Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing Plaintiff's claim alleging she suffered permanent lung injury from toxic vapors that spread throughout the building where she worked, holding that Plaintiff did not present evidence to create a dispute of material fact as to the element of causation.A maintenance worker at the multistory medical office building where Plaintiff worked used a chemical drain cleaner to clear a clogged restroom sink on a lower level. Plaintiff claimed that her inhalation of the fumes the building aggravated her preexisting asthmatic condition and permanently caused reduced pulmonary function. The district court granted Defendant's motion to dismiss, concluding that there was insufficient evidence presented that the chemical fumes caused the lung injury alleged by Plaintiff. The Supreme Court affirmed, holding that Plaintiff presented insufficient evidence about whether the dose of toxin to which she was exposed was capable of causing her alleged permanent injury. View "Uhler v. Graham Group, Inc." on Justia Law

The Supreme Court reversed the judgment of the district court denying Thomas L. Cardella & Associates' (Cardella) motion for judgment notwithstanding the verdict in this case alleging common law negligent supervision or retention, holding that the claim was barred by the Iowa Workers' Compensation Act (IWCA), Iowa Code ch. 85.Plaintiff sued Cardella two years after she quit her employment there. Because she missed the deadline for bringing a hostile work environment claim under the Iowa Civil Rights Act (ICRA), Iowa Code ch. 216, Plaintiff sued for common law negligent supervision or retention and presented her claim to the jury seeking emotional distress damages related to her mental health as a negligent supervision claim premised on Cardella failing to protect her from assault and battery. After a trial, the jury awarded Plaintiff $400,000 in emotional distress damages. The Supreme Court reversed, holding that, as presented to the jury, Plaintiff's claim was barred by IWCA. View "McCoy v. Thomas L. Cardella & Associates" on Justia Law

The Supreme Court affirmed in part and reversed in part the order of the district court denying Polk County's motion to dismiss this tort action under Iowa Code 670.4A, a new provision of the Iowa Municipal Tort Claims Act, and Iowa R. Civ. P. 1.421, holding that only two of the four counts met the applicable pleading standards.Plaintiff, a former County employee, brought this tort action against the County and members of the Polk County Board of Supervisors challenging his termination. In denying Defendants' motion to dismiss, the district court concluded that Iowa's recently-enacted qualified immunity provision did not apply retrospectively and that Plaintiff satisfied section 670.4A's new pleading requirement for qualified immunity defenses. The Supreme Court affirmed the district court's decision allowing counts one and four to proceed and reversed the district court with respect to the five remaining counts, holding (1) because the legislature did not expressly make subsection 670.4A(3) retrospective, it could not be applied in this case; and (2) of the petition's seven counts, only counts one and four met the applicable pleading standards and survived Defendants' motion to dismiss as a matter of law. View "Nahas v. Polk County" on Justia Law

The Supreme Court affirmed the summary judgment granted by the district court in favor of the City of Muscatine on claims seeking to hold the City vicariously liable for a former police officer's sexual assault, holding that Plaintiff was not entitled to relief as to her allegations of error.Plaintiff, who was drunk, was offered a ride to a hotel by a police officer. The officer followed Plaintiff to her room and raped her. The officer was convicted of third-degree sexual abuse of an incapacitated person. Plaintiff later sued the officer and the City alleging several tort causes of action. The district court granted summary judgment to the City, determining that Plaintiff failed to prove that the assault was within the scope of the officer's employment. The Supreme Court affirmed, holding that the district court (1) did not err in determining that Plaintiff's sexual assault fell outside his scope of employment; and (2) this Court declines to adopt Plaintiff's proposed aided-by-agency theory to impose vicarious liability on the City. View "Martin v. Tovar" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment to a police detective and his city employer in this case alleging defamation, abuse of process, and malicious prosecution, holding that there was no error.Plaintiff, who was acquitted of a sexual assault charge, sued county prosecutors and city police for allegedly pursuing the case against him. The Supreme Court held that the county prosecutors were entitled to dismissal from the case but rejected the investigating detective's arguments for dismissal on the pleadings. The district court ultimately granted summary judgment to the detective and the city. The Supreme Court affirmed, holding that the district court (1) properly granted summary judgment to the city defendants on Plaintiff's continuing malicious prosecution claim; and (2) did not err in dismissing Plaintiff's direct claims for damages under the Iowa Constitution. View "Venckus v. City of Iowa City" on Justia Law

