Justia Iowa Supreme Court Opinion Summaries

Respondent was incarcerated with an approaching release when the State filed a petition alleging Respondent was a sexually violent predator (SVP) under Iowa's civil commitment statute. After a jury trial, Respondent was found to be an SVP. The primary issue on appeal was whether the State properly waited until the conclusion of Respondent's overall prison term to bring an SVP proceeding, when Respondent received consecutive sentences for a sexual abuse offense and a burglary/arson offense, with the sentence for burglary/arson to be served after the sentence for the sexual abuse offense. The Supreme Court reversed, holding (1) a person receiving consecutive sentences, one of which is for a sexually violent offense, is "presently confined" within the meaning of the civil commitment statute, and thus, an SVP petition is timely filed if it is filed before the respondent's anticipated release from prison, as long as the current term of imprisonment includes a sentence for a sexually violent offense; (2) sufficient evidence supported the jury's verdict that Respondent was an SVP; but (3) it was error to admit expert testimony on the State's procedure for selecting persons against whom SVP proceedings are filed. View "In re Detention of Stenzel" on Justia Law

Defendant was arrested and charged with operating a vehicle while under the influence of a controlled substance in violation of Iowa Code 321J.2(1)(c). Defendant asserted an affirmative defense under section 321J.2(7)(b), which provides that an operator of a vehicle cannot be convicted of operating under the influence of a drug if he is taking the drug as prescribed by his doctor and in accordance with the labeling directions of the pharmacy. After a jury trial, Defendant was convicted of operating while intoxicated. The Supreme Court reversed, holding that there was insufficient evidence to support the verdict because the evidence was too speculative for a jury to conclude beyond a reasonable doubt that Defendant failed to take the prescription drugs as directed by his doctor or the pharmacy. View "State v. Schories" on Justia Law

Decedent's last will and testament and her correspondence with family members included specific directions to bury her in a plot she had already purchased at a cemetery in Montana. Decedent's surviving husband, Appellant, sought to bury her in Iowa and claimed the sole right to decide because Decedent had never executed a declaration under the Final Disposition Act designating anyone else to make that decision. The probate court granted a motion by the executor of Decedent's estate compelling burial in Montana. The Supreme Court reversed, holding (1) the operative statutory language requires enforcement of the surviving spouse's decision; and (2) therefore, the probate court erred in concluding that Decedent's wishes trumped her surviving husband's right to control disposition of her remains under the Final Disposition Act. View "In re Estate of Whalen" on Justia Law

While accompanying students on a field trip to a dairy farm, a chaperone (Plaintiff) was injured when she fell through a hole in the floor of a hayloft. Plaintiff filed a negligence suit against the dairy farm's owners (Defendants). The district court granted summary judgment for Defendants, concluding that Iowa's recreational use statute barred Plaintiff's claims. The court of appeals agreed that Defendants' property was covered by the recreational use statute, that Plaintiff was engaged in a recreational purpose, and that Defendants had not willfully or maliciously failed to guard or warn against a dangerous condition, but the court found that Plaintiff could still maintain a suit against Defendants as tour guides. The Supreme Court vacated the decision of the court of appeals, reversed the judgment of the district court, and remanded, holding (1) recreational use immunity did not extend to Defendants because Plaintiff was not engaged in a recreational purpose within the scope of the statute; but (2) Plaintiff had not raised a material issue of triable fact as to whether Defendants willfully or maliciously failed to guard or warn against the presence of the hole. View "Sallee v. Stewart" on Justia Law

The district court entered a decree dissolving the marriage of Steven and Diana Kimbro. To equalize the property distribution, the district court required Steven to make an equalization payment to Diana totaling $50,060. Steven appealed, arguing that the property distribution with the equalization payment was inequitable. Diana cross-appealed, contending that the district court erred by denying attorney fees. The court of appeals affirmed as modified by reducing the equalization payment to $5000. The Supreme Court (1) vacated the court of appeals' opinion regarding the reduction of the equalization payment and affirmed the district court's calculation of the equalization payment at $45,468; and (2) affirmed the lower courts' decision to deny Diana trial and appellate fees. View "In re Marriage of Kimbro" on Justia Law

