Justia Iowa Supreme Court Opinion Summaries

The Supreme Court granted further review of this dissolution-of-marriage case to consider the proper distribution of a retired spouse's monthly pension benefits. The district court awarded the entirety of those benefits to the retired spouse. The court of appeals reversed and divided the benefits between the spouses to the extent they were accrued during the marriage. The Supreme Court vacated the court of appeals decision in part and affirmed the district court's judgment as modified, holding that the court of appeals did not err in ruling that the benefits should have been divided but erred in dividing the benefits without taking into account the remaining allocation of property between the parties. Remanded. View "In re Marriage of O'Brien" on Justia Law

In this real estate dispute, some of the defendants filed a motion for sanctions, alleging Defendant brought the action to harass, cause unnecessary delay, and needlessly increase the cost of litigation. The district court ordered sanctions against Plaintiff's counsel for $1,000. The court of appeals affirmed the sanctions, ordering them payable to the jury and witness fund. The Supreme Court affirmed in part and vacated in part the court of appeals, holding (1) the district court did not abuse its discretion in fixing the amount of the sanction at $1,000; (2) the court abused its discretion by ordering the sanction be paid to the jury and witness fund; and (3) given Rule 1.413(1)'s preference of compensating victims, the district court should enter an order requiring Plaintiff's counsel to pay the sanction in equal sums to the defendants who sought the sanction as partial reimbursement of the legal fees they incurred in defending against the unfounded claims brought against them. Remanded. View "Rowedder v. Anderson" on Justia Law

An owner and contractor entered into an agreement for the construction of a new home. During construction, the owner refused to pay the contractor after discovering markups on the cost of materials. In response, the contractor halted construction and filed an action to enforce a mechanic's lien. The contractor subsequently filed a petition to foreclose the mechanic's lien. Although the contractor did not complete construction, the district court found the contractor rendered substantial performance under the contract and entered a judgment against the owner. The court of appeals affirmed. The Supreme Court affirmed in part and vacated in part the court of appeals and reversed the district court, holding that the trial court erred in concluding that the contractor had substantially completed work for the owner. Remanded. View "Flynn Builders, L.C. v. Lande" on Justia Law

In this interlocutory appeal, the Supreme Court reviewed the district court's ruling consolidating condemnation appeals from proceedings by two separate condemning authorities taking property from the same parent tract of farmland. The takings were four months apart for unrelated projects. The district court consolidated the landowner's appeals, finding common question of law or fact and a lack of prejudice. The Supreme Court reversed, holding that consolidation was an abuse of discretion, as (1) fact finders must determine just compensation for different types of takings by separate condemning authorities four months apart for unrelated projects; and (2) certain evidence in each case would be inadmissible in the other, thus creating a substantial risk of prejudice and jury confusion. Remanded for separate trials. View "Johnson v. Metro. Wastewater Reclamation Auth." on Justia Law

The board of directors of a nonprofit condominium association approved necessary but nonemergency repairs to the association's parking garage without a full vote by its members. The repairs were completed at an amount eight times greater than the theshold in the bylaw, which required preapproval of a supermajority of owners to authorize certain expenditures exceeding $25,000. Several condominium owners sued for a judicial declaration that the board's violation of the bylaw's preapproval requirement excused their obligation to pay. The association counterclaimed against the owners to collect their share of the completed repairs and for attorney fees. The district court ruled in favor of the owners. The Supreme Court reversed, (1) holding that the business judgment rule applies to the governance decisions of this board when it acts within its authority; and (2) because the bylaw at issue was ambiguous, the Court deferred to the board's authority under the governing declaration to decide questions of interpretation or application of the bylaws. Remanded. View "Oberbillig v. W. Grand Towers Condo. Ass'n" on Justia Law

