Justia Iowa Supreme Court Opinion Summaries

Evercom Systems provided telephone services to inmates in correctional facilities throughout the country. When Evercom billed a customer for collect calls he did not accept, the customer lodged a complaint to the Iowa Utility Board. The Board imposed a civil penalty for a "cramming" violation based on improper billing for collect telephone calls under Iowa Code 476.103 and Iowa Admin. Code r. 199-22.23. The district court reversed the agency's decision and imposition of the civil penalty, concluding that the Board misinterpreted the law and that no cram occurred. The court of appeals reversed the district court and reinstated the civil penalty. The Supreme Court vacated the court of appeals and affirmed the district court, holding that Evercom's actions did not constitute a cram under rule 199-22.23. Remanded for dismissal. View "Evercom Sys., Inc. v. Utils. Bd." on Justia Law

Following a jury trial, Robert Krogmann was convicted for attempted murder and willful injury. On appeal, Krogmann contended that (1) the district court erred in granting the State's pretrial request to freeze all his personal assets and requiring that he apply to the court for permission to use those assets for his legal defense, and (2) the prosecutor committed reversible misconduct by asking an inflammatory question at trial. The Supreme Court affirmed, holding (1) while the Court had concerns about the propriety of the asset freeze, Krogmann failed to preserve error on this issue; and (2) error was not preserved as to the incident of asserted prosecutorial misconduct, and this incident would not have amounted to reversible error in any event. View "State v. Krogmann" on Justia Law

Defendant Carson Walker was charged with operating a motor vehicle while intoxicated (OWI). After he was arrested, Walker requested to speak to his lawyer. While consulting, Walker and his lawyer talked through an intercom in a booth separated by a glass partition and were monitored by a police video camera. After conferring with his lawyer, Walker took a breath test, which measured Walker's blood level at more than double the legal limit. At trial, Walker moved to suppress the breath-test results based on the alleged violation under Iowa Code 804.20 to "see and consult confidentially" with his attorney "alone and in private." The district court granted the motion. On interlocutory appeal, the court of appeals reversed. The Supreme Court vacated the court of appeals and affirmed the district court's ruling suppressing the breath-test results, holding that the police violated Walker's section 804.20 rights by restricting his attorney conference to the booth with the glass partition under videotaped surveillance. View "State v. Walker" on Justia Law

Defendant Jesse Pearson, a seventeen-year-old, robbed and beat an elderly man. After he was apprehended, Pearson refused to waive his Miranda rights. The next morning, however, he confessed to his social worker, Marie Mahler, without his attorney present. The district court denied Pearson's motion to suppress his confession, concluding that Mahler's interview was not a custodial interrogation implicating Miranda safeguards. A jury convicted Pearson of first-degree robbery, willful injury, and going armed with intent. The court of appeals reversed Pearson's conviction on the going armed charge and otherwise affirmed. At issue on appeal was whether Pearson's confession to Mahler was admissible. The Supreme Court affirmed, holding that Mahler's interview of Pearson was not a custodial interrogation for Miranda purposes and that his confession to her was voluntary and admissible. View "State v. Pearson" on Justia Law

In this condemnation case, Plaintiffs brought an action against the Iowa Department of Transportation (IDOT) and the State. IDOT's motion to dismiss was granted. Subsequently, the district court granted summary judgment for the State, concluding that Plaintiffs' exclusive remedy was a mandamus action to compel condemnation proceedings. The court then dismissed the first action. Before the district court had entered its summary judgment ruling, Plaintiffs petitioned for writ of mandamus against IDOT in a second action. After the court granted summary judgment for the State, IDOT filed a motion for summary judgment, arguing that the dismissal of the first action barred Plaintiffs from bringing the second action under both claim and issue preclusion. The district court disagreed and granted Plaintiffs' requested writ of mandamus. Defendants appealed on the issue of claim preclusion. The Supreme Court affirmed, holding that when a court order dismissing an action reveals the court's intent to preserve a claim arising out of the same transaction that is pending in another lawsuit, the claim in the other lawsuit should be allowed to proceed. View "Lambert v. Dep't of Transp." on Justia Law

