Justia Iowa Supreme Court Opinion Summaries

After Toby Welch was arrested for operating a vehicle while intoxicated, police officers requested a breath specimen to be used for chemical testing. Welch refused the request. After talking to his attorney, however, Welch told officers that he wanted to consent to the breath test. The officers declined the request, commenting that because Welch had already refused, it was too late to submit to the test. Based on his refusal to submit to chemical testing, the Iowa DOT revoked Welch's driver's license for one year. The DOT's administrative law judge sustained the revocation, and the reviewing officer affirmed. The district court affirmed the revocation. At issue on appeal was whether the "one refusal is determinative" rule set forth in Krueger v. Fulton should be abrogated in favor of a more flexible standard permitting a motorist's subsequent consent to cure a prior initial refusal to submit to chemical testing. The Supreme Court rejected Welch's appeal and upheld the revocation of his license, concluding that a rule treating the motorist's initial refusal as determinative was supported by Court precedents, was consistent with the general assembly's intent, and was easier for police and courts to administer. View "Welch v. Iowa Dep't of Transp." on Justia Law

While an inmate at a correctional facility, Kevin Walker was assaulted by another inmate and was seriously injured. Walker brought a tort claim against the State, a correctional officer, and two activity specialists, claiming they negligently failed to ensure his safety. The State sought summary judgment based upon the discretionary function and intentional tort exceptions to the Iowa Tort Claims Act (ITCA). The district court denied the motion, concluding a genuine issue of material fact existed as to whether the prison staff involved had knowledge of a history of prior trouble involving Walker. The Supreme Court granted the State's application for interlocutory appeal and affirmed the decision of the district court, holding that the district court did not err in denying the State's motion for summary judgment where (1) because the decisions made by the correctional staff in the supervision of the inmates, in this instance, did not involve the evaluation of broad public policy factors, the State was not entitled to the discretionary function exception; and (2) as long as a claimant can show the State is negligent in performing a duty to protect a person from an assault, the intentional tort exception to the ITCA is not applicable. View "Walker v. State" on Justia Law

Bill Ernst gave Johnny Vajgrt permission to enter his property to remove a fallen tree. Vajgrt subsequently uprooted approximately forty live trees on Ernst's property. After Vajgrt died, Ernst filed a claim seeking compensatory damages and exemplary damages for the diminution of value of property, value of trees, and expenses for restoration of property. In addition, Ernst sought punitive damages. The district court awarded Ernst compensatory damages but declined to award any punitive damages, stating that it was well settled in Iowa that punitive damages may not be recovered from the estate of a deceased tortfeasor. On appeal, the Supreme Court affirmed, concluding that it would defer to the legislature's prior decisions and the Court's established precedents as it was not persuaded that it should reconsider those precedents. View "In re Estate of Vajgrt" on Justia Law

Two corporations organized as multiple housing cooperatives appealed the classification of their real estate as commercial for property tax purposes to the Jasper County Board of Review. The board did not alter the classification of the properties, and the cooperatives appealed. The district court affirmed the board's determination, concluding that the cooperative was actually operating as a standard rental property. After granting the cooperatives' combined motion for amendment and enlargement of findings and for a new trial, the district court concluded the cooperatives had followed all proper corporate formalities and were set up exactly as prescribed by Iowa law. Accordingly, the court reversed its prior ruling and concluded the real estate should properly be classified as residential. The court of appeals affirmed. On review, the Supreme Court affirmed, holding (1) Iowa law requires property owned by residential cooperatives, properly organized under chapter Iowa Code chapter 499A, to be classified as residential and taxed at residential property rates; and (2) because the cooperatives were operating on a nonprofit basis, there was no basis for penetrating the corporate veil. View "Krupp Place 1 Co-op, Inc. v. Jasper County Board of Review" on Justia Law

Michael Anderson, a convicted sex offender, was placed on electric monitoring and home supervision while on probation. After the district court revoked Anderson's probation, the court reinstated the prison terms. Anderson did not receive sentencing credit for the time he lived at home. Anderson filed an application for postconviction relief seeking such credit. The district court denied Anderson' application, concluding the statutory scheme only provided sentencing credit for time spent in a jail-like facility. The court of appeals affirmed. On review, the Supreme Court vacated the decision of the court of appeals and reversed the district court order denying credit, holding that the plain language of Iowa Code 907.3(3) requires credit for the time Anderson was committed to electronic monitoring and home supervision during his probation. Remanded. View "Anderson v. State" on Justia Law

