Justia Iowa Supreme Court Opinion Summaries

The case involves a dispute over the boundary between two parcels of land in Wapello County, Iowa. The northern parcel was owned by the Handlings and the southern parcel by the Sims. Both parties treated a fence line as the boundary between their properties for many years. In the mid-1990s, Scott Hubbell began leasing both properties for farming. In 2004, he built a machine shed south of the fence line, assuming it was on the southern property. In 2014, Hubbell and his wife purchased both properties, becoming the sole owners. In 2017, they sold the southern property to the Remmarks and in 2018, they sold the northern property to Sundance Land Company. A survey commissioned by Sundance revealed that the legal boundary between the properties ran south of the fence line, meaning the machine shed was encroaching onto the northern property. Sundance filed a petition to quiet title according to the survey boundary lines, alleging that the Remmarks were trespassing on the northern property.The district court found that a boundary line by acquiescence had been established at the old fence line during the Handlings’ and Sims’ respective ownership of the properties. The court rejected Sundance’s argument that the Hubbells’ common ownership of both parcels from 2014 to 2017 erased the boundary by acquiescence. The court of appeals affirmed the district court's decision.The Supreme Court of Iowa disagreed with the lower courts' decisions. The court held that when two adjoining parcels come under common ownership, any potential boundary by acquiescence between them is eradicated, and the ten-year clock for calculating boundary by acquiescence restarts when separate ownership resumes. The court vacated the decision of the court of appeals, reversed the district court judgment, and remanded for entry of judgment for Sundance in accordance with this opinion. View "Sundance Land Company, LLC v. Remmark" on Justia Law

The case involves a landowner, Medardo Rivera, who sought to clear an easement from his property. The easement was granted by a previous owner of the property to Clear Channel Outdoor, Inc., and later assigned to TLC Properties, Inc., an affiliate of Lamar Advertising Company. The easement allowed for the construction and operation of billboards on the property. Rivera argued that the easement was void as it was granted after he had already purchased the property.The district court granted summary judgment in favor of the easement holder, ruling that Rivera's action was time-barred under Iowa Code section 614.17A. This statute prevents actions to recover or establish an interest in real estate if the action is based on a claim arising more than ten years earlier, is against the holder of the record title to the real estate in possession, and the holder and their grantors have held chain of title to the real estate for more than ten years.The Supreme Court of Iowa reversed the district court's decision. The court agreed with Rivera's argument that section 614.17A could not apply to an action to clear an easement. The court reasoned that by its terms, section 614.17A only applies to claims against a "holder of the record title to the real estate in possession." Because easements are nonpossessory interests, an easement holder does not possess the encumbered real estate, and so section 614.17A cannot apply to an action to clear an easement. The case was remanded for further proceedings. View "Rivera v. Clear Channel Outdoor, LLC" on Justia Law

An elderly woman, Janice Geerdes, and her long-time friend, Albert Gomez Cruz, had a partnership raising hogs on a piece of land. Initially, Janice deeded half of her interest in the land to Albert. Over a decade later, she deeded the rest of her interest in the land to Albert, receiving nothing in return. About six months later, Janice’s adult daughters were appointed her conservator and guardian. The conservator challenged the validity of the quitclaim deed based on undue influence and lack of capacity.The district court set aside the deed, finding that there was undue influence through a confidential relationship and that Janice lacked the necessary capacity to deed her interest in the land. The court of appeals affirmed the decision on the basis of lack of capacity.The Supreme Court of Iowa, however, disagreed with the lower courts. The Supreme Court found that the conservator did not establish by clear, convincing, and satisfactory evidence that there was undue influence or that Janice lacked capacity at the time of the gift. The court found that the lower courts gave too much weight to the perceived improvidence of the transaction and too little weight to the testimony of the third-party accountant who witnessed the transaction. Therefore, the Supreme Court vacated the decision of the court of appeals, reversed the district court judgment, and remanded for further proceedings. View "Conservatorship of Janice Geerdes v. Cruz" 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

The Supreme Court of Iowa affirmed the decision of the Court of Appeals and the District Court in favor of the City of Des Moines, in a case brought by Lime Lounge, LLC. Lime Lounge, a bar, challenged a city ordinance requiring it to obtain a conditional use permit (CUP) to operate. After receiving noise complaints, the City revoked Lime Lounge's CUP, which was upheld in a prior appeal. Lime Lounge then challenged the ordinance arguing it was preempted by Iowa Code, violated equal protection and spot zoning prohibitions. The trial court dismissed Lime Lounge's claims and this decision was affirmed by the Court of Appeals.The Supreme Court of Iowa found that the city's ordinance was not preempted by state law. Rather, it was a proper exercise of the city's zoning authority and did not create a separate local alcohol license. The Court also rejected Lime Lounge's equal protection claim, holding that the city had a legitimate purpose in imposing a CUP on specific businesses selling alcohol. Finally, the Court dismissed the claim of illegal spot zoning, as Lime Lounge failed to prove that the city had engaged in such activity. The Court thus affirmed the dismissal of Lime Lounge's challenge to the ordinance. View "Lime Lounge, Inc. v. City of Des Moines, Iowa" on Justia Law

