Justia Iowa Supreme Court Opinion Summaries

The Supreme Court vacated the decision of the court of appeals affirming the decision of the district court concluding that the county board of adjustment legally granted an area variance to certain property owners, holding that the board of adjustment acted illegally in granting the variance from the county zoning ordinance.The Board of Adjustment of Cerro Gordo County granted the application for a variance filed by Gregory and Lea Ann Saul that allowed them to construct a pergola twenty-one inches from the property line. The local ordinance required a six-foot setback. The district court concluded that the board acted legally in granting the variance. The court of appeals affirmed. The Supreme Court vacated the judgment of the court of appeals and reversed the district court, holding that the Sauls did not meet their burden to establish unnecessary hardship. View "Earley v. Board of Adjustment of Cerro Gordo County" on Justia Law

The Supreme Court reversed the order of the district court denying Defendant's motion to set aside a default judgment awarding Plaintiff immediate and exclusive possession of Defendant's home, holding that the district court erred in denying Defendant's motion to set aside the default judgment.Plaintiff obtained title to Defendant's home by way of a tax sale deed and, after filing a petition for recovery of real property, obtained a default judgment awarding it possession of Defendant's home. Defendant filed a motion to set aside the default judgment, asserting that he was legally disabled and exempt from paying property taxes and that he had been trying to resolve the property tax issue for some time. The district court denied the motion. The Supreme Court reversed, holding that Defendant established good cause to set aside the default judgment. View "No Boundry, LLC v. Hoosman" on Justia Law

In this case brought by a tenant against her landlord and a neighboring tenant alleging breach of the lease's no-pets provision the Supreme Court reversed the judgment of the district court dismissing the case, holding that the landlord's accommodation of an emotional support dog was not reasonable.Plaintiff moved into an apartment building because of its no-pets policy. Afterwards, another tenant requested a reasonable accommodation to have his emotion support animal (ESA), a dog, with him on the apartment premises. The landlord allowed the ESA and tried to accommodate the two tenants, but Plaintiff still suffered from allergic attacks. Plaintiff sued, alleging breach of the lease and interference with the quiet enjoyment of her apartment. The landlord asserted in its defense that its waiver of the no-pets policy was a reasonable accommodation that it was required to grant under the Iowa Civil Rights Act (ICRA). The small claims court concluded that the landlord's accommodations were reasonable. The district court dismissed the case. The Supreme Court reversed and remanded the case, holding (1) the landlord's accommodation of the ESA was not reasonable because Plaintiff had priority in time and the dog's presence posed a direct threat to her health; and (2) Plaintiff was entitled to recover on her claims. View "Cohen v. Clark" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the determination of the Iowa Department of Revenue that capital gains Taxpayer earned from the sale of farmland she inherited from her father and leased on a cash-rent basis did not qualify for the exclusion from Iowa income tax allowed under Iowa Code 422.7(21)(a), holding that the assessment of additional taxes and related penalties and interest was not irrational, illogical, or wholly unjustifiable.At issue was whether the Department's interpretation of section 422.7(21)(a), as delineated in Iowa Administrative Code rule 701-40.38(1)(c), or the director's application of that rule to the facts was irrational, illogical, or wholly unjustified. The Supreme Court affirmed, holding (1) the Department acted within its discretion when it promulgated distinct rules for farm leases and other types of real property leases in rule 701-40.38(1)(c); and (2) Taxpayers' attempt to avoid the farm-specific rules is rejected. View "Christensen v. Iowa Department of Revenue" on Justia Law

The Supreme Court reversed the judgment of the district court ruling that Plaintiffs' claim seeking contract damages was barred by the limitations period set forth in Iowa Code 614.17A, holding that the district court erred in granting summary judgment.John and Dessie Rottinghaus filed a claim in the Estate of Sandra Franken, alleging that the Estate sold certain real estate in violation of their right of first refusal to purchase the real estate. The executor disallowed the claim and moved for summary judgment, claiming that section 614.17A barred the Rottinghauses' claim. The district court granted the motion for summary judgment, concluding that the statute of limitations precluded the Rottinghauses' claim for damages. The Supreme Court reversed, holding (1) section 614.17A applies only to actions seeking to recover or establish an interest in or claim to real estate filed against the holder of the record title; and (2) neither the merger doctrine, the statute of frauds, the indirect effect of section 614.17A, nor the statute of limitations in section 614.1(5) barred the Rottinghauses' damages action. View "In re Estate of Franken" on Justia Law

The Supreme Court affirmed the judgment of the district court finding that Plaintiffs had a "losing cause of action," concluding that Plaintiffs' claims against Defendants were frivolous, and granting Defendants' motion for costs and expenses, holding that the district court did not err or abuse its discretion.A group of property owners alleged that confined animal feeding operations (CAFOs) operated and supported by Defendants amounted to a nuisance. The plaintiffs later dismissed their lawsuit because they failed to exhaust farm mediation and then later refiled. Two of the plaintiffs (together, Plaintiffs), however, voluntarily dismissed their claims a second time, resulting in an adjudication against them on the merits. Defendants sued Plaintiffs seeking costs and expenses pursuant to Iowa Code 657.11(5). The district court granted the motions. The Supreme Court affirmed, holding (1) two voluntary dismissals meant Plaintiffs had "a losing cause of action"; (2) Plaintiffs' claims were frivolous; and (3) the district court's apportionment of costs and expenses was appropriate. View "Merrill v. Valley View Swine, LLC" on Justia Law