In 2007, Hardin County Drainage District 55 provided Union Pacific Railroad Company with statutory notice requiring the railroad to rebuild and reconstruct damaged subterranean drainage tile found under the railroad's roadbed. Railroads are statutorily required to pay for the construction and maintenance of culverts and bridges occurring at natural waterways on the railroad's right-of-way. Union Pacific countered that the underground drainage tiles were not "culverts" as defined by the relevant statute. The district court entered judgment for the drainage district, finding the railroad breached its statutory duty to repair the drainage tile. The Supreme Court reversed, holding that the drainage tile did not fit the statutory definition of a culvert, and thus the railroad was not obligated to pay for the repairs. Remanded. View "Hardin County Drainage Dist. 55 v. Union Pac. R.R. Co." on Justia Law

Plaintiffs, farmers, purchased a Farm-Guard insurance policy from First Maxfield Mutual Insurance Association. Grinnell Mutual Reinsurance Company (Grinnell Mutual) reinsured the policy. Two years later, 535 of the hogs Plaintiffs were raising suffocated to death in Plaintiffs' building. Plaintiffs filed a claim with Grinnell Mutual to recover under the policy, but Grinnell Mutual denied the claim. Plaintiffs sued Grinnell Mutual for breach of contract. Both parties filed motions for summary judgment. The district court denied Grinnell Mutual's motion and granted Plaintiffs' motion based on the reasonable expectation doctrine. The court of appeals affirmed on alternative grounds, concluding the insurance policy was ambiguous and construing the ambiguity in favor of Plaintiffs. The Supreme Court reversed, holding (1) the policy was not ambiguous, and as a matter of law, the policy did not provide coverage; and (2) as a matter of law, the doctrine of reasonable expectations did not apply here. Remanded with instructions to enter judgment in favor of Grinnell Mutual. View "Boelman v. Grinnell Mut. Reinsurance Co." on Justia Law

Defendant was one of several adult caregivers for a five-year-old girl suffering from malnutrition. The State charged Defendant with two counts of child endangerment, and a jury found Defendant guilty of child endangerment causing serious injury. Defendant appealed, contending that the district court erred by allowing a caseworker for the Department of Human Services (DHS) to testify that a child abuse report against Defendant was administratively determined to be "founded." The Supreme Court reversed the judgment of the district court and remanded the case for a new trial, holding that it was reversible error to allow testimony that DHS had determined the child abuse complaint against Defendant was founded. View "State v. Huston" on Justia Law

This dispute centered around a revocable trust Settlor created during her lifetime. Settlor was the trustee of the trust until shortly before her death, when she substituted Judith Cunningham as trustee. After Settlor died, Marylynn Miller, a beneficiary, asked the probate court to order Cunningham to account for the activities of the trust since her appointment and to order Cunningham to reimburse her for attorney fees. Upon the probate court's order, Cunningham rendered the accounting. The probate court then ordered Cunningham to personally pay attorney fees and costs incurred during the course of the proceeding. The Supreme Court (1) reversed the ruling that Cunningham had a duty to account to Miller for the period preceding Settlor's death, as, pursuant to Iowa Code 633A.3103, the settlor alone is entitled to accounting for the period the trust is revocable; and (2) reversed the order requiring Cunningham to personally pay the fees and costs incurred litigating that issue, as there was no evidence Cunningham was guilty of malfeasance, fraud, or abuse. View "In re Trust of Trimble" on Justia Law

After a contentious divorce from his ex-wife, Beth Weier, Scott wrote a memoir called Mind, Body and Soul. The book discusses Scott's personal transformation following his divorce. Beth and her father, Gail Bierman, filed suit against Scott and Author Solutions, Inc. (ASI), the company that produced the book, for invasion of privacy, libel, and intentional infliction of emotional distress. Scott and ASI (Defendants) filed motions for summary judgment, which the district court denied. The Supreme Court affirmed in part and reversed in part, holding (1) the district court correctly denied Scott's motion for summary judgment on all claims; but (2) as a bona fide book publisher, ASI should be considered a media defendant, and therefore, ASI was entitled to summary judgment as to Plaintiffs' libel and false light invasion of privacy claims because Plaintiffs failed to provide sufficient proof to establish a prima facie case under the established standards applicable to such defendants. View "Bierman v. Weier" on Justia Law