Justia Iowa Supreme Court Opinion Summaries

An executor brought a cause of action against a bank for failing to obtain approval for investments it made on behalf of the deceased when the deceased was under conservatorship and the bank acted as conservator. The district court dismissed the executor's claim. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the conservator's failure to seek prior approval of the investment of the ward's property under Iowa Code 633.647 did not, in and of itself, make the conservator personally liable for losses caused by the investment; (2) to find the conservator personally liable for losses caused by an investment, the executor must prove a breach of fiduciary duty under Iowa Code 633.633A; and (3) in this case, the executor failed to prove a breach of fiduciary duty. View "Leo v. First Cmty. Trust, N.A." on Justia Law

After a jury trial, Raymond Redmond was convicted of indecent exposure. Redmond appealed, contending that the district court abused its discretion by permitting the State to impeach Redmond with his prior first-degree harassment conviction under Iowa R. Evid. 5.609(a)(1). The court of appeals affirmed the district court's evidentiary ruling. The Supreme Court vacated the court of appeals and reversed the district court, holding (1) the district court abused its discretion by allowing the State to impeach Redmond with his prior conviction as the prior conviction's probative value did not outweigh its prejudicial effect, and (2) the error was not harmless. Remanded for a new trial. View "State v. Redmond" on Justia Law

After a jury trial, David DeSimone was convicted of sexual abuse in the third degree. DeSimone's conviction was affirmed on appeal. DeSimone subsequently filed an application for postconviction relief, asserting that the State committed a Brady violation when it failed to turn over a witness's timecard showing that the witness could not possibly have seen the events to which she testified. The district court denied relief, and the court of appeals affirmed. The Supreme Court vacated the court of appeals and reversed the judgment of the district court, holding that the State's failure to disclose the timecard was a Brady violation because (1) the State suppressed the evidence, (2) DeSimone met his burden of proof that the evidence was favorable to his guilt or innocence, and (3) the evidence was material to the issue of guilt. Remanded. View "DeSimone v. State " on Justia Law

Employee filed a personal injury lawsuit against a company under common ownership with Employer and ultimately settled the claim. About nine months after the settlement, Employer terminated Employee's employment. Employee filed suit against Employer, asserting an intentional tort claim for wrongful termination in violation of public policy and claiming that Employer terminated his employment because he brought the previous personal injury claim. The district court granted Employer motion to dismiss for failure to make a claim. The court of appeals reversed. On review, the Supreme Court vacated the court of appeals and affirmed the district court, holding that Iowa Code 668, the state's comparative fault statute, did not contain a clearly defined and well-recognized public policy of the state limiting an employer's discretion to discharge an at-will employee. View "Berry v. Liberty Holdings, Inc." on Justia Law

While investigating a death by shooting, state police spoke with Justin Marshall, whom the police believed to have information relating to the crime. Because of Marshall's apparent plan to leave the area, the State filed a material witness complaint against him and obtained an arrest warrant for him. After Marshall's arrest, another man was charged with murder in connection to the death. Marshall filed a motion to dismiss the material witness complaint, alleging his continued detention violated due process, equal protection, and cruel and unusual punishment. The district court ordered Marshall's release, concluding that the authority of the State to detain a material witness is extinguished when a trial date is set for the underlying crime and the material witness is served with a subpoena. At issue on review was the proper interpretation of Iowa Code 804.11, which provides for the arrest of a material witness when the witness might be unavailable for service of a subpoena. The Supreme Court affirmed the order of the district court, concluding that section 804.11 authorizes the arrest and detention of material witnesses to felonies only for the purpose of ensuring that a valid subpoena may be served upon the witness. View "Marshall v. State" on Justia Law

Daniel Lado pleaded guilty to dependent adult abuse. Later, Lado filed a pro se petition for postconviction relief that contained a request for appointment of counsel. The district court appointed Lado counsel. After no action was taken on Lado's application, the district court dismissed Lado's petition pursuant to Iowa R. Civ. P. 1.944. Lado filed a pro se notice of appeal, alleging dismissal under rule 1.944 resulted from ineffective assistance of counsel. The court of appeals (1) affirmed the dismissal, and (2) found Lado's counsel was ineffective but preserved his claim for postconviction relief because it found the record was insufficient to determine whether the district court would have granted Lado's postconviction relief application if his counsel had acted competently. The Supreme Court vacated the court of appeals and reversed the district court, holding (1) Lado's counsel committed structural error in failing to seek a continuance to prevent dismissal under rule 1.944 or to make application to the court for the reinstatement of his case after it was dismissed by operation of the rule; and (2) the error constructively denied Lado the right to counsel. Remanded to district court for adjudication on the merits. View "Lado v. State" on Justia Law

The juvenile court terminated the noncustodial mother's parental rights to two children after finding termination was in the children's best interests. The court of appeals reversed, giving weight to the fact that termination would end the mother's child support payments. The father of one child filed a timely application for further review, and the other father did not. The Supreme Court vacated the court of appeals and affirmed the juvenile court as to the child whose father filed the application for further review and affirmed as to the other child, holding that the elimination of possible child support may not affect a termination of parental rights proceeding if termination is otherwise in the child's best interests. View "In re H.S." on Justia Law

Plaintiffs, landowners, challenged special assessments against their property for public improvements to a residential subdivision made by the city. Plaintiffs argued that the city council's decision to make public improvements within a subdivision rendered the city unable to assess the costs of the improvements to the landowners when a city ordinance provided for the improvements to be made by the subdivider. The district court (1) determined the city failed to enforce a subdivision ordinance requiring the subdivider to pay for street improvements but concluded that Plaintiffs failed to state a claim upon which relief could be granted because a city cannot be sued for its failure to enforce ordinances; and (2) found the assessments were not excessive. The Supreme Court affirmed, holding (1) Plaintiffs failed to state a claim upon which relief could be granted, (2) the city's failure to require the subdivider to personally make all improvements did not invalidate the authority of the city to assess property owners, and (3) the Plaintiffs did not establish the assessments to their property exceeded the special benefits provided by the improvement. View "Nelson v. City of Hampton" on Justia Law

During the administration of Ralph Roethler's estate, the executor of the estate did not notify Becky and Kent Lewis that Roethler's will gave the Lewises a first right to purchase eighty acres of farmland. The Lewises later sought to reopen Ralph Roethler's etate to allow them to exercise the option. The district court held that the Lewises met the statutory grounds set out in Iowa Code 633.489 to reopen the estate. The court of appeals reversed, holding that the Lewises' petition to reopen was time-barred. On review, the Supreme Court vacated the decision of the court of appeals and affirmed the district court's judgment, holding (1) the Lewises' petition to reopen satisfied the statutory grounds set forth in section 633.489 to reopen an estate, and (2) the district court properly construed the will to permit the Lewises to exercise their first right of purchase irrespective of the executor's intent to sell the land. View "In re Estate of Roethler" on Justia Law

Alan Watts was convicted of possession with the intent to deliver, drug stamp tax violations, and possession of drug paraphernalia. Watts appealed, contending that the district court erred in denying his motion to suppress evidence obtained from searching his apartment. The Supreme Court affirmed Watts' convictions and sentence, holding that although the initial warrantless sweep of Watts' apartment was unlawful due to a lack of exigent circumstances, the district court did not err in denying Watts' motion to suppress because (1) the officers later procured a warrant to conduct a full search of the apartment, (2) the evidence in question was located during that search, and (3) the State demonstrated that the warrant would have been sought and granted even without the information from the earlier improper sweep. View "State v. Watts" on Justia Law