After the district court dismissed criminal charges against J.W., J.W. filed a motion to expunge any information pertaining to the dismissed charges pursuant to Iowa Code 692.17, specifically requesting that the information be removed from the Iowa Court Information System (ICIS), including the website Iowa Courts Online, and the computer data storage systems for the county sheriff, city police, state division of criminal investigation, and the FBI. The district court granted J.W.'s request. The attorney general petitioned for a writ of certiorari, which the Supreme Court granted. The Court sustained the writ, holding that (1) Section 692.17(1) does not require criminal cases that ended in dismissal or acquittal to be removed from ICIS or the website Iowa Court Online; and (2) making dismissed criminal case information available to the public, while withholding public access to deferred judgments, does not violate the Equal Protection Clause of the Iowa Constitution. View "Judicial Branch v. Dist. Court for Linn County" on Justia Law

After the district court dismissed a criminal charge against C.R., C.R. filed an application to expunge the dismissed charge pursuant to Iowa Code 692.17. The district court granted the request and held (1) judicial review from the administrative process afforded by Section 692.5 was not the exclusive remedy for a person seeking deletion of records from the Department of Public Safety, Division of Criminal Investigation (DPS) computer system, and (2) electronic docket entries on the Iowa Courts Information System (ICIS) and the website Iowa Courts Online relating to C.R.'s dismissed case were covered by the statute. The Supreme Court granted the attorney general's petition for writ of certiorari. The Court sustained the writ and vacated the district court's order, finding that the district court acted without jurisdiction in reviving a dismissed criminal case for the purpose of ordering a nonparty such as DPS to delete records. The Court concluded that Section 692.5 provides the exclusive administrative remedy for a person such as C.R. seeking removal of criminal history data from DPS files, and it is not appropriate to bring a direct civil action or to use a prior criminal case for that purpose. View "Dep't of Pub. Safety v. Dist. Court for Polk County" on Justia Law

One of the subsidiaries of Annett Holdings was a trucking company that employed Michael Vititoe as a driver. Vititoe was given a Comdata credit card to purchase fuel. Comdata had a written contract with Kum & Go that enabled the Kum & Go truck stop from which Vititoe purchased fuel to handle Comdata transactions. For four years, Vititoe used the Comdata credit card at the Kum & Go truck stop to obtain cash while reporting purchases of fuel. After the fraud was discovered, Vititoe was arrested and convicted of theft. Annett Holdings sued Kum & Go for negligence and breach of contract as an alleged third-party beneficiary of the contract between Kum & Go and Comdata. The district court granted summary judgment to Kum & Go, (1) finding the negligence claim was barred by the economic loss rule; and (2) rejecting the breach of contract claim on the ground that Annett was not an intended beneficiary of the contract. The Supreme Court affirmed, holding the district court did not err in granting summary judgment to Kum & Go on both claims. View "Annett Holdings, Inc. v. Kum & Go, L.C." on Justia Law

Robert Harkins was convicted of third-degree sexual abuse. While he was incarcerated, Harkins refused to sign a treatment contract assuming responsibility for his offenses in order to participate in the correctional facility's sex offender treatment program (SOTP). The Department of Corrections then suspended Harkins's earned time pursuant to Iowa Code 903A.2(1)(a). Harkins filed an application for postconviction relief, arguing that the suspension of his earned-time credits for failure to participate in the SOTP violated his Fifth Amendment privilege against self-incrimination. The district court held that the State unconstitutionally compelled Harkins to give testimony but found the testimony would be potentially incriminating only until March 21, 2009, the last day on which the State could prosecute Harkins for perjury based upon his trial testimony. The Supreme Court granted certiorari, holding that (1) the statute does not violate the Fifth Amendment, and (2) the State may use earned-time credits as an incentive for convicted sex offenders to obtain sex offender treatment even when the treatment requires an acknowledgment of responsibility. The Court set aside the district court's order to the extent it reinstated Harkins's earned time through March 21, 2009 and remanded. View "State v. Iowa Dist. Court for Webster County" on Justia Law

Plaintiff Mark Peak broke his leg while helping Ellis and Rachel Adams move furniture using a rented U-Haul truck. The liability insurer for U-Haul paid its policy limits of $20,000 to Peak in exchange for a release that specifically named Ellis and arguably covered Rachel. When Peak sought additional compensation from another of insurer for the Adamses, the insurer denied coverage based on the release. Peak filed a negligence action against Adamses, alleging they were liable for negligence in their operation of the rental truck and their failure to remove snow from their driveway. The district court granted defendants' motion for summary judgment, concluding the release barred Peak's claims against both Ellis and Rachel. The court of appeals reversed. At issue was whether the release covered Ellis and Rachel as well as U-Haul and its insurer. On further review, the Supreme Court held that the district court correctly granted summary judgment for Ellis based on the release, while fact questions precluded summary judgment for Rachel. The Court vacated the decision of the court of appeals and affirmed in part and reversed in part the district court judgment. View "Peak v. Adams" on Justia Law