the intrusion on solitude or seclusion component of the tort of invasion of privacy when the plaintiff establishes by a preponderance of evidence that the electronic device or equipment used by a defendant could have invaded privacy in some way. View "Koeppel v. Speirs" on Justia Law

The State charged Daniel Rainsong with theft in the first degree, dependent adult abuse and habitual offender. The State alleged Rainsong stole $15,000 each from his mother, a dependent adult who passed away, and her husband, Loren Radford. The State later noticed the deposition of Radford, but Rainsong refused to attend the deposition. The State proceeded to take the deposition of Radford without participation by Rainsong. When the State attempted to introduce the deposition at trial, the district court denied the request. The Supreme Court granted interlocutory review and affirmed, holding that the district court correctly decided not to allow the State to introduce at trial the statement contained in Radford's noticed deposition because (1) Iowa R. Crim. P. 2.13 did not authorize the taking of the deposition; and (2) therefore, the noticed deposition was nothing more than a sworn affidavit, and its admission would violate Rainsong's right to confrontation as guaranteed by the Confrontation Clause. View "State v. Rainsong " on Justia Law

The board of directors of a nonprofit condominium association approved necessary but nonemergency repairs to the association's parking garage without a full vote by its members. The repairs were completed at an amount eight times greater than the theshold in the bylaw, which required preapproval of a supermajority of owners to authorize certain expenditures exceeding $25,000. Several condominium owners sued for a judicial declaration that the board's violation of the bylaw's preapproval requirement excused their obligation to pay. The association counterclaimed against the owners to collect their share of the completed repairs and for attorney fees. The district court ruled in favor of the owners. The Supreme Court reversed, (1) holding that the business judgment rule applies to the governance decisions of this board when it acts within its authority; and (2) because the bylaw at issue was ambiguous, the Court deferred to the board's authority under the governing declaration to decide questions of interpretation or application of the bylaws. Remanded. View "Oberbillig v. W. Grand Towers Condo. Ass'n" on Justia Law

Employee injured her right ankle when she slipped and fell during the course of her employment. Employer later terminated Employee's employment. Employee filed a claim with the workers' compensation commission seeking benefits as a result of her alleged injuries. The commissioner ruled in favor of Pease, concluding that she suffered an injury to the body as a whole and that her work injury was a substantial contributory factor in her state of depression. The commissioner awarded Pease permanent total disability, accrued benefits, and reimbursement for medical expenses. The district court affirmed the commissioner's findings of fact with respect to the causation of Employee's mental and physical injuries and held that substantial evidence supported the commissioner's findings regarding disability. The court of appeals reversed the award, finding substantial evidence did not support the commissioner's findings on causation. The Supreme Court vacated the court of appeals and affirmed the district court, holding that the commissioner's findings of fact were supported by substantial evidence. View "Cedar Rapids Cmty. Sch. Dist. v. Pease" on Justia Law

Wild Rose Entertainment and Signature Management Group (SMG) entered into an agreement that delineated the parties' relationship with regard to future state casino projects. After Wild Rose was awarded a gaming license to develop a casino in Emmetsburg, it terminated the agreement. SMG sued Wild Rose for breach of contract, and a jury found Wild Rose breached the agreement. During the Emmetsburg action, Wild Rose was awarded a gaming license to develop a casino in Clinton. SMG then filed a separate action against Wild Rose, alleging that it breached paragraph 5A of the agreement by failing to negotiate in good faith with SMG for the management of the Clinton casino. Paragraph 5A was litigated in the Emmetsburg action. The district court granted summary judgment for Wild Rose, concluding the doctrine of claim preclusion barred SMG's current claim. The court of appeals affirmed after finding Wild Rose repudiated the entire agreement, which required SMG to seek damages for all remaining rights of performance under the contract in the first lawsuit. The Supreme Court affirmed, holding (1) no genuine issue of material fact existed as to whether Wild Rose repudiated the agreement, and (2) the doctrine of claim preclusion barred the action. View "Pavone v. Kirke" on Justia Law

Jose Aguilera was convicted of second-degree murder. In his second application for postconviction relief, Aguilera contended that he was denied due process when the prosecution failed to turn over an Iowa Division of Criminal Investigation file containing several witness statements prior to Aguilera's initial trial. The district court found the material was suppressed and that it was favorable but that it was not material to the issue of guilt and dismissed the application. The court of appeals affirmed. The Supreme Court vacated the court of appeals and reversed the district court, holding that because the suppressed, favorable statements that were not turned over by the State had a reasonable probability of impacting the outcome of the trial, a Brady violation occurred, and Aguilera's due process rights were violated. Remanded. View "Aguilera v. State" on Justia Law

Matthew Elliott was found guilty by a jury of willful injury causing serious injury and child endangerment resulting in death. The court of appeals affirmed. At issue on appeal was whether the district court erred in allowing hearsay testimony from a detective when it allowed the detective to testify about a certain interview. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the district court, holding that the disputed testimony was hearsay, and the error was not harmless because the improper admission of the hearsay evidence was prejudicial to Elliott's substantive rights. Remanded for a new trial. View "State v. Elliott" on Justia Law