Justia Iowa Supreme Court Opinion Summaries

Patient filed suit against Doctor for malpractice and Hospital for negligent credentialing. During trial, Hospital produced Doctor's credentialing file, which was admitted into evidence. The jury returned a verdict in favor of Patient. The Supreme Court reversed, concluding that evidence admitted at trial concerning Doctor's disciplinary hearing was confidential and should have been excluded. Meanwhile, the court of appeals decided Day v. Finley Hospital, which held that the contents of a credentialing file fell within Iowa Code 147.135's peer review protection. On remand, Hospital filed a motion for summary judgment, arguing that Doctor's previously produced credentialing file was inadmissible and that, without the documents, Patient lacked sufficient evidence to establish a prima facie case. The district court granted the motion. The Supreme Court affirmed, holding (1) the law of the case did not bar Hospital from objecting to the use of Doctor's credentialing file on remand for retrial because the Court's earlier opinion did not expressly or impliedly decide the admissibility of the credentialing file; and (2) section 147.135(2) sets forth not only a privilege but a separate rule of inadmissibility, so principles of waiver did not foreclose the district court from revisiting the admissibility of the credentialing file. View "Cawthorn v. Catholic Health Initiatives Iowa Corp." on Justia Law

Husband obtained a purchase-money mortgage from Bank to invest in commercial real estate. Wife's signature was forged in executing the purchase-money mortgage. After Husband's death, Bank attempted to foreclose its mortgage, but Husband's Estate and Wife asserted Wife's fraudulent signature voided the mortgage. The district court (1) granted Bank summary judgment, concluding its purchase-money mortgage was superior to Wife's statutory dower interest and the Estate's other debts and charges; and (2) ordered any excess sale proceeds to be paid to the Estate. The court of appeals (1) affirmed the award of summary judgment; but (2) reversed the district court's determination that the foreclosure sale surplus be paid to the Estate, instead holding that Wife's statutory dower interest took priority over the Estate's other debts and charges. The Supreme Court affirmed the court of appeals, holding that a surviving spouse's dower interest, codified in Iowa Code 633.211 as to nonhomestead real property, was not subject to the debts and charges of the Estate of the spouse who died intestate. View "Freedom Financial Bank v. Estate of Boesen " on Justia Law

Plaintiff, City of Riverdale, spent sixteen months in district court litigating wither Defendants, several individuals, were entitled to view security camera video of a confrontation with the mayor over earlier records requests at the city clerk's counter. The mayor filed a declaratory judgment action at the advice of a junior attorney even though a senior partner attorney earlier advised the mayor to produce the recordings. The trial court ordered the City to turn over a copy of the videotape and awarded Defendants attorney fees. The court of appeals vacated the fee award because the district court made no finding of bad faith on the part of the City. The Supreme Court vacated the court of appeals and affirmed the district court, holding (1) Iowa Code 22.10(3)(c) required the City to pay Defendants' reasonable attorney fees because the district court found the City violated the statute by withholding the video; and (2) the district court did not err by implicitly rejecting the City's good-faith, reasonable delay defense notwithstanding the City's reliance on advice of legal counsel. Remanded. View "City of Riverdale v. Diercks" on Justia Law

Stevie Harrington was sentenced to forty years incarceration after he pled guilty to and was convicted of several drug-related offenses. His sentence included a mandatory sentence enhancement for being in the immediate possession of a firearm. The court of appeals remanded for resentencing, concluding that there was insufficient evidence to support the sentencing enhancement and the district court had relief on improper factors for imposing sentence. On resentencing, the district court sentenced Harrington to a total of thirty years. The sentences included two sentence enhancements that the district court did not apply in Harrington's original sentence. Harrington appealed, contending that, although his overall sentence decreased, because the district court applied the new sentencing enhancements, he was entitled to a presumption of judicial vindictiveness under North Carolina v. Pearce. The court of appeals affirmed. The Supreme Court affirmed, holding that because Harrington received a shorter overall sentence on resentencing for his convictions, the presumption of judicial vindictiveness did not apply. View "State v. Harrington" on Justia Law

Krisha Bowman, a single mother of three minor children, received Section 8 housing assistance for several years. The Des Moines Municipal Housing Agency (DMMHA) later discontinued Bowman's housing assistance based on five alleged occurrences of unreported income. A hearing officer found that Bowman's assistance had been properly terminated. The district court affirmed. The Supreme Court affirmed, holding (1) DMMHA's determination that Bowman had five occurrences of unreported income was supported by substantial evidence; (2) DMMHA's policy of treating a failure to report each child's Social Security benefits as a separate occurrence of unreported income did not violate the Fair Housing Act; and (3) DMMHA did not improperly fail to consider Bowman's mitigating circumstances before terminating her assistance. View "Bowman v. City of Des Moines Mun. Hous. Agency" on Justia Law

