Justia Iowa Supreme Court Opinion Summaries

Articles Posted in Real Estate & Property Law
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In this case disputing whether a drainage district properly reclassified benefits in connection with a drainage repair project the Supreme Court affirmed, holding that the lower courts did not err.The drainage district at issue was formed more than a century ago, and a railroad that traversed the land within the district court was assessed 4.81 percent of the benefit of installation of tiling. In 2018, the drainage district determined that repairs were needed to the tiling and sought to reclassify the land in the district to equitably apportion the cost of the new repairs. The reclassification commission recommended that one-half of the repair cost be assessed to the railroad through the reclassification process. The drainage district approved the reclassification. The railroad brought this action challenging the reclassification. The district court granted summary judgment for the railroad, concluding that the reclassification commission acted inequitably, and declared the reclassification of benefits null and void. The court of appeals affirmed. The Supreme Court affirmed, holding that the railroad met its burden of showing that the assessment was inequitable and improper as a matter of law. View "Union Pacific Railroad Co. v. Drainage District 67 Board of Trustees" on Justia Law

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In this dispute over the just compensation award for commercial property the Supreme Court held that the district court did not abuse its discretion by limiting the testimony of the property owner regarding his opinion testimony that sales of other commercial property were comparable where that opinion required technical or specialized knowledge.An Iowa municipality condemned part of the owner's undeveloped land for a road. The district court allowed the owner to opine as to the site's reduction in value resulting from the taking but barred the owner's evidence of comparable sales on the grounds that the owner relied on hearsay and was unqualified as an expert. The Supreme Court affirmed, holding that the owner, a former restaurant manager, was not qualified as an expert under Iowa R. Evid. 5.702 to offer the opinion testimony given his lack of expertise and the complexity of these commercial real estate valuations. View "Rausch v. City of Marion" on Justia Law

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The Supreme Court reversed the district court's grant of summary judgment in favor of Plaintiff in this real estate dispute, holding that Plaintiff offered sufficient evidence to survive Defendants' motion for summary judgment.A few months after purchasing a home Plaintiff discovered water in the basement. Plaintiff later sued the sellers, her real estate agent, the seller's real estate agent, and a home inspector, alleging that they had misrepresented the condition of the house. The district court granted summary judgment for Defendants based on Plaintiff's failure to designate an expert on causation and damages. The court of appeals affirmed. The Supreme Court vacated the opinion of the court of appeals and reversed the summary judgment, holding that expert testimony was not required for Plaintiff to survive Defendants' motion for summary judgment on either causation or damages. View "Putman v. Walther" on Justia Law

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The Supreme Court reversed the judgment of the district court granting a tax deed holder possession of disputed property and remanded the case for dismissal, holding that Iowa R. Civ. P. 1.943 barred the tax deed holder's third forcible entry and detainer (FED) action, and the district court erred in concluding otherwise.At issue was Rule 1.943, under which a second voluntary dismissal of a tax deed holder's FED action operates as an adjudication on the merits unless the court orders otherwise. The tax deed holder in this case twice purported to dismiss without prejudice its FED petition against the property owner who was delinquent in paying taxes. The district court allowed the tax deed holder's third FED action to go forward. The Supreme Court reversed, holding that the district court erred by allowing the third FED action to go forward because it involved the same claim as the two prior actions. View "ACC Holdings, LLC v. Rooney" on Justia Law

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The Supreme Court reversed the ruling of the district court affirming the decision of the Public Information Board that the Polk County Assessor violated the Open Records Act by refusing to disclose a list of property owners who asked that their names be removed from the public name search function on the Assessor's website, holding that a statutory exemption applied.A reporter sought the list at issue, and the Assessor withheld it as exempt from disclosure under Iowa Code 22.7(18). Thereafter, the reporter filed a complaint with the Board, which ordered the Assessor to disclose the list. The district court affirmed. The Supreme Court reversed and remanded the case, holding (1) the Assessor had the burden to establish that the list was exempt under section 22.7(18); and (2) the Assessor met that burden, showing that the list is confidential, subject to resolution of an open issue. View "Ripperger v. Iowa Public Information Board" on Justia Law

