Justia Iowa Supreme Court Opinion Summaries

Melissa and Heather Gartner were a married lesbian couple. Heather conceived a child using an anonymous sperm donor. The child was born during the spouses' marriage. The Gartners requested a birth certificate recognizing both Heather and Melissa as the child's parents. The Department of Public Health refused to place the name of the nonbirthing spouse in a lesbian marriage on the birth certificate without the spouse first adopting the child. The district court ordered the Department to issue the Gartners a birth certificate listing both spouses as parents but did not require the Department to extend the same practice to other married lesbian couples. The Supreme Court affirmed as modified, holding (1) Iowa Code 144.13(2), Iowa's presumption of parentage statute, violates the equal protection clause of the Iowa Constitution because it allows for only "the name of the husband" to appear on the birth certificate; and (2) accordingly, the Department must presumptively list on a child's birth certificate the nonbirthing spouse in a lesbian marriage when the child was born to one of the spouses during their marriage. View "Gartner v. Iowa Dep't of Pub. Health" on Justia Law

Defendant was convicted of operating a motor vehicle while intoxicated. Defendant appealed the denial of his motion to suppress, arguing that the police officer who stopped his vehicle lacked either reasonable suspicion or probable cause to justify the stop. The officer testified that he observed a violation of Iowa Code 321.37(3), which makes it unlawful for the owner of a vehicle to place a frame around the registration plate that does not permit full view of the license plate numbers and letters, and that violation was the basis for the stop. The Supreme Court reversed, holding that the officer did not have either probable cause or reasonable suspicion to stop Defendant's vehicle, and thus, all evidence obtained in the subsequent stop was inadmissible. Remanded. View "State v. Tyler" on Justia Law

A lakefront property was zoned residential but was historically operated as a marina pursuant to special-use permits allowing nonconforming use. The Supreme Court previously held that while the use of the property as a marina was lawful under the special-use permits, the permits did not allow an expansion of use that included on-premises consumption of alcohol with live entertainment, karaoke, and full-moon parties. The owner of the property subsequently sought to operate a bar on a structure called the Fish House Lounge, which was moored to the marina's seawall but was capable of getting underway in the lake. Fish House had a liquor license from the State. The district court found the arrangement amounted to a nonconforming use of the property in violation of the City's zoning regulations and entered an injunction (1) prohibiting the use of the marina property to provide access to or parking for the bar and to provide other services for the bar; and (2) prohibiting the property owner from serving alcohol on any structure moored to the premises. The Supreme Court affirmed but directed the district court to modify its injunction to prohibit nonaccessory activities solely on the land within the geographic boundaries of the City. View "City of Okoboji v. Parks" on Justia Law

After Appellant was granted parole, Appellant and his parole officer signed a parole agreement that contained standard and special terms of parole. One standard condition authorized any parole officer of law enforcement officer to conduct a warrantless, suspicionless search of Appellant and the home, vehicle, and belongings of Appellant. During one such parolee search, a police officer took Appellant's car keys and searched Appellant's car, where the officer discovered a large quantity of marijuana. The State subsequently charged Appellant with drug possession. Appellant moved to suppress the marijuana seized from the search of his vehicle, asserting that the search was unconstitutional because the condition authorizing the search constituted involuntary consent. The district court denied Appellant's motion and found him guilty of the charges. The Supreme Court reversed, concluding that a parole agreement does not satisfy the consent exception to the reasonableness and warrant requirements of the search and seizure clause of the Iowa Constitution. Remanded for a new trial. View "State v. Baldon" on Justia Law

Plaintiff and Defendant were brother and sister. Defendant was a longtime resident of Maryland. Plaintiff allegedly lived in Iowa in 2003. After Plaintiff obtained employment in Iraq in 2003, he opened a checking account in Des Moines and provided Defendant with checks that could be used to draw on the account to provide for the needs of his children and to pay the bills. Instead of using the checks as agreed, Plaintiff claimed Defendant used the checks to withdraw funds for her personal use. Plaintiff filed a lawsuit against Defendant in Iowa district court for breach of contract, conversion, bad faith, fraud, and breach of fiduciary duty. The district court dismissed the complaint for lack of personal jurisdiction over Defendant, finding that sufficient minimum contacts were lacking. The Supreme Court reversed, holding that Defendant was subject to personal jurisdiction in Iowa under the Calder v. Jones foreseeable effects test based on the claim of an intentional tort in Iowa. Remanded. View "Shams v. Hassan" on Justia Law