Plaintiff brought a personal injury action arising out of an automobile accident then voluntarily dismissed the action eleven days prior to trial in order to further develop expert testimony on the extent of permanent injuries caused by the accident. Two months later, Plaintiff refiled the action. The district court granted summary judgment to Defendant, holding that Iowa's savings statute was inapplicable under the facts of the case. The court of appeals affirmed. The issue on appeal was whether the voluntary dismissal of Plaintiff's claim under the circumstances met the savings statute requirement that the claim "fails" without "negligence in its prosecution." The Supreme Court affirmed, holding that Plaintiff's claim did not meet the requirements of the savings statute and that the district court properly granted summary judgment for Defendant. View "Furnald v. Hughes" on Justia Law

A jury found Defendant Robin Brubaker guilty of operating while intoxicated, fourth offense, and unlawful possession of a prescription drug. On appeal, Defendant contended that the district court erred by denying his motion to suppress evidence found in his car when officers searched it after his arrest and that his trial counsel was ineffective for failing to object specifically to the sufficiency of the evidence offered by the State regarding the charge of unlawful possession of a prescription drug. The Supreme Court reversed the judgment for unlawful possession of a prescription drug and remanded the case for dismissal of that charge, holding that trial counsel was ineffective and if counsel had made the proper object regarding the sufficiency of the evidence, the district court would have dismissed the unlawful possession charge. View "State v. Brubaker" on Justia Law

A bank attempted to prove an accounting negligence claim by using an expert witness to testify regarding the accountant's audit of a lumber company. The district court refused to allow the expert to testify as to generally accepted CPA auditing standards, whether the accountant breached those standards, and causation. The district court left open the question of whether the expert could testify as to the accountant's work papers. At trial, the bank made an offer of proof as to the work papers but did not move to introduce them, and so the court never ruled on their admissibility. The jury returned a verdict finding the accountant did not negligently perform the audit. The court of appeals reversed the district court and remanded for a new trial. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding (1) the bank failed to preserve error on the work-paper issue, and (2) the expert was not qualified to testify on the ultimate issue of whether the accountant violated generally accepted accounting standards because the expert lacked the knowledge, skill, experience, training, or education to provide an adequate basis for this testimony. View "Quad City Bank & Trust v. Jim Kircher & Assocs., P.C." on Justia Law

Harold Johnson was found to be a sexually violent predator (SVP) and was civilly committed. At a final hearing, the district court concluded Johnson still possessed a mental abnormality that predisposed him to commit sexually violent offenses and denied Johnson's discharge. Johnson appealed, arguing that the district court erred in denying his motion for discharge or sanctions under Iowa Code 229A.8(5)(e) because his final hearing was not commenced within sixty days of the determination Johnson was entitled to a hearing. The court of appeals (1) affirmed the district court's order finding section 229A.8(5)(e) was directory rather than mandatory, and (2) concluded that the provision did not require a trial to be conducted within sixty days but only that the trial be scheduled within sixty days. The Supreme Court vacated the decision of the court of appeals and affirmed the district court's order denying discharge, holding (1) section 229A.8(5)(e) requires the district court to conduct a final hearing within sixty days, but (2) the court's failure to conduct a hearing within sixty days entitles an SVP to civil remedies, not discharge. View "In re Detention of Johnson" on Justia Law

Judith Utter was charged with supplying alcohol to a person under the legal age. Utter pled guilty to the charge. Subsequently, Utter appealed, arguing her trial counsel provided ineffective assistance by failing to file a motion to dismiss the charge based on the State's violation of Iowa's speedy indictment rule. The court of appeals affirmed after analyzing the issue and preserving Utter's claim for a postconviction relief proceeding. The Supreme Court vacated the court of appeals and reversed the district court, holding (1) the State violated the speedy indictment rule by failing to indict Utter with the forty-five day window mandated by Iowa R. Crim. P. 2.33(2)(a); (2) Utter's trial counsel failed to perform an essential duty by failing to file a motion to dismiss based on the State's violation of the speedy indictment rule; and (3) Utter did not enter the plea voluntarily or intelligently as she would not have pled guilty if she had known the court was required to dismiss the information under rule 2.33(2)(a) and the State could not charge her with any other violation of Iowa Code 123.47 arising out of the underage drinking party at her home. Remanded with directions to dismiss the information. View "State v. Utter" on Justia Law