The Supreme Court reversed the foreclosure decree entered by the district court giving priority under a future-advances clause to the full amount of credit extended by the first lienholder rather than the maximum amount set forth in the notice provision of the first lienholder's mortgage, holding that the first lienholder's priority was capped at $148,000.A bank made a series of loans to a farmer and obtained a mortgage with a future-advances clause on a farm property. The bank's mortgage contained language stating that the mortgage secured credit in the amount of $148,000. The farmer later took out a loan from a second bank, also secured in part by the same farm property. When the first bank filed a foreclosure proceeding, the parties disputed whether the first bank's lien had priority for all amounts due to the first bank or only up to $148,000. The district court found that the first bank's priority was not limited to $148,000 but extended to all debt secured by the mortgage. The Supreme Court reversed, holding (1) the first bank's priority was capped at $148,000, plus interest; and (2) the first bank was not allowed to collect default interest at eighteen percent as part of its first-priority lien where there was no written agreement to pay that rate. View "Blue Grass Savings Bank v. Community Bank & Trust Co." on Justia Law

In this dispute over Contractor's attorney fees the Supreme Court affirmed the judgment of the district court finding that Homeowners waived their assertion that including attorney fees in a mechanic's lien foreclosure decree violated their homestead rights, holding that Homeowners needed to raise their homestead exemption before the district court entered the foreclosure decree.This appeal stemmed from a judicial determination that Homeowners had to pay most of Contractor's unpaid bill and that Contractor was entitled to foreclosure of its mechanic's lien. Later, a revised decree was entered granting Contractor the right to foreclose a mechanic's lien against the property both for the principal amount due and for the attorney fees. When a second sheriff's sale of the residence was impending, Homeowners, for the first time, asserted that including attorney fees in the mechanic's lien foreclosure decree violated their homestead rights. The judicial court found a waiver by Homeowners. The Supreme Court affirmed, holding (1) attorney fees can be recovered in a mechanic's lien foreclosure action against the homestead; and (2) the district court correctly found that principles of res judicata and waiver barred Homeowners' assertion of a homestead exemption. View "Standard Water Control Systems, Inc. v. Jones" on Justia Law

The Supreme Court affirmed the judgment of the district court declining to modify a restriction on alienability of paintings painted by artist Grant Wood and donated in 1976 to Coe College in Cedar Rapids, holding that the 1976 gift was restricted.A foundation donated the paintings to the college, and the gift letter stated that "this would be their permanent home, hanging on the walls of Stewart Memorial Library." While the college traditionally treated the paintings on its books as an unrestricted gift that could be sold or otherwise alienated, in 2016, an auditor determined the paintings should be treated as a restricted gift. The college subsequently filed a petition seeking a judicial interpretation of the gift's terms. The district court ruled that there existed a restriction on the alienability of the paintings and declined to modify the restriction. The Supreme Court affirmed, holding (1) the language in the gift letter did restrict the gift; (2) the Uniform Prudent Management of Institutional Funds Act does not apply; and (3) it was premature to consider the application of the common law doctrine of cy pres because there was no showing the gift restrictions cannot be carried out at present. View "In re Application of Coe College for Interpretation of Purported Gift Restrictions v. Coe College" on Justia Law

The Supreme Court affirmed the decision of the district court affirming the Carroll County Board of Adjustment's denial of Appellants' application for a variance from Carroll County Airport Zoning Ordinance height restrictions, holding that this Court's opinion rejecting Appellants' preemption defense in a companion case, was fatal to Appellants' appeal of the zoning variance denial.Appellants built a grain leg on their farmland that violated the zoning ordinance's height restrictions. The Federal Aviation Administration (FAA) made a no-hazard determination. The Carroll Airport Commission disagreed with the FAA's determination and filed an equitable action to have the grain leg declared a nuisance. After Appellants unsuccessfully sought a variance, the district court entered judgment for the Commission on its nuisance claim. In both the nuisance action and the zoning appeal Appellants argued that the FAA's no-hazard determination preempted local regulations as a matter of law. The district court rejected that defense in the nuisance action. The court of appeals and Supreme Court affirmed. The district court then affirmed the Board's denial of the variance, again rejecting the preemption defense. Because the nuisance case adjudicated the same federal preemption issue Appellants raised in this preceding, the Supreme Court's opinion rejecting Appellants' preemption defense in the nuisance action was fatal to Appellants' appeal of the zoning appeal. View "Danner v. Carroll County Board of Adjustment" on Justia Law