Husband obtained a purchase-money mortgage from Bank to invest in commercial real estate. Wife's signature was forged in executing the purchase-money mortgage. After Husband's death, Bank attempted to foreclose its mortgage, but Husband's Estate and Wife asserted Wife's fraudulent signature voided the mortgage. The district court (1) granted Bank summary judgment, concluding its purchase-money mortgage was superior to Wife's statutory dower interest and the Estate's other debts and charges; and (2) ordered any excess sale proceeds to be paid to the Estate. The court of appeals (1) affirmed the award of summary judgment; but (2) reversed the district court's determination that the foreclosure sale surplus be paid to the Estate, instead holding that Wife's statutory dower interest took priority over the Estate's other debts and charges. The Supreme Court affirmed the court of appeals, holding that a surviving spouse's dower interest, codified in Iowa Code 633.211 as to nonhomestead real property, was not subject to the debts and charges of the Estate of the spouse who died intestate. View "Freedom Financial Bank v. Estate of Boesen " on Justia Law

In this condemnation case, Plaintiffs brought an action against the Iowa Department of Transportation (IDOT) and the State. IDOT's motion to dismiss was granted. Subsequently, the district court granted summary judgment for the State, concluding that Plaintiffs' exclusive remedy was a mandamus action to compel condemnation proceedings. The court then dismissed the first action. Before the district court had entered its summary judgment ruling, Plaintiffs petitioned for writ of mandamus against IDOT in a second action. After the court granted summary judgment for the State, IDOT filed a motion for summary judgment, arguing that the dismissal of the first action barred Plaintiffs from bringing the second action under both claim and issue preclusion. The district court disagreed and granted Plaintiffs' requested writ of mandamus. Defendants appealed on the issue of claim preclusion. The Supreme Court affirmed, holding that when a court order dismissing an action reveals the court's intent to preserve a claim arising out of the same transaction that is pending in another lawsuit, the claim in the other lawsuit should be allowed to proceed. View "Lambert v. Dep't of Transp." on Justia Law

Plaintiffs, landowners, challenged special assessments against their property for public improvements to a residential subdivision made by the city. Plaintiffs argued that the city council's decision to make public improvements within a subdivision rendered the city unable to assess the costs of the improvements to the landowners when a city ordinance provided for the improvements to be made by the subdivider. The district court (1) determined the city failed to enforce a subdivision ordinance requiring the subdivider to pay for street improvements but concluded that Plaintiffs failed to state a claim upon which relief could be granted because a city cannot be sued for its failure to enforce ordinances; and (2) found the assessments were not excessive. The Supreme Court affirmed, holding (1) Plaintiffs failed to state a claim upon which relief could be granted, (2) the city's failure to require the subdivider to personally make all improvements did not invalidate the authority of the city to assess property owners, and (3) the Plaintiffs did not establish the assessments to their property exceeded the special benefits provided by the improvement. View "Nelson v. City of Hampton" on Justia Law

During the administration of Ralph Roethler's estate, the executor of the estate did not notify Becky and Kent Lewis that Roethler's will gave the Lewises a first right to purchase eighty acres of farmland. The Lewises later sought to reopen Ralph Roethler's etate to allow them to exercise the option. The district court held that the Lewises met the statutory grounds set out in Iowa Code 633.489 to reopen the estate. The court of appeals reversed, holding that the Lewises' petition to reopen was time-barred. On review, the Supreme Court vacated the decision of the court of appeals and affirmed the district court's judgment, holding (1) the Lewises' petition to reopen satisfied the statutory grounds set forth in section 633.489 to reopen an estate, and (2) the district court properly construed the will to permit the Lewises to exercise their first right of purchase irrespective of the executor's intent to sell the land. View "In re Estate of Roethler" on Justia Law

Bill Ernst gave Johnny Vajgrt permission to enter his property to remove a fallen tree. Vajgrt subsequently uprooted approximately forty live trees on Ernst's property. After Vajgrt died, Ernst filed a claim seeking compensatory damages and exemplary damages for the diminution of value of property, value of trees, and expenses for restoration of property. In addition, Ernst sought punitive damages. The district court awarded Ernst compensatory damages but declined to award any punitive damages, stating that it was well settled in Iowa that punitive damages may not be recovered from the estate of a deceased tortfeasor. On appeal, the Supreme Court affirmed, concluding that it would defer to the legislature's prior decisions and the Court's established precedents as it was not persuaded that it should reconsider those precedents. View "In re Estate of Vajgrt" on Justia Law