Justia Iowa Supreme Court Opinion Summaries

At issue in this case was whether a trial court's entry of a default judgment under Iowa R. Civ. P. 1.971(3) is justified when a party fails to appear personally for trial, but the party's attorney is present and able to proceed in the client's absence. The court of appeals affirmed the district court's entry of default judgment due to Plaintiff's failure to appear personally at the time of his scheduled trial. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the district court, holding that because Rule 1.971(3) does not require a party to appear personally for trial, it was an abuse of discretion to enter a default judgment against Plaintiff when his counsel was present and able to proceed to trial on his behalf. View "Jack v. P & A Farms, Ltd." on Justia Law

At issue in this appeal was whether a surviving spouse's elective share, as defined in Iowa Code 633.238, includes pay-on-death (POD) assets. The probate court ruled that three of Karen Myers's assets, a checking account, certificate of deposit, and an annuity, all payable on her death to her daughters, should be included in the elective share of her surviving spouse, Howard Myers. The assignees of Howard's elective share argued that the elective share should include POD assets under Sieh v. Sieh, which held the elective share includes assets in a revocable trust. The executor argued that the General Assembly, by amending section 633.238 in 2009, expressly limited the surviving spouse's elective share to four categories of assets listed in the statute, none of which included POD assets. The Supreme Court reversed the ruling of the probate court, concluding that the 2009 amendment to section 633.238 trumps Sieh, and the controlling statutory language omits POD assets from the surviving spouse's elective share. Remanded. View "In re Estate of Myers" on Justia Law

The district court found Defendant guilty of fraudulent practice in the third degree for possessing 218 packs of cigarettes lacking tax stamps. At issue on appeal was whether "the amount of money or value of property or service involved" in this crime was the amount of the unpaid tax or, rather, the value of the cigarettes. Defendant contended the degree of the crime should be based on the unpaid cigarette tax, which was insufficient to convict her of third-degree fraudulent practice. The district court determined the degree of fraudulent practice was based on the value of the cigarettes, not the amount of the unpaid tax. The court of appeals affirmed. The Supreme Court affirmed, holding that, under Iowa Code 453A.36, the possession of unstamped cigarettes was the fraudulent practice, not the unpaid tax, and therefore, the district court correctly entered judgment against Defendant for third-degree fraudulent practice. View "State v. Messer" on Justia Law

Wife asked the Supreme Court to determine the validity of a premarital agreement, the fairness of a property settlement, the sufficiency of the spousal support, and the denial of expert fees incurred by Wife's attorney in preparation of the case for trial. The court of appeals affirmed the district court's decision upholding the premarital agreement, the property settlement, the award of spousal support, and denying the expert fees. The Supreme Court (1) affirmed the lower courts' decision concerning the premarital agreement and the distribution of property; but (2) vacated the part of the court of appeals opinion and modified the district court decision regarding the spousal support award and the expert fees, holding (i) Husband was required to pay spousal support in the sum of $7,000 per month until Wife's death or remarriage, and (ii) Husband was required to pay $17,050 in attorney fees for the expert services provided to Wife's attorney. View "In re Marriage of Schenkelberg" on Justia Law

Appellant was convicted of first-degree in murder in 2005. In 2009, Appellant filed an application for postconviction relief alleging his trial was ineffective for (1) failing to raise the defense of temporary insanity or diminished capacity, and (2) failing to adequately support the request for bifurcation of his trial. Appellant also asserted his appellate counsel on direct appeal was ineffective for failing to appeal the trial court's denial of his request for bifurcation. The postconviction court denied Appellant's application. The court of appeals affirmed, finding that the postconviction court did not rule on Appellant's specific claims, and Appellant failed to preserve error by filing a subsequent motion under Iowa R. Civ. P. 1.904. The Supreme Court affirmed the denial of Appellant's application for postconviction relief, holding (1) the postconviction court did rule on Appellant's claims, and the claims were properly preserved for appeal; but (2) Appellant's claims lacked merit. View "Lamasters v. State" on Justia Law

The Supreme Court granted further review of this dissolution-of-marriage case to consider the proper distribution of a retired spouse's monthly pension benefits. The district court awarded the entirety of those benefits to the retired spouse. The court of appeals reversed and divided the benefits between the spouses to the extent they were accrued during the marriage. The Supreme Court vacated the court of appeals decision in part and affirmed the district court's judgment as modified, holding that the court of appeals did not err in ruling that the benefits should have been divided but erred in dividing the benefits without taking into account the remaining allocation of property between the parties. Remanded. View "In re Marriage of O'Brien" on Justia Law

In this putative class action, Plaintiffs were doctors of chiropractic who alleged they had been victimized by the discriminatory practices of Iowa's largest health insurer, Wellmark, Inc. The district court (1) granted Wellmark's motion to dismiss claims brought under Iowa's insurance regulatory statutes because no private cause of action was provided therein; (2) granted Wellmark's motion for summary judgment on Plaintiffs' antitrust claims based on the "state action" exemption found in Iowa Code 553.6(4); (3) granted summary judgment on claims alleging Wellmark breached its obligations under a judicially approved national class action settlement in Love v. Blue Cross Blue Shield Ass'n; and (4) granted summary judgment on several specific antitrust claims. The Supreme Court (1) reversed in part, holding that the district court erred in granting summary judgment on Plaintiffs' antitrust claims based on the state action exemption, as the record failed to establish the challenged conduct fell within the exemption; and (2) otherwise affirmed. Remanded. View "Mueller v. Wellmark, Inc." on Justia Law

The operator of an establishment offering nude and seminude dance performances sought an injunction restraining a city from enforcing its ordinance regulating nude and seminude dancing. The district court found that state law did not preempt the ordinance and that the ordinance was constitutional. The Supreme Court reversed the judgment of the district court, holding that state law preempts enforcement of the ordinance because the ordinance attempts to regulate nude dancing, and therefore, the ordinance is unenforceable against the establishment. Remanded to the district court with instructions to enter an order enjoining the city from enforcing its ordinance against the establishment. View "Mall Real Estate, LLC v. City of Hamburg" on Justia Law

This case required the Supreme Court to decide whether filmmakers receiving tax credits from the State of Iowa under the State's tax credit program could enjoin the State from releasing summaries of their films' final budgets to the public. The district court determined they could. The Supreme Court reversed, holding (1) the budget summaries do not qualify as trade secrets under Iowa Code 22.7(3); (2) the budget summaries cannot be considered "reports to governmental agencies which, if released, would give advantage to competitors and serve no public purpose" under Iowa Code 22.7(6); and (3) the filmmakers failed to meet Iowa Code 22.8's requirements for injunctive relief by demonstrating disclosure would not be in the public interest and would substantially and irreparably injure any person or persons. Remanded. View "Iowa Film Prod. Servs. v. Iowa Dep't of Econ. Dev." on Justia Law

The American Civil Liberties Union of Iowa Foundation submitted an open records request to the Atlantic Community School District records custodian requesting information pursuant to Iowa's Open Records Act concerning the discipline of two school district employees after the school district disciplined them for performing a strip search of five students. The district court entered summary judgment in favor of the school district. The Supreme Court affirmed, holding that the district court did not err in finding that the disciplinary information sought was exempt from disclosure under Iowa Code 22.7(11), which exempts from disclosure "personal information in confidential personnel records of public bodies including...cities, boards of supervisors, and school districts." View "ACLU of Iowa vs. Atlantic Cmty. Sch. Dist." on Justia Law