Justia Iowa Supreme Court Opinion Summaries

Sally Splittgerber suffered a fall while walking on a city sidewalk, leading to a personal injury lawsuit against the owner of the adjacent property, the lessee of that property (Bankers Trust), and the City of Des Moines. The plaintiffs alleged that these parties were negligent in maintaining the uneven sidewalk. After settling the claims, Bankers Trust sought contribution from the City for the settlement payment, arguing that the City, not the property owner or lessee, was responsible for maintaining the sidewalk.The district court, relying on the precedent set in Madden v. City of Iowa City, granted summary judgment in favor of the City. The court held that the City could impose liability on abutting landowners for damages resulting from other types of failures to maintain sidewalks, beyond just snow and ice removal. Bankers Trust appealed this decision, asking the Supreme Court of Iowa to overrule the Madden decision.The Supreme Court of Iowa agreed with Bankers Trust, stating that the Madden decision was wrongly decided. The court found that the City's attempt to shift costs and liability to abutting landowners for sidewalk maintenance and accidents beyond what the state statute allows was in direct conflict with the legislature's express determination about where such burdens reside. The court noted that the statute only permits cities to require abutting landowners to repair sidewalks if the city first notifies the landowners by certified mail that a repair is necessary, and only permits cities to hold abutting landowners liable for damages if they fail to remove snow and ice from the sidewalk.The court overruled the Madden decision, reversed the district court's summary judgment ruling, and remanded the case for further proceedings consistent with this opinion. View "Bankers Trust Company v. City Of Des Moines" on Justia Law

The plaintiff, Ron Myers, suffered a leg injury after slipping on a diving board at a city pool in Cedar Falls, Iowa. He sued the City of Cedar Falls, alleging that the diving board lacked a slip-resistant surface required by state regulations. The City moved for summary judgment, arguing that it was immune from liability under Iowa Code section 670.4(1)(l), which grants immunity to operators of municipal swimming pools unless there is a "knowing" violation of regulations. The district court granted the City's motion, concluding that Myers failed to establish a "knowing" violation of the regulations.Myers appealed the decision, and the case was transferred to the court of appeals. The court of appeals reversed the district court's decision, finding that there were factual questions about the condition of the diving board that precluded summary judgment. The City then sought further review from the Supreme Court of Iowa.The Supreme Court of Iowa accepted the City's invitation to overrule a previous decision, Sanon v. City of Pella, which had interpreted the "criminal offense" exception to immunity for operators of municipal swimming pools under Iowa Code section 670.4(1)(l) to include violations of agency regulations. The court found that Sanon was "egregiously wrong" and had caused ongoing problems. The court held that the legislature did not make violating swimming pool regulations a criminal offense, and therefore, the City was immune from liability under Iowa Code section 670.4(1)(l). The court vacated the decision of the court of appeals and affirmed the district court's summary judgment. View "Myers v. City of Cedar Falls" on Justia Law

The case revolves around a medical malpractice claim filed by Darrin P. Miller against Catholic Health Initiatives-Iowa, Corp. and several medical professionals. The claim arose from the death of Miller's wife, Meredith, who died after a car accident when an endotracheal tube was incorrectly placed in her esophagus instead of her trachea. Miller alleged that the medical providers breached the standard of care by incorrectly performing the intubation and failing to identify and correct the error.The defendants sought dismissal of the case on two grounds: the expert's certificate of merit was not signed under oath as required by Iowa Code section 147.140, and the expert, an anesthesiologist, was not qualified to testify against the defendant surgeons or respiratory therapist. The district court denied the defendants' motions, ruling that the expert's unsworn but signed letter substantially complied with the affidavit requirement and that the expert's qualifications satisfied section 147.139.The Supreme Court of Iowa reversed the district court's decision. The court held that the expert's signed but unsworn report did not substantially comply with section 147.140's affidavit requirement, and this violation was not cured by the expert's sworn declaration served over three months after the statutory deadline. The court did not reach the question of whether the expert anesthesiologist was qualified under section 147.139 to testify against these defendants. The case was remanded for dismissal of the medical malpractice claims with prejudice. View "Miller v. Catholic Health Initiatives-Iowa, Corp." on Justia Law

