Justia Iowa Supreme Court Opinion Summaries

Articles Posted in Real Estate & Property 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

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The Supreme Court reversed the district court's judgment denying Insurer's motion for directed verdict on this action concerning Insurer's alleged delay in paying a claim, holding that the district court erred in denying the motion for directed verdict on Insured's breach of contract and bad faith causes of action.A fire broke out in Insured's kitchen that resulted in a total loss of the building and its contents. Insured invoked its right to the appraisal process. The appraisers signed an appraisal letter establishing the loss amount at $502,000. Insurer paid the amount in full. Eight months later, Insured sued Insurer for breach of contract and bad faith based on Insured's failure to pay the $550,000 building coverage limit and for its actions during the appraisal hearing. The jury returned a verdict in favor of Insured and awarded $48,000 in damages. The Supreme Court reversed, holding (1) Insured's invocation of the appraisal process and Insurer's timely payment of the appraisal award required dismissal of the claims as a matter of law; and (2) Insured failed to prove bad faith for any actions taken after the appraisal hearing. View "Luigi's Inc. v. United Fire & Casualty Co." on Justia Law

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The Supreme Court affirmed in part and vacated in part the judgment of the court of appeals reversing the ruling of the district court finding that an amended pleading by the Estate of Francis O. Glaser related back to its original pleading and therefore permitted an additional conveyance to be set aside after the statute of limitations had lapsed, holding that the district court erred in concluding that the late amendment related back to the date of the original motion.The Estate in this case attempted to void a predate transfer of farm property by Glaser to a friend. In order to do so, at the close of the evidence, the Estate filed a motion to amend the original motion to set aside property conveyances that failed to mention the farm property. The district court permitted the late amendment and found that the amendment related back to the filing of the original motion. Therefore, the court concluded that the claim was not barred by the applicable statute of limitations and that the challenged conveyances should be set aside. The Supreme Court held, like the court of appeals, that the late claim to set aside the farm property was barred by the applicable statute of limitations. View "Kindsfather v. Bowling" on Justia Law

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The Supreme Court reversed the ruling of the district court striking Plaintiff's resistance to a motion for summary judgment and vacated the resulting summary judgment and bench trial judgment, holding that the district court abused its discretion by striking the entire resistance filing without any showing of prejudice or violation of a prior court order.On the last day of an extended deadline Plaintiff filed his resistance and supporting papers. The next day, the clerk of court rejected Plaintiff's filing because of the failure to redact Plaintiff's social security number. The district court granted Defendants' motion to strike the filing as untimely and noncompliant and subsequently granted summary judgment dismissing Plaintiffs' claims. A different judgment ultimately entered judgment for Defendants on their counterclaims. The Supreme Court reversed, holding that the district court abused its discretion by granting Defendants' motion to strike Plaintiff's resistance filings. View "Toney v. Parker" on Justia Law

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In this action seeking to set aside a sheriff's sale of the stock of Plaintiff's farm business the Supreme Court vacated the decision of the court of appeals reversing the decision of the district court concluding that Plaintiff's claims were untimely or barred by claim preclusion, holding that the court of appeals erred.In his motion to dismiss, Defendant argued that this action was repetitive of prior unsuccessful lawsuits and that Defendant was precluded under court order from filing any new actions regarding the sheriff's sale. The district court adopted Defendant's arguments in its dismissal order. The court of appeals reversed. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding that the district court correctly found that claim preclusion applies. View "Daniels v. Holtz" on Justia Law

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The Supreme Court affirmed the ruling of the district court granting summary judgment dismissing Kristina Lewis's negligence claims against Howard L. Allen Investments, Inc. (Allen Investments), holding that Allen Investments did not owe a duty to protect Lewis from the harm she suffered.Allen Investments sold a house under a contract of sale that required the buyers to make monthly payments for ten years. Five years into the payment period the buyers leased the house to Lewis and her fiancé. The house subsequently caught fire, causing Lewis to suffer serious injuries. Lewis brought this negligence action against the buyers and Allen Investments. The district court granted summary judgment for Allen Investments, concluding that the company, as a contract seller, owed no duty to Lewis. The Supreme Court affirmed, holding (1) Allen Investments was not the landlord of the property under Iowa's Uniform Residential Landlord and Tenant Act, Iowa Code chapter 562A; and (2) Allen Investments owed no duty of care to Lewis to maintain the property. View "Lewis v. Howard L. Allen Investments, Inc." on Justia Law