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The Supreme Court affirmed the ruling of the district court that the contractual default interest rate applied in this dispute over the redemption of farmland and affirmed the court of appeals' decision requiring timely full payment of the amount necessary, holding that remand was required in this case.An attorney representing an investor underpaid the amount necessary to redeem farmland by at least $1,798 below the minimum owed. After concluding that the redemption was timely the district court resolved the parties' dispute over the interest rate by ruling that the contract default rate of twenty-one percent controlled, not the 4.25 percent nondefault rate. The court of appeals affirmed the twenty-one percent interest rate but concluded that the attempted redemption was untimely. The Supreme Court affirmed the judgment of the court of appeals and declined to grant equitable relief, holding that the court of appeals correctly held that the attempted redemption failed as untimely. View "Great Western Bank v. Clement" on Justia Law

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The Supreme Court reversed the order of the district court denying Defendants' motion to dismiss this petition seeking to force Defendants to enact legislation that will compel Iowa farmers to take action that will significantly reduce levels of nitrogen and phosphorus in the Raccoon River, holding that the motion to dismiss should have been granted.Plaintiffs - two social justice organizations - brought this case against Defendants - the State, four state agencies, and multiple state officials - seeking declaratory relief and to compel the State to adopt a "Raccoon River remedial plan with mandatory agricultural water pollution controls." Defendants moved to dismiss the petition based on lack of standing, nonjusticiability, and failure to exhaust administrative remedies. The district court denied the motion. The Supreme Court reversed, holding (1) the petition's attenuated causation theory was insufficient to establish that Plaintiffs' members suffered a concrete injury at the hands of Defendants that a favorable court decision was likely to redress; and (2) Plaintiffs' effort to repurpose the public trust doctrine to solve a complex environmental problem presented a nonjusticiable political question. View "Iowa Citizens For Community Improvement v. State" on Justia Law

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The Supreme Court reversed the judgment of the district court denying Hamilton County Public Hospital's motion for summary judgment concerning Plaintiff's defamation claim and Iowa Wage Payment Collection Law (IWPCL) claim, holding that Plaintiff's defamation and statutory wage claims failed.Plaintiff, a general surgeon, was employed by the hospital. After an investigation, Plaintiff's employment through a for-cause provision in his contract was terminated. The hospital subsequently made two reports to the Iowa Board of Medicine and the National Practitioner Data Bank. Plaintiff then brought this action. The hospital moved for summary judgment on the defamation and IWPCL claims, but the district court denied the motion. The Supreme Court reversed on interlocutory appeal, holding (1) Plaintiff's defamation claim failed because the challenged portions of the reports were nonactionable opinions; and (2) Plaintiff's statutory wage claim failed because he did not perform work for which he was not paid. View "Andrew v. Hamilton County Public Hospital" on Justia Law

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The Supreme Court sustained Liquor Bike LLC's petition for writ of certiorari and vacated the district court's order disqualifying Liquor Bike's counsel on the ground that counsel's representation of Liquor Bike in this matter was directly adverse to a current client of counsel's law firm in another matter, holding that the district court abused its discretion.The district court disqualified Liquor Bike's counsel, Billy Mallory and Brick Gentry, P.C., in a boundary-dispute litigation, concluding that Mallory's representation of Liquor Bike violated Iowa Rule of Professional Conduct 32:1.7. Liquor Bike filed a petition for a writ of certiorari challenging the district court's disqualification of its counsel. The Supreme Court sustained the petition, holding that the district court did not subject the motion for attorney disqualification to strict scrutiny and, instead, found a concurrent conflict of interest where none existed. View "Liquor Bike, LLC v. Iowa District Court for Polk County" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals reversing the order of the district court insofar as it modified the rent rates, duration, and for-profit subleasing rights in certain farm leases entered into by a ward's conservator, holding that the court of appeals did not err.After entering into written leases with members of Marvin Jorgensen's family members, Marvin's court-appointed conservator filed a motion seeking direction on whether the farm leases were appropriate. The district court concluded that the leases were inconsistent with Marvin's past practices and reformed them to provide a discount. The court of appeals reversed the ruling as to the reformation of the conservator's farm leases with Marvin's daughter. The Supreme Court affirmed, holding that the court correctly modified the rent rates, duration and for-profits subleasing rights in the daughter's leases. View "In re Guardianship & Conservatorship of Marvin M. Jorgensen" on Justia Law