Justia Iowa Supreme Court Opinion Summaries

In this interlocutory appeal in a case involving claims for injuries resulting from a high-speed chase, the Supreme Court reversed the decision of the district court denying the State's motion for summary judgment, holding that the State was entitled to summary judgment under Iowa Code 321.231.Law enforcement officer Brett Tjepkes was chasing Scott Grimes, the perpetrator of a multi-state crime spree, when Grimes crashed head-on with another vehicle. Amber Martinez, the sole occupant of the car he hit, suffered serious injuries. Martinez brought suit, alleging that the Officer Tjepkes acted negligently, causing her injuries. The State moved for summary judgment, arguing that Tjepkes could not be held legally liable as the cause of the crash. The district court denied the motion, finding that a disputed issue of fact existed as to whether Tjepkes's actions were reckless. The State brought this interlocutory appeal. The Supreme Court reversed, holding that no reasonable jury could find that Tjepkes's decision to pursue Grimes was reckless. View "Martinez v. State" on Justia Law

The Supreme Court reversed the order of the district court dismissing with prejudice Plaintiff's petition asserting claims arising under the Iowa Municipal Tort Claims Act (IMTCA), holding that the district court erred in dismissing the case with prejudice after Plaintiff had already voluntarily dismissed his case without prejudice.Iowa Code 670.4A sets forth a qualified immunity defense to and heightened pleading requirements for claims arising under the IMTCA. Plaintiff sued the City of Waterloo and one of its police officers, alleging that the officer shot him without justification. Defendants moved to dismiss the petition pursuant to section 670.4A. The day before a scheduled hearing on the motion Plaintiff dismissed his petition without prejudice. The district court granted Defendants' motion to set aside the dismissal with prejudice based on Plaintiff's alleged failure to meet the statutory pleading requirement. The Supreme Court reversed, holding that nothing in the language of section 670.4A required dismissal with prejudice. View "Alvarez-Victoriano v. City of Waterloo" on Justia Law

In this interlocutory appeal, the Supreme Court reversed the decision of the district court ordering certain records produced to Plaintiff in discovery before trial, holding that the district court erred by relying on civil discovery rules to compel production of the records at issue.Plaintiff's daughter was killed in a motorcycle accident. Plaintiff brought a tort action against the driver of the motorcycle and settled without subpoenaing the county sheriff's investigative reports. After a criminal investigation and prosecution of the driver was complete Plaintiff brought this enforcement action under Iowa Code chapter 22 against the county sheriff's department seeking to obtain its complete investigation file. The district court ordered the records produced to Plaintiff in discovery before trial without ruling on their confidentiality. The Supreme Court reversed, holding that the district court erred in compelling disclosure of the sheriff's investigation materials to Plaintiff's counsel. View "Vaccaro v. Polk County" on Justia Law

The Supreme Court affirmed in part and vacated in part the ruling of the court of appeals affirming the jury's verdict on libel-per-se damages and punitive damages, holding that remittitur was appropriate in this case.After a jury trial, Hoffmann Innovations, Inc. and Jerry Hoffmann were awarded $11 million in compensatory and punitive damages against Scott Clark based on defamatory statements that Clark made on social media and in podcasts. During the proceedings, the trial court repeatedly sanctioned Clark for violating a consent order preventing both parties from making disparaging statements about each other. Ultimately, the court struck Clark's answer and affirmative defenses in an attempt to secure compliance with sanctions. Without any defense pleaded to the claims, the trial proceeded on only the amount of damages. The Supreme Court reversed in part, holding that the jury used the wrong measure of damages on the damages awarded and that remittitur was also appropriate for punitive damages. View "Hoffman v. Clark" on Justia Law

The Supreme Court reversed the decision of the district court granting summary judgment in favor of Defendants on Plaintiffs' premises liability claims against Alcoa Inc. and on their products liability claims against Iowa-Illinois Taylor Insulation, Inc. (IITI) for supplying asbestos-containing insulation in the Alcoa plant, holding that the district court erred.At issue was the provision in Iowa Code 686B.7(5) that a "defendant in an asbestos action or silica action shall not be liable for exposures from a product or component part made or sole by a third party." In the instant asbestos case, the district court read the statute to limit liability to manufacturers of the asbestos-containing product at issue. The district court held that section 686B.7(5) granted immunity to Alcoa and IITI because the asbestos-containing insulation was manufactured by third parties. The Supreme Court reversed, holding that the district court failed to appreciate the legal significance of the legislature's use of the phrase "produce or component part made or sold by a third party" to reference a products liability defense known as the component parts defense as described in the specific context of asbestos litigation. View "Beverage v. Alcoa, Inc." on Justia Law

