Justia Iowa Supreme Court Opinion Summaries

Plaintiff and Defendant were siblings who owned two farm properties as tenants in common. The first tract was located in Butler County and the second tract was located in Hardin County. In 2013, Plaintiff filed separate actions against Defendant in Butler and Hardin counties seeking partition by sale of both tracts. The actions were consolidated for trial. Defendant opposed the proposed partition by sale and urged the court to partition the tracts in kind instead. The district court ultimately ordered the sale of both tracts. The court of appeals reversed. The Supreme Court vacated the decision of the court of appeals and affirmed the district court’s judgment, holding that Defendant failed to meet her burden to prove it would be equitable and practicable to partition the tracts in kind. View "Newhall v. Roll" on Justia Law

The Dyersville City Council voted to rezone the area containing the Field of Dreams movie site from agricultural to commercial in order to facilitate the development of a baseball and softball complex. Community members filed writs of certiorari, arguing (1) since the city council acted in a quasi-judicial function, the city council’s act of passing the ordinances was invalid; and (2) there was sufficient opposition to the rezoning to trigger a unanimous vote of the city council contained in the city code. The district court annulled the writs. The Supreme Court affirmed, holding (1) the city council acted in its proper legislative function when it rezoned the subject property, and both ordinances were validly passed; and (2) no procedural or substantive errors affected the city council’s rezoning decisions. View "Residential & Agricultural Advisory Committee, LLC v. Dyersville City Council" on Justia Law

Iowa Arboretum, Inc. and Iowa 4-H Foundation entered into a ninety-nine-year lease agreement for a tract of land owned by the Foundation. The majority of the land is used by the Arboretum as an arboretum. The Foundation served the Arboretum with a notice of termination of tenancy, asserting that the land is agricultural for purposes of Iowa Const. art. I, 24, and that the lease violates the constitutional proscription on agricultural leases exceeding a term of twenty years. In response, the Arboretum filed a petition for declaratory judgment and injunctive relief to establish the validity of the lease. The district court granted declaratory relief to the Arboretum and declared the lease valid, determining that the subject land was not agricultural. The Supreme Court affirmed, holding that the land at issue is not agricultural land for purses of Iowa Const. art. I, 24, and therefore, the lease is valid and enforceable. View "Iowa Arboretum, Inc. v. Iowa 4-H Foundation" on Justia Law

Attorney Larry Stoller filed a multicount petition on behalf of NuStar Farms, LLC against Robert and Marcia Zylstra, alleging that the Zylstras agreed to sell NuStar a parcel of farmland but failed to tender the requisite deed and that the Zylstras did not abide by certain terms contained in certain manure easement agreements. The Zylstras filed a motion seeking to disqualify Stoller as the attorney for NuStar based on a conflict of interest. Specifically, the Zylstras alleged that Stoller’s representation of NuStar was a concurrent conflict of interest with his representation of them. The district court denied the motion. The Supreme Court reversed, holding that the district court (1) did not abuse its discretion in holding that Stoller could not be disqualified under the substantial relationship test; but (2) abused its discretion in not disqualifying Stoller from representing NuStar in the action because Stoller did have a concurrent conflict of interest. View "NuStar Farms, LLC v. Zylstra" on Justia Law

A citizens group and a school district (collectively, Appellants) challenged a city’s amendment of an economic development urban renewal plan. Specifically, Appellants challenged the use of tax increment financing (TIF) for economic development purposes and argued that the plan violated Iowa law by unlawfully extending the duration of a TIF area, unlawfully using revenue from that TIF area to support development in other parts of the city, and failing to conform to the terms of the city’s general plan. The district court ruled in favor of the city. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) the city impermissibly extended the duration of the TIF area; (2) revenue may be shared within the consolidated, larger TIF area subject to certain time limits; and (3) the city’s general plan and the urban renewal plan were not inconsistent with each other. View "Concerned Citizens of Southeast Polk Sch. Dist. v. City of Pleasant Hill" on Justia Law

