Justia Iowa Supreme Court Opinion SummariesArticles Posted in Personal Injury
Hoffman v. Clark
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
Beverage v. Alcoa, Inc.
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
Posted in: Personal Injury, Products Liability
Tripp v. Scott Emergency Communication Center
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
Estate of Farrell v. State
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
Chavez v. MS Technology LLC
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
Carlson v. Second Succession, LLC
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
Posted in: Civil Procedure, Personal Injury
Mengwasser v. Comito
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
Askvig v. Snap-On Logistics Co.
The Supreme Court affirmed the order of the district court granting Employer's motion to dismiss a petition for judicial review as untimely, holding that the district court correctly dismissed Claimant's petition for judicial review.Claimant sustained a work injury and pursued workers' compensation benefits. The workers' compensation benefits ordered Employer to pay temporary total disability benefits related to Claimant's right extremity injury but rejected Claimant's claim that she had also sustained a right shoulder occupational injury. According to Iowa Code 17A.19(3), Claimant had thirty day to file a petition for judicial review. Claimant's attorney failed to file the petition by the deadline. When the attorney realized his oversight, Claimant filed a petition for judicial review. The district court dismissed the petition as untimely. The Supreme Court affirmed, holding that the district court did not err. View "Askvig v. Snap-On Logistics Co." on Justia Law
Lukken v. Century, Inc.
The Supreme Court reversed the ruling of the district court granting summary judgment in favor of the owner of a zip line in this personal injury action, holding that exculpatory clauses purporting to negate liability for acts that are wantonly or recklessly committed generally violate public policy.Mt. Crescent Ski Area contracted with Challenge Quest, LLC to build and install a zip line. When Plaintiff took the zip line an employee had failed to reset the zip line's braking system after the previous rider existed. Consequently, Plaintiff slammed into a wood pole at the base of the zip line and fractured his neck. Plaintiff sued Challenge Quest and Mt. Crescent. The district court granted summary judgment in favor of Challenge Quest, concluding that it owed no duty to Plaintiff because it didn't install the allegedly defective braking system in place when Plaintiff was injured. The district court also granted summary judgment for Mt. Crescent based on a liability waiver that Plaintiff signed before riding. The Supreme Court reversed the summary judgment ruling as to Mt. Crescent, holding that the contractual waiver limiting Mt. Crescent's liability was unenforceable to the extent it purported to eliminate liability for the willful, wanton, or reckless conduct that Plaintiff alleged. View "Lukken v. Century, Inc." on Justia Law
Koster v. Harvest Bible Chapel–Quad Cities
The Supreme Court affirmed the judgment of the district court granting summary judgment to Defendants and dismissing Plaintiff's breach of fiduciary and defamation claims, holding that summary judgment was proper.Ryan Koster, a former member of Harvest Bible Chapel (HBC), a nondenominational Christian church, filed suit against HBC and three of its pastors, alleging breach of fiduciary duty, invasion of privacy, defamation, vicarious liability, and conspiracy. The district court granted summary judgment to Defendants as to all counts. Koster appealed, challenging the dismissal of the breach of fiduciary duty and defamation claims. The Supreme Court affirmed, holding that defamation was warranted on these claims. View "Koster v. Harvest Bible Chapel–Quad Cities" on Justia Law