Justia Iowa Supreme Court Opinion Summaries

Gerald Kirke and Wild Rose Entertainment (collectively, defendants), entered into an agreement with John Pavone and Signature Management Group (collectively, plaintiffs), stating the ownership and management relationship between the parties upon the opening of casino projects within the state. Wild Rose later terminated the agreement, and plaintiffs sued defendants for breach of contract and other claims. The district court sustained defendants' motion for a directed verdict on most of plaintiffs' claims but allowed the breach of contract claims. After a jury trial, the district court found Wild Rose breached the agreement and awarded plaintiffs ten million dollars in damages. Defendants filed a motion for a new trial, which the district court denied. The court of appeals reversed the judgment and remanded the case for judgment in favor of defendants. On review, the Supreme Court vacated the decision of the appellate court and affirmed the judgment of the district court, holding, inter alia, that the district court did not err in (1) overruling defendants' motion for a directed verdict on plaintiffs' breach of contract claims; (2) allowing the jury to award damages for a period of as much as thirty years; and (3) denying defendants' motion for a new trial. View "Pavone v. Kirke" on Justia Law

Defendant Wendell Harrington was convicted of ongoing criminal conduct, first-degree theft, second-degree theft, and three counts of second-degree burglary, all enhanced as a habitual offender. The court of appeals reversed Harrington's conviction for ongoing criminal conduct, affirmed his remaining convictions, and preserved his ineffective-assistance claim for postconviction relief. The Surpeme Court granted review to consider whether the district court erred in admitting Harrington's prior theft and burglary convictions under Iowa R. Evid. 5.609. At issue was whether State v. Axiotis required the district court to balance the probative and prejudicial nature of Harrington's prior convictions before admitting them. The court of appeals concluded the district court had no duty to apply a balancing test as Harrington's prior convictions involved dishonesty and were therefore admissible under Iowa R. Evid. 5.609(a)(2). The Supreme Court agreed with the court of appeals and overruled Axiotis to the extent it suggests the balancing test articulated in Iowa R. Evid. 5.609(a)(1) applies to prior convictions that involve dishonesty or false statement under Iowa R. Evid. 5.609(a)(2). Accordingly, the Court affirmed the court of appeals decision as to the issue and affirmed the district court's admission of Harrington's prior convictions for impeachment purposes. View "State v. Harrington" on Justia Law

Defendant Justin Derby was charged with third-degree burglary, five counts of forgery, and escape from custody. On the morning of trial, Derby presented the district court with an oral motion in limine seeking to exclude the admission of Derby's prior convictions. The district court partially sustained Derby's motion and prevented the State from using Derby's prior convictions in its case in chief. The court overruled Derby's motion to the extent that it sought to "bullet-proof...the defendant from being impeached" with his prior felony convictions. Derby elected not to testify as a result of the ruling and was later convicted as charged. Derby appealed, asserting the district court erred in overruling his motion in limine. The court of appeals held Derby failed to preserve his claim because he elected not to testify. In support of its ruling, the court cited State v. Brown, which held that the defendant must testify in order to preserve error to challenge the use of his prior convictions as impeachment. On review, the Supreme Court declined to depart from stare decisis and, accordingly, affirmed the decision of the court of appeals and the district court's judgment. View "State v. Derby" on Justia Law

Defendant Anouhak Keutla pled guilty to manufacturing a controlled substance. The district court granted Keutla a deferred judgment and placed her on supervised probation for two years. After a report of probation violations was filed, the district court revoked defendant's deferred judgment, entered an adjudication of guilt, imposed a five-year prison sentence, suspended the sentence, ordered probation, and imposed a fine. The court further ordered defendant to serve six months in jail for contempt. Defendant appealed, arguing that the district court did not have the authority both to revoke her deferred judgment and to find her in contempt. The court of appeals concluded that the district court exceeded its authority by both revoking defendant's deferred judgment and punishing her for contempt and remanded the case. The Supreme Court granted review. The Court agreed with the court of appeals, concluding that the entire sentence should be reversed and remanded to the district court for resentencing. View "State v. Keutla " on Justia Law

Appellant Randy Meyers was convicted of lascivious conduct with a minor and sex abuse in the third degree stemming from Meyer's sexual relationship with his seventeen-year-old stepdaughter, Mindy. Meyers appealed, contending there was insufficient evidence to support the conviction. Meyers supported his appeal by focusing on the absence of testimony by Mindy that the sex acts with Meyers were by force or against her will. Myers also asserted that Mindy's consent could not be negated without expert evidence that she suffered from a recognized mental defect, and claimed that expert testimony presented by the state that Mindy was psychologically unable to consent was insufficient to vitiate consent under the statute. The court of appeals affirmed. The Supreme Court also affirmed, holding (1) the district court did not err in finding sufficient evidence that the sex acts occurred, and (2) that all the circumstances taken together support a finding that the sex acts engaged in between Meyers and Mindy were by force or against the will of Mindy. View "State v. Meyers" on Justia Law

Elizabeth Von Linden took her life three weeks after she was discharged as an inpatient from defendant Mercy Hospital's psychiatric ward and six days after her outpatient office visit with Mercy's psychiatrist. Von Linden's husband brought a wrongful death action against Mercy, alleging negligent care. Mercy raised defenses, including Von Linden's comparative negligence. The jury found both Mercy and Von Linden negligent and allocated ninety percent of the total fault to Von Linden and ten percent to Mercy, resulting in a defense verdict. At issue on appeal was whether the state's comparative fault act, Iowa Code chapter 668, permits a jury to compare the fault of a noncustodial suicide victim with the negligence of the mental health professionals treating her. The Supreme Court held that Von Linden owed a duty of self-care as an outpatient, and the district court committed no reversible error in allowing the jury to compare her fault. The Court therefore affirmed the judgment for Mercy. View "Mulhern v. Catholic Health Initiatives" on Justia Law