Randall Pals' vehicle was searched during a traffic stop to investigate an ongoing minor infraction of a municipal ordinance. The police officer discovered marijuana. Pals moved to suppress the evidence, challenging the legality of the traffic stop and search. The district court denied the motion, and Pals was convicted of possession of a controlled substance. The court of appeals affirmed. The Supreme Court vacated the court of appeals and reversed the district court, holding that the district court erred by refusing to grant Pals' suppression motion where (1) the police officer had probable cause to believe that Pals was committing an ongoing civil offense, and therefore, the initial traffic stop was legal; but (2) pursuant to an application of the Iowa version of the U.S. Supreme Court's Schneckloth v. Bustamonte totality of the circumstances test, Pals' consent to search his vehicle was not voluntarily under the Iowa Constitution. Remanded. View "State v. Pals" on Justia Law

Homeowners filed suit against Contractor, asserting claims for defamation and illegal collection practices. After a trial, the jury rejected Homeowners' claims and awarded Contractor damages for its breach of contract counterclaim. Homeowners filed a motion for a new trial, arguing that Contractor committed misconduct by giving false testimony and fabricating an exhibit in order to support that testimony. Homeowners recognized the flaws in the exhibit before the case was submitted to the jury, but instead of alerting the court, decided to argue those flaws to the jury during the rebuttal stage of closing argument. The district court granted the motion. The court of appeals reversed the district court's order granting a new trial. The Supreme Court affirmed, holding that the district court abused its discretion in granting a new trial where (1) the district court did not lack authority to grant a new trial simply because the objection to the exhibit could have been raised earlier and was not; but (2) considering all the circumstances, including the absence of real misconduct or prejudice and Homeowners' decision to wait until rebuttal argument to bring forward its concerns, the district court abused its discretion in granting a new trial. View "Loehr v. Mettille" on Justia Law

Appellant Deng Kon Tong was convicted of being a felon in possession of a firearm in violation of Iowa Code 724.26. The court of appeals affirmed. Appellant appealed, claiming the district court erred in denying his motion to dismiss the charge because he had not been convicted of any felony at the time he allegedly possessed the firearm. Although Tong had pled guilty to a felony earlier the same year he was convicted in the instant case, he received a deferred judgment and a term of probation that had not been revoked. The Supreme Court affirmed, holding that the wording of section 724.26 indicated that the legislature intended the term "convicted of a felony," as used in that statute, to include a deferred judgment where Appellant had not successfully completed the term of his probation. View "State v. Tong" on Justia Law

Based on his guilty plea, Orlando Rodriguez was convicted for reckless vehicular homicide for an incident in which Rodriguez was an active participant in a drive-away theft of gasoline. Rodriguez was not driving the car when the accident occurred. Rodriguez appealed, claiming (1) he received ineffective assistance of counsel because there was no factual basis to support his plea; and (2) the district court imposed an illegal sentence by levying a $125 law enforcement initiative surcharge. The court of appeals affirmed Rodriguez's conviction but vacated his sentence with respect to the surcharge. The Supreme Court affirmed, holding (1) a passenger can be responsible as a party to the crime under a joint criminal conduct theory; (2) this case had a factual basis to support Rodriguez's plea, and Rodriguez's counsel was not ineffective for failing to challenge it; and (3) the district court had no statutory authority to apply a fine for a law enforcement initiative surcharge to vehicular homicide. View "State v. Rodriguez" on Justia Law

Appellant David Daughenbaugh pled guilty to criminal charges in exchange for the State's promise not to oppose Appellant's request for a deferred judgment. The district court accepted Appellant's request for a deferred judgment, placed him on supervised probation, and imposed civil penalties. Appellant subsequently filed an application for postconviction relief, alleging ineffective assistance of counsel. The State filed a motion for summary judgment, asserting that Appellant had not been "convicted" for purposes of postconviction relief. The district court held (1) Appellant was entitled to file a claim for postconviction relief because Appellant's guilty pleas amounted to convictions even though he received a deferred judgment; and (2) counsel was not ineffective. The Supreme Court affirmed but for different reasons, holding (1) a guilty plea pursuant to a deferred judgment is not a "conviction" under Iowa's postconviction statute; and (2) therefore, Appellant was not entitled to postconviction relief. View "Daughenbaugh v. State" on Justia Law