The case revolves around Lori Randolph, who was injured after falling down stairs in a rental property owned by Aidan, LLC. Randolph sued Aidan, alleging negligence in failing to provide safe stairs. Aidan, in turn, filed a third-party claim against Sioux City, asserting that a city employee had inspected the property and declared it compliant with the municipal code. Aidan claimed that the city was negligent in hiring, retaining, or supervising the unqualified inspector, and thus, should indemnify Aidan for any damages owed to Randolph. Sioux City moved to dismiss Aidan’s claim, arguing it was immune under Iowa Code section 670.4(1)(j).The district court denied Sioux City's motion to dismiss Aidan's claim. Sioux City and Randolph requested interlocutory review, which was granted. The Supreme Court of Iowa was tasked with reviewing the denial of Sioux City's motion for the correction of errors at law.The Supreme Court of Iowa reversed the district court's decision. The court held that Sioux City was immune from Aidan's claim under Iowa Code section 670.4(1)(j). The court reasoned that Aidan's claim for negligent hiring was "based upon" the negligence of Sioux City's employee in inspecting the stairs. Therefore, the claim fell within the scope of the immunity provided by section 670.4(1)(j). The court remanded the case for further proceedings, including the dismissal of Aidan's claim against Sioux City. View "Randolph v. Aidan, LLC" on Justia Law

In this case, decided by the Supreme Court of Iowa, Justin Loew, an employee of Menard, Inc., appealed the district court's decision that denied his claim for workers' compensation benefits. Loew had previously received benefits for a 20% functional impairment to his lower back caused by a work-related injury in 2015, which had been calculated using the industrial method and resulted in a 30% reduction in his earning capacity. In 2018, Loew suffered a second work-related injury to his lumbar spine which increased his functional impairment to 28%. Under the 2017 changes to the workers' compensation law, Loew's compensation for this injury was to be based solely on his functional impairment, since he returned to work at the same or greater wages. However, the workers' compensation commissioner denied Loew any additional benefits for his second injury, reasoning that Menard was entitled to offset the prior payment based on reduced earning capacity against the new claim for functional impairment.The Supreme Court of Iowa disagreed with the commissioner's reasoning and reversed the district court's judgment. The court held that it was incorrect to offset compensation based on loss of earning capacity (from the first injury) against compensation based on functional impairment (from the second injury), as these are incommensurables. Further, the court found that the commissioner erred in interpreting Iowa Code section 85.34(7) to preclude compensation for Loew's new permanent partial disability, as this statute only limits an employer's liability for preexisting disabilities that have already been compensated. Loew was seeking compensation for a new permanent partial disability, not a preexisting one, hence Menard was liable for this new disability. The court remanded the case back to the commissioner for further proceedings consistent with its opinion. View "Loew v. Menard, Inc." on Justia Law

In Iowa, a ten-year-old boy was treated at the University of Iowa Hospitals and Clinics (UIHC) for a dislodged feeding tube and died the next day. The boy's mother filed administrative tort claims on behalf of the child's estate prior to being appointed as the estate's administrator. The child's parents also individually claimed loss of consortium. The claims were dismissed by the district court, which ruled that the mother lacked authority to file a claim on behalf of the estate prior to her official appointment, and that the parents had not properly filed individual administrative tort claims.The Supreme Court of Iowa held that the district court was correct to dismiss the parents' individual claims as no individual administrative tort claims were filed. However, the court determined the district court had erred in dismissing the estate's claims, arguing that the mother's administrative tort claims were valid despite her not being appointed as the estate's administrator at the time of filing. The court explained that a representative may act to protect an estate's interests before being officially appointed and can ratify pre-appointment acts, granting them the same effect as acts that would occur after appointment. The court also confirmed that the district court did not abuse its discretion by refusing to permit the plaintiffs' new evidence. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "Anderson v. State of Iowa" on Justia Law