The Supreme Court affirmed the judgment of the district court denying the motion filed by the Council Bluffs Water Works' to dismiss the claim brought by Jim and Angela Sutton for strict liability, holding that the district court did not err in failing to dismiss Suttons' strict liability claim.After an underground water main broke near the Suttons' home the Suttons sued Water Works for the ensuing damage to their house, alleging strict liability and negligence. Water Works moved to dismiss the strict liability claim on the grounds that the Iowa Municipal Tort Claims Act, Iowa Code ch. 670, did not permit a strict liability claim against it. The district court denied the motion, and Water Works filed an application for interlocutory appeal. The Supreme Court affirmed, holding that the Act does not allow a claim for strict liability against a municipality for damage caused by an underground water main break. View "Sutton v. Council Bluffs Water Works" on Justia Law

On interlocutory appeal and cross-appeal of a ruling on a motion to dismiss the state constitutional tort and common law claims arising out of a warrantless arrest of Plaintiff's spouse the Supreme Court affirmed in part and reversed in part, holding that the district court erred in denying Defendants' motion to dismiss Plaintiff's claims for intentional infliction of emotional distress (IIED) and trespass.Plaintiff brought this lawsuit against law enforcement officials and their employers asserting state constitutional tort claims, as well as common law claims for assault, trespass, and intentional infliction of emotional distress. Defendants filed a motion to dismiss. The district court granted the motion as to the state constitutional tort claims but denied it as to the common law claims. Plaintiff applied for, and Defendants' cross-applied for, interlocutory appeal. The Supreme Court (1) affirmed the district court's dismissal of Plaintiff's state constitutional tort claims and assault claim, holding there was no error; and (2) reversed the denial of Defendants' motion to dismiss the IIED and trespass claims, holding that there was sufficient evidence to support this claim. View "White v. Harkrider" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment to Defendants and dismissing Plaintiff's various legal theories of direct damages liability under the Iowa Constitution, holding that Godfrey v. State, 898 N.W.2d 844 (Iowa 2017), is hereby overruled.Plaintiff, a garbage truck driver, was stopped on a busy high by a Iowa Department of Transportation (IDOT) officer for a cracked windshield. During the interaction, Plaintiff was arrested and later charged with interference with legal acts. He was later acquitted of the charge, and subsequently sued the State and the IDOT officer, arguing that his passive noncooperation did not give the officer probable cause to arrest him. The district court granted summary judgment for the defendants. Plaintiff appealed and asked the Court to endorse his constitutional tort claim under Godfrey. The Supreme Court affirmed, holding (1) this Court overrules Godfrey and restores the law as it existed before 2017; and (2) this Court no longer recognizes a standalone cause of action for money damages. View "Burnett v. Smith" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment to Defendants as to some of Plaintiff's claims and the judgment entered on the defense verdicts on Plaintiff's remaining defamation claims, holding that Plaintiff had not shown grounds for reversal.Plaintiff, the former principal at St. Joseph's Catholic School, brought this action against Father Josephs Pins, St. Joseph's Church, and the Diocese of Des Moines after her employment was terminated, alleging fraud and defamation by all defendants and breach of contract against Father Pins. The district court granted summary judgment in favor of Defendants as to Plaintiff's fraud, breach of contract, and defamation claims, and then a jury returned defense verdicts on the remaining defamation claims. The Supreme Court affirmed, holding that Plaintiff was not entitled to reversal on his allegations of error. View "Konchar v. Pins" on Justia Law

The Supreme Court affirmed the rulings of the district court and court of appeals that the workers' compensation commissioner erred in granting Employer's motion for summary judgment and dismissing Employee's review-reopening petition, holding that Employee was permitted to pursue a claim for a permanent injury in a review-reopening proceeding despite an earlier adjudication that her injury was not permanent.Employee was injured during the course and work of her employment. Employee filed a petition seeking workers' compensation for a permanent disability, but the deputy commissioner refused to order additional benefits beyond those that Employer had already paid. Employee filed a petition for review-reopening with the workers' compensation commission. The commission determined that Employee's claim for permanent disability benefits was barred by principles of res judicata. The district court reversed, and the court of appeals affirmed. The Supreme Court affirmed, holding that the agency erred in dismissing Employer's review-reopening petition. View "Green v. North Central Iowa Regional Solid Waste Authority" on Justia Law