The Supreme Court reversed the judgment of the district court affirming the decision of the workers' compensation commissioner denying Petitioner's petition for benefits for trauma-induced mental injuries she suffered on the job while working as emergency dispatcher, holding that because Petitioner established that her PTSD resulted from a manifest happening of a sudden traumatic nature from an unexpected cause or unusual strain, Petitioner was entitled workers' compensation benefits.Petitioner, a sixteen-year veteran of the county emergency dispatch system, sought benefits for the PTSD she suffered after taking a 911 call from a woman screaming over and over at a high pitch, "Help me, my baby is dead." The workers' compensation commissioner and district court denied benefits, concluding that the mother's call wasn't an "unexpected cause or unusual strain." The Supreme Court reversed, holding that Petitioner was entitled to benefits because she established that her PTSD resulted from a manifest happening of a sudden traumatic nature from an unexpected cause or unusual strain. View "Tripp v. Scott Emergency Communication Center" on Justia Law

The Supreme Court vacated the decision of the court of appeals concluding that the public-duty doctrine barred Plaintiffs' tort claims against the State of Iowa and two municipalities, holding that the district court correctly denied Defendants' motion for judgment on the pleadings.This case arose from an accident in which a driver traveling the wrong way on Interstate 80 collided with another vehicle, killing all of the occupants. Plaintiffs brought this action alleging that Defendants were liable because of their role in negligently constructing and operating a confusing interchange used by the errant driver. Defendants filed a joint motion for judgment on the pleadings under the public-duty doctrine, which the district court denied. The court of appeals reversed, concluding that the public-duty doctrine barred all of Plaintiffs' claims against Defendants. The Supreme Court vacated the decision below and remanded the case for further proceedings, holding that complaint was sufficient to avoid application of the public-duty doctrine for purposes of adjudicating the motion for judgment on the pleadings. View "Estate of Farrell v. State" on Justia Law

The Supreme Court affirmed the decision of the district court affirming the conclusion of the workers' compensation commissioner that Claimant's rotator cuff injury was a scheduled shoulder injury rather than an unscheduled whole body injury under Iowa Code 85.34(2), holding that there was no error.Claimant sustained a work-related injury that was diagnosed as a "full thickness rotator cuff tear that has retracted to the level of the glenoid, severe AC arthrosis, tendonitis and tearing of the biceps tendon." In seeking permanent partial disability benefits, Claimant argued that her injury qualified as an unscheduled injury to the body as a whole, entitling her to industrial disability benefits. The commissioner concluded that Claimant's rotator cuff injury was a scheduled injury to the shoulder, and the district court affirmed. The Supreme Court affirmed, holding that the district court properly determined (1) Claimant's rotator cuff injury was a scheduled shoulder injury under Iowa Code 85.34(2)(n); and (2) substantial evidence supported the commissioner's finding that Claimant failed to prove her biceps tear resulted in a permanent disability to her arm under section 85.34(2)(m). View "Chavez v. MS Technology LLC" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the judgment of the district court concluding that Plaintiff's filed petition did not relate back to her previously rejected filing, holding that the district court did not err in granting Defendants' motion to dismiss.Plaintiff filed this personal injury suit against Defendants one day after the two-year statute of limitations set forth in Iowa Code 614.1(2). Defendants filed a motion to dismiss the petition on the grounds that Plaintiffs' claims were time-barred. In response, Plaintiff argued that her untimely petition related back to the date she attempted to file her petition but the clerk of court rejected it due to Plaintiff's failure to include personal identification information with the proposed filing. The district court dismissed the action, concluding that the filed petition did not relate back to the rejected filing. The court of appeals affirmed. The Supreme Court affirmed, holding that Plaintiff's filing did not relate back to her attempted filing. View "Carlson v. Second Succession, LLC" on Justia Law

The Supreme Court remanded this case for a new trial, holding that the district court misapplied changes to the Iowa Rules of Civil Procedure when it excluded certain evidence in this case, and the ruling may have affected the outcome of trial.In 2014, the amendments to the Iowa Rules of Civil Procedure were adopted, inspired by prior changes to the federal rules. In the instant case, the district court excluded certain expert opinions of Plaintiff's treating chiropractor on the grounds that the chiropractor had not formed those opinions during treatment and Plaintiff had not submitted a timely expert report required under Iowa R. Civ. P. 1.500(2)(b). The Supreme Court reversed, holding that because the 2014 rule changes allow parties to submit more limited rule 1.500(2)(c) disclosures for experts who have not been retained for purposes of litigation the district court abused its discretion in its evidentiary ruling. View "Mengwasser v. Comito" on Justia Law