In this case, Charlene and Michael Jorgensen sued Dr. Adam Smith, his professional corporation (Adam Smith, M.D., P.C.), and Tri-State Specialists, L.L.P., a clinic that employed Dr. Smith, after Charlene underwent surgeries in 2016 and 2018 that they allege were botched by Dr. Smith. They specifically claim that Tri-State was negligent in retaining Dr. Smith despite knowledge of his unfitness to practice surgery. The Supreme Court of Iowa considered whether the Jorgensens were required to produce a "certificate of merit affidavit" containing an expert’s opinion that the clinic had breached the applicable standard of care by retaining Dr. Smith, under Iowa Code section 147.140 (2018). The court found that this requirement did not apply to the Jorgensens' claim of negligent retention. While Tri-State is considered a "health care provider" as per the definition in the Iowa Code, the language of the statute requiring a certificate of merit refers to negligence in the practice of a profession, occupation, or in patient care. The court concluded that in the context of section 147.140, the term "occupation" does not encompass the activities of entities such as Tri-State. Therefore, the court affirmed the lower court's decision denying Tri-State's motion for summary judgment. View "Jorgensen v. Smith" on Justia Law

In the early morning of January 26, 2019, Simranjit Singh was driving a truck on Interstate 80 in Cass County, Iowa, when he hit a cow that had wandered onto the road. Singh was injured and his truck was damaged. The cow, owned by defendant Michael McDermott, was killed. Singh sued McDermott for negligence, claiming that McDermott was negligent in letting his cow wander onto the highway.McDermott moved for summary judgment, arguing that there was insufficient evidence to show that he was negligent. The district court granted McDermott's motion and Singh appealed. The Iowa Court of Appeals affirmed the district court's decision, and Singh sought further review from the Supreme Court of Iowa.The Supreme Court of Iowa affirmed the decisions of the lower courts, noting that the record did not contain sufficient evidence to support a finding of negligence by McDermott. The court clarified that the mere presence of a cow on the highway, without more, does not establish negligence on the part of the cow's owner. The court explained that the common-law duty of cattle owners is a "duty of ordinary care," such as the care an "ordinarily prudent and careful farmer exercises under like circumstances" to keep cows out of the highway.In this case, the court found no direct or circumstantial evidence of negligence on the part of McDermott, noting that there was no evidence of any unmended defects in his fence or that he failed to secure a gate. Singh's contention that the mere presence of the cow on the highway constituted "prima facie evidence" of negligence was rejected as this regime was a product of a now-repealed statute. The court also rejected Singh's reliance on the doctrine of res ipsa loquitur, finding that there was no evidence that a cow would not have escaped "in the ordinary course of things" if McDermott had used reasonable care. View "Singh v. McDermott" on Justia Law

The Supreme Court of Iowa reviewed a case where a plaintiff, James Penny, brought a lawsuit against the City of Winterset and a police officer, Christian Dekker, for damages caused by a collision. Officer Dekker was responding to an emergency call and had his overhead lights and siren on. He was traveling northbound and James Penny was traveling westbound when their vehicles collided at an intersection. As a result of the collision, Penny sustained several injuries. The district court granted summary judgment in favor of the defendants, concluding that the police officer's conduct was not reckless. However, the Court of Appeals reversed this decision.On further review, the Supreme Court of Iowa found that Officer Dekker's conduct did not rise to the level of recklessness under Iowa law, affirming the district court's grant of summary judgment. The court noted that while Officer Dekker did not come to a complete stop at the stop sign, he was not required to do so under Iowa Code section 321.231(3)(a) if he slowed down to a speed "necessary for safe operation." The court concluded that while it may have been negligent for Officer Dekker not to have perceived the lights to his right as coming from Penny's vehicle rather than a farmhouse, this failure did not rise to the level of recklessness. Thus, the court vacated the decision of the Court of Appeals and affirmed the district court's judgment. View "Penny v. City of Winterset" on Justia Law

In the case before the Supreme Court of Iowa, the plaintiff, Renee Hummel, brought a medical malpractice suit against the defendants, Adam B. Smith, Adam Smith, M.D., P.C., and Tri-State Specialists, L.L.P. The defendants requested an interlocutory review of a lower court order that denied their motion to strike and for summary judgment. The issue at the heart of the defendants' motion was that the expert who signed the plaintiff's certificate of merit did not have an active license to practice medicine.The Supreme Court of Iowa reversed the lower court's decision and remanded the case. The court determined that an expert who signs a plaintiff's certificate of merit in a medical malpractice case must have an active license to practice medicine. Therefore, the lower court erred in denying the defendants' motion to strike and for summary judgment on the basis that the plaintiff's certificate of merit was signed by an expert without an active medical license. View "Hummel v. Smith" on Justia Law