The Polk County assessor set the 2011 valuation of Wellmark, Inc.’s corporate headquarters located in Des Moines at $99 million. Wellmark protested. The Polk County Board of Review denied the protest. On appeal, the district court found the value of the property on January 1, 2011 was $78 million. At issue in this case was whether the property should have been valued as if it were a multi-tenant office building, which would likely be the result if the property were sold, or whether the property should have been valued according to its current use as a single-tenant headquarters building. The Supreme Court reversed, holding that while there had been a showing of no active market for a single-tenant office building such as the Wellmark property, value should be based on the presumed existence of a hypothetical buyer at the property’s current use. View "Wellmark, Inc. v. Polk County Bd. of Review" on Justia Law

Bank was the holder of a promissory note executed by Mortgagors and the mortgage that secured the note. After Mortgagors defaulted on the note Bank brought a foreclosure action and obtained an in rem judgment and decree of foreclosure against Mortgagors. More than two years after the entry of the original judgment, the property had not been sold, and Bank filed a notice of rescission of the foreclosure. Bank subsequently filed this foreclosure action and moved for summary judgment. Mortgagor counterclaimed for quiet title and wrongful foreclosure, arguing that she was entitled to own the property because the house was not sold within two years of the foreclosure decree. The district court granted summary judgment in favor of Bank. The Supreme Court affirmed, holding that the two-year special statute of limitations in Iowa Code 615.1(1) does not limit the period of time for a mortgagee to rescind a prior foreclosure judgment. View "U.S. Bank Nat’l Ass’n v. Callen" on Justia Law

At issue in this quiet title action was whether the two-year special statute of limitations in Iowa Code 615.1(1) applies only to judgment liens or whether the underlying debt is also extinguished after the end of the two-year period. The district court granted summary judgment in favor of Bank. The court of appeals affirmed. The Supreme Court affirmed, holding (1) in accordance with U.S. Bank Nat’l Ass’n v. Callen, the two-year special statute of limitations in section 615.1(1) does not apply to rescission; and (2) Mortgagor’s unclean hands defense to foreclosure has been waived. View "Kobal v. Wells Fargo Bank, N.A." on Justia Law

At issue in this case was whether the terms of two five-year leases, which automatically self-renewed for four additional five-year terms unless the tenant unilaterally opted out of the lease, offended Iowa Const. art. I, 24. James Gansen rented land used for agricultural purposes from the Charles Gansen Trust until the trustee unsuccessfully attempted to negotiate a higher rent from James. The trustee filed a petition for declaratory action, alleging, inter alia, that the leases violated Iowa Const. art. I, 24, which provides that no lease of agricultural lands “shall be valid for a longer period than twenty years.” The district court granted summary judgment in favor of the Trust, concluding that the leases violated article I, section 24. The Supreme Court affirmed, holding (1) although prior litigation took place between the parties involving the same agricultural leases, claim preclusion did not apply to bar the Trust’s claim that the leases violated the Iowa Constitution; and (2) the leases at issue violated article I, section 24 to the extent they remained in effect after the passage of twenty years from their inception. View "Gansen v. Gansen" on Justia Law

In 2012, the Iowa City Board of Review reclassified eighteen properties from commercial to residential for property tax purposes because the properties had recently been organized as multiple housing cooperatives. Two Iowa corporations organized the cooperatives under chapter 499A of the Iowa Code. The City of Iowa City appealed, arguing that the Board’s reclassification was improper because two natural persons, not two corporations, must organize multiple housing cooperatives under the Code. The City also argued that the organizers did not properly organize the cooperatives because each cooperative had more apartment units than members and section 499A.11 requires a one-to-one ratio. The district court granted summary judgment in favor of the Board and the intervening housing cooperatives. The Supreme Court affirmed, holding (1) two Iowa corporations may organize a multiple housing cooperative under chapter 499A; and (2) the Code does not require a one-apartment-unit-per-member ownership ratio for a multiple housing cooperative to be properly organized. View "City of Iowa City v. Iowa City Bd. of Review" on Justia Law