In this case, the Iowa Supreme Court reviewed a dispute involving property owners David and Jeanie Vaudt and Wells Fargo Bank, which held the mortgage on neighboring property owned by Fredesvindo Enamorado Diaz and Denice Enamorado. The Vaudts had installed a landscaping barrier that encroached on the Enamorado's property. When the Enamorados disputed the boundary, the Vaudts filed a petition to quiet title, claiming boundary by acquiescence and adverse possession. Wells Fargo moved to dismiss the claims, arguing they were time-barred by a one-year statute of limitations related to property transfers by trustees. The district court agreed with Wells Fargo, citing a previous Iowa Supreme Court ruling (Heer v. Thola).The Vaudts appealed, asking the Supreme Court to overrule Heer. They argued their claims arose from the conduct of the Enamorados' predecessors in interest, not the transfer of property by the trustee's deed. The Supreme Court agreed with the Vaudts, stating that Heer incorrectly interpreted the statute of limitations, which applies specifically to claims arising from transfers by trustees, not to all adverse claims. The court overruled Heer, rejecting its broad application of the one-year statute of limitations to boundary-by-acquiescence claims.The court reversed the district court's dismissal of the Vaudts' claims, remanding the case for further proceedings. View "Vaudt v. Wells Fargo Bank, N.A." on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the decision of the Iowa Utilities Board (IUB) to grant MidAmerican Energy Company's petition for a franchise to build electric transmission lines in Madison County, some of which would run through a road right-of-way encumbering Appellant's land, holding that MidAmerican satisfied the statutory requirements for a franchise.Specifically, the Supreme Court held (1) MidAmerican satisfied the statutory requirement that new electric transmission lines must be necessary for a public use; (2) Iowa Code 306.46(1) provides utilities like MidAmerican with statutory authority to construct, operate, repair, or maintain their utility facilities with a public road right-of-way, including that right-of-way at issue in this case; and (3) as to the question of whether the construction of electric transmission lines within Appellant's right-of-way could result in a constitutional taking requiring compensation, this Court is evenly divided. View "Juckette v. Iowa Utilities Bd." on Justia Law

The Supreme Court affirmed the summary judgment of the district court concluding that a condominium owner-landlord owed no duty of care with respect to a downspout that discharged water directly onto a shared driveway, holding that the owner-landlord had no common law, contractual, or statutory duty to keep the driveway clear.The condominiums at issue in this case were subject to a horizontal property regime pursuant to Iowa Code ch. 449B, which, in turn, was governed by a document referred to as the declaration. Shelly and Cameron Barnes leased a condominium unit from CDM Rentals, LLC. After Shelly fell on ice on the shared driveway the Barneses brought this negligence lawsuit. The district court granted summary judgment for CDM on the ground that CDM lacked control over the common areas. The Supreme Court affirmed, holding (1) regarding premises liability, CDM lacked control of the driveway and downspout under the declaration; and (2) the district court correctly concluded that the Uniform Residential Landlord and Tenant Act, Iowa Code ch. 562A, requires landlords to maintain common areas but only to the extent the landlord has control over those areas. View "Barnes v. CDM Rentals, LLC" on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that "repowering" a wind plant, or replacing a substantial proportion of its parts, does not change the analysis for valuing wind plants for property tax purposes under Iowa Code 427B.26, holding that the district court did not err.Story County Wind, LLC (SCW) owned a wind energy conversion property. In 2019, a repowering project began for the wind plants. Because the Story County Assessor continued to value and assess the wind plants as before, in 2021, SCW filed a protest seeking to modify the assessment. The Board declined to modify the assessment. The Supreme Court affirmed, holding that, under section 427B.26, repowering a wind plant by replacing component parts does not charge the plants' valuation for property tax purposes. View "Story County Wind, LLC v. Story County Bd. of Review" on Justia Law

In this action concerning a lease renewal for property on which a cell tower was built the Supreme Court affirmed the judgment of the district court and the court of appeals in favor of a cell phone service company and dismissing this action brought by property owners, holding that there was no error.In 1988, the cell phone company entered into a thirty-year lease of the subject property that included a thirty-year renewal option. In 2018, when the lease came up for renewal, the rent was substantially below market, and the company gave written notice of renewal to the property owners. Because the company did not immediately pay the renewal rent the property owners brought suit arguing that the option had not been validly exercised. The district court granted judgment for the cell phone company, and the court of appeals affirmed. The Supreme Court affirmed, holding that the property owners were not entitled to relief on their allegations of error. View "Pitz v. U.S. Cellular Operating Co. of Dubuque" on Justia Law