Justia Iowa Supreme Court Opinion Summaries

After Tenants moved out of an apartment, Landlord withheld the rental deposit for an automatic carpet-cleaning charge, replacement of a damaged door, and monthly penalties for failure to pay for the door. Tenant sued in small claims court alleging that Landlord improperly failed to return the rental deposit. The magistrate held for Tenant on most issues and awarded damages. The district court upheld some but not all of the magistrate’s decision, concluding (1) Landlord could charge Tenant for the replacement of the exterior door; (2) Tenant was liable to Landlord for rent during two months when the premises was vacant; but (3) Landlord’s automatic deduction from the rental deposit for carpet cleaning violated the Iowa Uniform Residential Landlord and Tenant Act (IURLTA). The Supreme Court affirmed in part and reversed in part, holding (1) the district court correctly found in favor of Tenant on the issue of cleaning costs; (2) the district court erred in ruling against Tenant on the issue of liability for the door repair and on the claim for damages for failure to permit Tenants from subleasing the apartment; and (3) the district court erred in awarding punitive damages under IURLTA. View "De Stefano v. Apartments Downtown, Inc." on Justia Law

After Tenants moved out of an apartment, Landlord deducted $904 fomr the rental deposit for an automatic carpet-cleaning charge, replacement of an interior door, and monthly penalties for failure to pay for the door. Tenant filed a small claims action alleging that Landlord unreasonably failed to return the rental deposit and willfully used a rental agreement with known prohibited provisions. A magistrate determined that Landlord violated the Iowa Uniform Residential Landlord and Tenant Act (IURLTA) by requiring Tenants to pay for the interior door repair and for the cost of carpet cleaning. The magistrate concluded that Tenant was entitled to punitive damages for bad-faith retention of the rental deposit and an award of two months’ rent for willfully using provisions in its rental agreement that violated the IURLTA. The magistrate awarded Tenant an additional two months’ rent and attorneys’ fees. The district court affirmed. The Supreme Court affirmed in all respects except on the issue of a knowing use of provisions violating the IURLTA and a bad-faith retention of the rental deposit, holding (1) the record does not contain sufficient evidence to support a knowing violation of the IURLTA, and (2) there was insufficient fact-finding on the issue of bad-faith retention of the rental deposit. Remanded. View "Caruso v. Apartments Downtown, Inc." on Justia Law

Tenant leased certain property from Landlord. Landlord filed a petition for a declaratory judgment seeking a ruling that it could have reasonable access to the property to show it to prospective buyers. The district court found the lease to be unambiguous and granted summary judgment to Tenant, concluding that Tenant could exclude Landlord from showing the property until ninety days remained in the term of the lease. The Supreme Court reversed the judgment of the district court, holding that lease provisions that gave Landlord the right to sell the property at any time during the lease term encompassed the right to access the property temporarily at reasonable times to show the property to prospective buyers. View "Alta Vista Props., LLC vs. Mauer Vision Ctr., PC" 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

Tenant brought claims against her landlord, the City of Dubuque, and a City official (Defendants), asserting that they unlawfully caused her eviction from her apartment. Tenant alleged, among other things, that the conduct of Defendants violated a number of her statutory rights under the Iowa Uniform Residential Landlord and Tenant Act (IURLTA). To the extent the Dubuque ordinance authorized the action of Defendants, Tenant argued the ordinance was preempted by the IURLTA. The district court concluded that Tenant was entitled to the return of her security deposit but denied all other relief. The Supreme Court affirmed in part and reversed in part, holding (1) the ordinance was not preempted by the IURLTA and there was no violation of federal law in this case; (2) the ordinance was not unconstitutionally vague and any procedural due process claim was moot; (3) the landlord violated the IURLTA when he removed the belongings of Tenant from the apartment, and landlord's withholding of Tenant's security deposit was a bad faith violation of IURLTA. Remanded. View "Lewis v. Jaeger" on Justia Law

Plaintiff corporation filed an action against Defendant, a resident of Nebraska, for damages related to the termination of an apartment lease in Iowa where Defendant formerly resided. Plaintiff attempted to serve notice under Iowa's long-arm statute by certified mail at a forwarding address provided by Defendant upon the termination of his tenancy in the apartment. The notice, however, was returned by postal authorities. Plaintiff took no further action to achieve service, and the district court entered a default judgment against Defendant. Based on the default judgment, Plaintiff sought to garnish Defendant's wages at his Nebraska employer. Defendant sought to quash the garnishment on the ground that Plaintiff failed to comply with the requirements of Iowa Code 617.3 in connection with the underlying action. The district court denied Defendant relief. The Supreme Court reversed, holding that the underlying default judgment that gave rise to the garnishment in this case was void for lack of personal jurisdiction over Defendant as provided in section 617.3. Remanded with instructions to grant the motion to quash. View "L.F. Noll Inc. v. Eviglo" on Justia Law