Justia Iowa Supreme Court Opinion Summaries

The case revolves around a legal malpractice action against a state public defender, who represented a client convicted of sexual abuse. The client, Donald Lyle Clark, was convicted and sentenced to prison. The conviction was affirmed on appeal. However, in postconviction proceedings, the court determined that Clark's defense counsel had provided ineffective assistance and ordered a new trial. The state declined to prosecute, and Clark filed a civil action for legal malpractice against the state as the lawyer’s employer. The district court granted partial summary judgment, holding that the finding of ineffective assistance in the postconviction proceedings established counsel’s negligence as a matter of law. The jury found the lawyer negligent and awarded Clark $12 million in emotional distress damages.The Supreme Court of Iowa reversed the judgment for emotional distress damages. The court clarified that to recover emotional distress damages for legal malpractice, the plaintiff must prove more than negligence. The court held that the plaintiff must prove by a preponderance of clear, convincing, and satisfactory evidence that the criminal defense attorney acted with willful and wanton disregard for the client’s rights or safety. The court concluded that the district court erred by instructing the jury that negligence was sufficient. The case was remanded for further proceedings consistent with this opinion. View "Clark v. State of Iowa" on Justia Law

Timothy Smith was convicted of two counts of sexual abuse in the second degree for the sexual abuse of his former stepdaughter, H.R. Smith filed an application for postconviction relief, arguing that his trial counsel provided ineffective assistance in failing to request additional peremptory strikes after the trial court denied his for-cause challenges to four prospective jurors, in failing to move for a mistrial due to claimed juror misconduct, and in failing to call favorable defense witnesses. The postconviction court denied Smith’s application for postconviction relief.The Iowa Court of Appeals held that the postconviction court erred in denying Smith’s claim regarding trial counsel’s failure to request additional peremptory strikes but did not address the remaining claims. The court of appeals reversed Smith’s convictions and remanded the case for further proceedings. The State of Iowa appealed this decision to the Supreme Court of Iowa.The Supreme Court of Iowa vacated the decision of the court of appeals and affirmed the judgment of the district court. The Supreme Court held that Smith failed to establish that his trial counsel breached an essential duty in not moving for a mistrial due to alleged jury misconduct. The court also held that Smith failed to prove his trial counsel breached an essential duty in failing to call certain witnesses that would have been favorable to Smith’s defense. The court concluded that the cumulative prejudice analysis set forth in Clay was inapplicable here because the court found no breaches of duty for those claims. View "Smith v. State of Iowa" on Justia Law

The case involves two attorneys, Jeffrey Peterzalek and Molly Weber, who sought to quash subpoenas for their depositions in a civil rights case brought by Charis Paulson against her employers, the State of Iowa and the Iowa Department of Public Safety (DPS). Paulson alleged gender-motivated discrimination and retaliation. Weber had represented DPS in its response to Paulson's civil rights complaint before the Iowa Civil Rights Commission (ICRC), while Peterzalek had represented DPS and its leaders in various other matters over the years. The district court declined to quash the subpoenas but ordered that the depositions be sealed. The attorneys then filed a petition for writ of certiorari with the Supreme Court of Iowa.The Supreme Court of Iowa granted the writ and retained the case. The attorneys argued that the court should adopt the Shelton test, which narrowly limits the circumstances in which opposing counsel may be deposed. They also argued that they should not be deposed or, alternatively, that substantial limitations should be imposed if their depositions were allowed.The Supreme Court of Iowa agreed with the attorneys' argument to adopt the Shelton test. Applying the test, the court concluded that Weber's deposition should be quashed as she was opposing counsel in the ongoing dispute and the information sought could be obtained by other means and was protected by the work-product doctrine. However, the court affirmed the district court's refusal to quash the subpoena for Peterzalek's deposition, as he was not opposing counsel in the ongoing dispute. The court remanded the case for further proceedings, including the entry of an order quashing the subpoena for Weber's deposition. View "Peterzalek v. Iowa District Court for Polk County" on Justia Law

The Supreme Court sustained Liquor Bike LLC's petition for writ of certiorari and vacated the district court's order disqualifying Liquor Bike's counsel on the ground that counsel's representation of Liquor Bike in this matter was directly adverse to a current client of counsel's law firm in another matter, holding that the district court abused its discretion.The district court disqualified Liquor Bike's counsel, Billy Mallory and Brick Gentry, P.C., in a boundary-dispute litigation, concluding that Mallory's representation of Liquor Bike violated Iowa Rule of Professional Conduct 32:1.7. Liquor Bike filed a petition for a writ of certiorari challenging the district court's disqualification of its counsel. The Supreme Court sustained the petition, holding that the district court did not subject the motion for attorney disqualification to strict scrutiny and, instead, found a concurrent conflict of interest where none existed. View "Liquor Bike, LLC v. Iowa District Court for Polk County" on Justia Law

