Justia Iowa Supreme Court Opinion Summaries

Property owners (Owners) had a lengthy dispute with Linn County over whether houses they had built were subject to the County's zoning and subdivision ordinances. In two separate decisions, the Linn County Board of Adjustment (Board) (1) denied an agricultural exemption for a six-acre parcel that included Owners' residence, and (2) denied an agricultural exemption for a second house on a forty-three-acre parcel that Owners argued was an additional farmhouse. The district court found that substantial evidence support both decisions of the Board and denied Owners' petitioners for writ of certiorari. The court of appeals affirmed. The Supreme Court affirmed, holding that substantial evidence supported the Board's determinations that the houses at issue were not "primarily adopted, by reason of nature and area, for use for agricultural purposes." View "Lang v. Linn County Bd. of Adjustment" on Justia Law

The State filed a petition alleging that fifteen-year-old J.W.R. committed delinquent acts of incest. J.W.R. entered an Alford plea to the incest allegation. A juvenile court officer recommended J.W.R. be adjudicated a delinquent and placed in a residential treatment facility for sex offenders. The juvenile court issued a consent decree withholding adjudication that J.W.R. had committed a delinquent act. Over the State's objection, the court placed J.W.R. in the legal custody of juvenile court services, with the Department of Human Services as payment agent, for purposes of placement in a residential facility. The court of appeals sustained the State's writ of certiorari. The Supreme Court affirmed, holding that the legislature did not grant this authority to juvenile courts in Iowa Code 232.46. View "State v. Dist. Court" on Justia Law

Plaintiff was involved in an automobile accident with Defendants. After seeking a settlement with Defendants' insurance company, Plaintiff commenced an action against Defendants. Plaintiff, however, failed to negotiate an enforceable agreement with Defendants' insurance representative to delay service and took no action to institute service of process of a lawsuit on Defendant within the required time period. The district court held good cause existed to excuse the untimely service of process and denied Defendants' motion to dismiss. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court did not commit legal error by concluding good cause existed for the failure to accomplish timely service of process. View "Rucker v. Taylor" on Justia Law

In 1999, Appellant was convicted of first-degree murder and sentenced to life in prison without parole. In 2002, Appellant unsuccessfully sought postconviction relief. In 2006, the Supreme Court issued its decision in State v. Heemstra, in which the Court held that if the act causing willful injury is the same act that causes the victim's death, the former is merged into the murder and therefore cannot serve as the predicate felony for felony-murder purposes. In 2009, Appellant filed another application for postconviction relief, arguing that, under Heemstra, he would not have been convicted of felony-murder, and Heemstra should be applied retroactively. The application was filed after the statute of limitations had expired but within three years of the Court's decision in Heemstra. The district court granted the State's motion for summary disposition, finding that the three-year limitations bar applied. The Supreme Court reversed because Appellant raised a ground of fact or law that could not have been raised within the applicable time period. Remanded. View "Nguyen v. State" on Justia Law

Appellant pled guilty in 2000 to attempted burglary in the third degree. In 2011, Appellant filed an application for postconviction relief, arguing that, pursuant to the U.S. Supreme Court's decision in Padilla v. Kentucky, he had received ineffective assistance of counsel because his counsel had failed to advise him that pleading guilty would result in his removal from the United States. The district court granted summary judgment on Appellant's application, finding it to be untimely. The Supreme Court affirmed, holding that, based on the U.S. Supreme Court's decision in Chaidez v. United States, because Padilla announced a new rule of constitutional criminal procedure, it did not apply retroactively to convictions like Appellant's that became final before the Padilla decision. View "Nguyen v. State" on Justia Law

After Defendant was twice arrested and convicted of sexual offenses, proceedings were commenced for Defendant's commitment as a sexually violent predator. After a jury trial, Defendant was committed to the Civil Commitment Unit for Sexual Offenders (CCUSO). In 2010, Defendant submitted a petition seeking a final hearing on whether he should be discharged from the CCUSO or placed in a transitional release program. Thereafter, the State submitted its notice of annual review for 2011 asserting there was no evidence of any change in Defendant's mental abnormality constituting a ground for his discharge. Defendant subsequently filed a petition requesting a final hearing on his 2011 annual review and his claims for either discharge or placement in the transitional release program. The district court concluded Defendant failed to demonstrate by a preponderance of the evidence that he was entitled to a final hearing on either discharge or placement in a transitional release program. The Supreme Court affirmed, holding that the district court did not err in its judgment. View "Taft v. Dist. Court" on Justia Law

Plaintiff brought suit against Defendants, residential landlords, after Plaintiff slipped and fell on the premises while visiting her son, who leased an apartment from Defendants. After a jury trial, the trial court ruled in favor of Defendants. The court of appeals reversed and remanded for a new trial, concluding that the district court erred in excluding Plaintiff's proposed instructions informing the jury of a landlord's obligations under the lease agreement and under Iowa Code 562A.15(1)(a)-(d). The Supreme Court vacated the decision of the court of appeals and affirmed the district court's ruling, holding that the legal concepts contained in Plaintiff's requested instructions were adequately embodied in other instructions given by the district court. View "Crawford v. Yotty" on Justia Law

In 2010, Defendant pled guilty to stalking, first offense, with protective order, and fourth-degree criminal mischief. In 2011, Defendant was charged by information with stalking, second offense, or, alternatively, stalking in violation of a protective order. Defendant filed a motion to dismiss, arguing the State had not alleged sufficient facts to support a violation of the stalking statute, as the State had only detailed one incident of harassment. Specifically, Defendant argued that the use of the previous incidents, for which he was convicted, to prove the required course of conduct, would violate the double jeopardy clause. The district court granted the motion. The Supreme Court reversed, holding that the stalking statute, as applied in this case, did not violate the double jeopardy clause. View "State v. Lindell" on Justia Law

Defendant killed her longtime boyfriend. At trial, Defendant raised a defense of justification based on evidence of battered women's syndrome and a defense of insanity based on various diagnoses including depression and an anxiety disorder. Defendant was convicted of first-degree murder. The Supreme Court affirmed the conviction, holding that the district court did not erroneously (1) instruct the jury on the elements of a justification defense; (2) instruct the jury that Defendant bore the burden to prove an insanity defense; and (3) deny Defendant's motion for mistrial after the prosecution violated a ruling in limine during opening statements. View "State v. Frei" on Justia Law

Wife filed for divorce from Husband in 2009 after a dozen years of marriage. The district court (1) ordered Wife to pay child support of $219 per month, and (2) awarded Husband a share of the marital assets in excess of $2.1 million and Wife a share less than $150,000, and ordered Husband to make Wife an equalization payment for over $1 million. The court of appeals modified the property division award by decreasing the equalization payment to $250,000, finding the district court failed to consider the tax consequences of the property division and thus substantially overvalued the assets allocated to Husband. At issue on appeal was whether the district court's award of the equalization payment was equitable where most of the underlying assets were associated with a farming operation. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding that the district court was correct in its calculation of the equalization payment and its order fixing the amount of child support. View "McDermott v. McDermott" on Justia Law