The Iowa Department of Transportation (IDOT) suspended a commercial driver's license (CDL) for one year for operation of a commercial motor vehicle with an alcohol concentration of .04 or more. The driver contested the suspension on the ground that the IDOT had erred in concluding that in the CDL context, breathalyzer test results are not to be adjusted for the breathalyzer test's recognized margin of error. The district court and court of appeals affirmed the IDOT decision. The Supreme Court affirmed, holding that there was no indication in the structure or language of the relevant statutes that the legislature intended that a breathalyzer test result be adjusted by the recognized margin of error in making an alcohol concentration determination for the purpose of CDL suspensions. View "Watson v. Iowa Dep't of Transp." on Justia Law

Defendant was charged with one count of robbery and one count of willful injury causing serious injury. The charges both stemmed from a single incident involving a single victim. Pursuant to a plea agreement, Defendant pleaded guilty to two counts of willful injury causing serious injury. Defendant appealed, arguing that his trial counsel was ineffective for allowing him to enter a guilty plea without a factual basis. The court of appeals vacated one of the willful injury convictions, finding that there was not a sufficient factual basis in the record to support a second independent charge of willful injury causing serious injury. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding that the record established an independent factual basis for the factual charge, and thus, counsel was not ineffective in allowing Defendant to enter guilty pleas to two separate counts of willful injury causing serious injury. View "State v. Velez" on Justia Law

In 2006, the Iowa Department of Revenue assessed the value of Qwest Corporation's Iowa operating property. Qwest protested the assessment by challenging the general assembly's previous decision to tax the personal property of incumbent local exchange carriers (ILECs) but not competitive long distance telephone companies (CLDTCs) or wireless providers operating in Iowa. Specifically, Qwest argued that the tax scheme which taxed ILECs for the value of their personal property but not CLDTCs and wireless providers violated Qwest's equal protection rights. The State Board of Tax Review (Board) concluded that Qwest's constitutional rights were not violated. The district court reversed. The Supreme Court reversed the district court and upheld the Board's assessment on Qwest, holding that imposing a tax on Iowa-based personal property of ILECs but not on that of CLDTCs or wireless service providers did not violate the Iowa Constitution, as the differential tax treatment of these enterprises is rationally related to legitimate state interests in encouraging the development of new competitive telecommunications infrastructure while raising revenue from those providers that historically had a regulated monopoly and continue to enjoy some advantages of that monopoly. View "Qwest Corp. v. State Bd. of Tax Review" on Justia Law

Plaintiff sued Defendant, a bar, for injuries sustained when he was assaulted in the bar's parking lot. The district court granted summary judgment in favor of the bar, finding as a matter of law that the assault in the parking lot and Plaintiff's resulting injury were not foreseeable to the bar. The court of appeals reversed, holding that Defendant owed Plaintiff a duty and that Plaintiff had raised questions of fact as to foreseeability related to the issues of breach of duty and scope of liability. The Supreme Court affirmed, holding (1) the district court erred in concluding that Defendant, as a matter of law, could not have breached its duty of reasonable care; (2) a reasonable fact finder could conclude that Plaintiff's harm was within the appropriate scope of liability for Defendant; and (3) genuine issues of material fact remained regarding each element of Plaintiff's negligence claim, and summary judgment was therefore inappropriate. Remanded. View "Hoyt v. Gutterz Bowl & Lounge LLC" on Justia Law

Steven Sheeder and Barlett Grain Co. entered into oral agreements for the sale of grain. The parties later confirmed the agreement with a signed, written document containing an arbitration clause that was not part of the oral agreements. After Bartlett requested adequate assurance of performance and Sheeder did not provide such assurance, thus repudiating the contracts, Bartlett filed a complaint against Sheeder with the National Grain Feed Association (NGFA). Sheeder failed to sign an arbitration contract as required by NGFA arbitration rules, and NGFA entered a default judgment for Bartlett for breach of contract. Bartlett subsequently filed an application for confirmation of the arbitration award. The district court denied the application, concluding that there was no enforceable agreement between the parties to arbitrate. The Supreme Court reversed, holding (1) Bartlett and Sheeder entered into written agreements to arbitrate because the parties' oral agreements were modified by signed writings including agreements to arbitrate; and (2) the written agreements between Sheeder and Bartlett were not unconscionable. View "Barlett Grain Co. v. Sheeder" on Justia Law