In this action brought by a law firm seeking to enforce its payment due under a contingency fee contract the Supreme Court affirmed the judgment of the district court ordering judgment against the family that retained the law firm for one-third of their recovery plus interest, holding that the one-third contingency fee contract was reasonable at the time of its inception.After a car accident left a motorist in critical condition, the motorist's family (Appellants) retained a law firm to represent the motorist's interests. A contingency fee contract required Appellants to pay one-third of the recovery to the law firm for attorney fees. Appellants accepted a $7.5 million offer to settle the case. When Appellants failed to pay the contingency fee the law firm brought this action to enforce its payment. Appellants argued that the one-third contingency fee contract violated Iowa Rule of Professional Conduct 32:1.5(a) because it was an unreasonable fee. Judgment was ordered against Appellants for one-third of the recovery plus interest. The Supreme Court affirmed, holding (1) the one-third contingency fee agreement was reasonable at the time of its inception; and (2) this Court will not use the noncontingency fee factors under Rule 32:1.5(a) to reevaluate the contingency fee contract from a position of hindsight. View "Munger, Reinschmidt & Denne, LLP v. Plante" on Justia Law

Mathahs has practiced law in Iowa since 2001. In October 2001, he contracted with the Iowa State Public Defender (SPD) to provide legal services to indigent adults and juveniles in certain Iowa counties. The contract was renewed until 2013. Mathahs submitted General Accounting Expenditure (GAX) forms to the SPD detailing the dates, services performed, and the amount of time for each service. In March 2013, the SPD contacted Mathahs with concerns over the accuracy of Mathahs’s GAX forms. Mathahs had claimed more than 3000 hours and had received more than $180,000 in fiscal year 2010. Mathahs initially blamed inaccuracies on his secretary. SPD rejected Mathahs’s explanation. On April 26, Mathahs self-reported his misconduct to the Iowa Supreme Court Attorney Disciplinary Board. On September 23, 2015, after investigating, the attorney general’s office informed the SPD that it found no provable evidence of intent to steal or defraud. In June 2017, the Board filed a complaint, alleging violations of Iowa Rules of Professional Conduct 32:1.5(a) (unreasonable fees or expenses) and 32:5.3(b) (lack of supervision over a nonlawyer employee). Mathahs moved to dismiss, claiming laches because the Board delayed for more than four years in bringing its complaint after he had self-reported and such delay unduly prejudiced his defense. A panel of the Supreme Court Grievance Commission found that Mathahs violated the rules. The Supreme Court of Iowa imposed a 60-day suspension, declining to address the issue of laches. View "Iowa Supreme Court Attorney Disciplinary Board v. Mathahs" on Justia Law

The conduct of an attorney who was removed by order of the district court from his elected position as Van Buren County Attorney, while deserving of disapproval, did not rise to the level of misconduct that would warrant the “drastic” remedy of a court order removing an elected official from office.The Supreme Court reversed the judgment of the district court and vacated the order removing Defendant from the office of county attorney, holding that the State’s evidence was insufficient to meet the high bar necessary for the removal of Defendant from his elected office. The Supreme Court remanded the case for entry of an order reinstating Defendant as Van Buren County Attorney. View "State v. Watkins" on Justia Law

The district court order disqualifying an attorney from representing a criminal defendant, based primarily on speculative evidence of a potential conflict, constituted “an untenable ground for the district court to exercise its discretion.”The Supreme Court reversed the order of the district court granting the State’s motion to disqualify attorney Steven Gardner from defending Carlos Ramon Mulatillo on felony drug charges. Less than two weeks before the jury trial was to commence, Mulatillo and Gardner were informed of the name of a confidential informant and the potential conflict of interest between Gardner and this individual. Gardner had previously represented the confidential informant for approximately one month on felony drug charges. After a Watson hearing, the district court concluded that there was a serious potential for a conflict of interest that precluded Gardner from representing Mulatillo. The Supreme Court reversed, holding that the evidence provided by the State did not rise to the level of substantial evidence that was necessary to prove that Gardner’s continued representation of Mulatillo created a serious potential for an actual conflict of interest. View "State v. Mulatillo" on Justia Law

The Iowa District Court for Story County issued an order appointing the local public defender of Nevada, Iowa to represent a juvenile, who had been detained. The public defender filed a motion to withdraw, citing conflicts of interest between the juvenile and other clients. After a detention hearing, the court ordered the juvenile’s transfer from detention to shelter care and then withdrew the local defender’s appointment and appointed new conflict-free counsel for the juvenile. The court subsequently taxed to the state public defender the court and travel costs related to the hearing for withdrawing from the representation of the juvenile prior to the hearing without first taking steps to secure alternative representation for the juvenile. The state public defender filed a petition for writ of certiorari in the Supreme Court, claiming that the district court acted illegally when it taxed the court and travel costs against the state public defender. The Supreme Court sustained the writ, holding that the district court exceeded its authority and made an error of law in determining that the state public defender or the local public defender violated either statutory or ethical duties under the circumstances of this case. View "State Public Defender v. Iowa District Court" on Justia Law

The Iowa Commission on Judicial Qualifications recommended that a magistrate, who maintained a website where he posted information regarding his availability to perform marriage ceremonies - for a fee - at locations other than the courthouse, be publicly reprimanded for violating the Iowa Code of Judicial Conduct. Some of the photos showed the magistrate wearing his judicial robes. Before the matter was submitted to the Supreme Court, the magistrate resigned. The Supreme Court concluded that the magistrate committed violations of Canon 1 and Iowa Code of Judicial Conduct Rules 51:1.2 and 51:1.3, holding that the code does not per se bar a judicial officer from publicizing his availability to perform marriage ceremonies but that some aspects of the advertising at issue in this case violated the code. View "In re James H. Martinek" on Justia Law