Justia Iowa Supreme Court Opinion Summaries

A juvenile, K.C., was charged with two serious misdemeanors: carrying dangerous weapons and possession of marijuana. As K.C. was 17 at the time of the incident, the juvenile court had initial jurisdiction. However, after K.C. turned 18, the State filed a petition to waive the juvenile court's jurisdiction. In preparation for the waiver hearing, K.C. hired a forensic psychologist, Dr. Tracy Thomas, to conduct an evaluation. K.C. requested the State to cover Dr. Thomas's fees, which were estimated to be $7,990. The juvenile court initially authorized the fees but later set a limit of $4,590, deeming the full amount unreasonable. K.C. filed a motion for additional expert fees, which was denied by the juvenile court. K.C. then filed a petition for a writ of certiorari, arguing that the juvenile court acted illegally by not properly determining whether the requested expert fees were reasonable.The Supreme Court of Iowa agreed with K.C. that the juvenile court's order was not supported by substantial evidence. The court noted that three of the four reasons the juvenile court initially cited for deeming the full fee unreasonable were no longer relevant. The court also found that the juvenile court failed to provide any explanation for why it declined to increase the fee award or reconsider its denial. The Supreme Court of Iowa concluded that the juvenile court's reasoning was based on an erroneous application of law and thereby abused its discretion.The Supreme Court of Iowa sustained the writ of certiorari, vacated the juvenile court's orders denying K.C.'s requests for additional expert fees, and remanded the matter for entry of an order authorizing the full $7,791.20 in expert fees for Dr. Thomas's work. View "K.C. v. Iowa District Court for Polk County" on Justia Law

The case involves a dispute between the Terrace Hill Society Foundation (THSF) and the Terrace Hill Commission (the Commission) over the ownership and control of a collection of property and historical artifacts displayed at the Governor's official residence, Terrace Hill. THSF filed a petition seeking a declaration that it was the sole owner of the collection and an injunction granting it the right to access, itemize, insure, maintain, and preserve the collection. The Commission and its chairperson, Kristin Hurd, moved to dismiss the suit, arguing that it was barred by the doctrine of sovereign immunity and that Hurd could not provide the requested relief.The district court denied the motion to dismiss with respect to the Commission, finding that the factual allegations in the petition, when viewed in the light most favorable to THSF, were sufficient to overcome the State's immunity from suit. The court reasoned that the Commission had willingly accepted possession of THSF's property and retained it after the expiration of a 1996 agreement between the parties. However, the court granted the motion to dismiss with respect to Hurd and dismissed the claims against her without prejudice.On appeal, the Supreme Court of Iowa affirmed the district court's decision. The court held that the State can impliedly or constructively waive its immunity from suit when it voluntarily creates certain legal relationships that subject it to liability. The court found that THSF's amended petition alleged sufficient facts to plead a voluntary bailment, a legal relationship sounding in contract, which impliedly waived the State's sovereign immunity. The court also affirmed the dismissal of the claims against Hurd without prejudice, rejecting her argument that the claims should have been dismissed with prejudice. The case was remanded for further proceedings. View "Terrace Hill Society Foundation v. Terrace Hill Commission" on Justia Law

The Supreme Court of Iowa reviewed a case involving a dispute between the University of Iowa and Modern Piping, Inc., a mechanical contractor. The dispute arose during the construction of the University of Iowa Stead Family Children’s Hospital. Modern Piping sought to arbitrate some delay disputes, but the University obtained a temporary injunction preventing arbitration. Modern Piping successfully had the injunction dissolved and sought to recover not only the fees and costs it incurred in doing so, but also restitution for the University's wrongful injunction.The district court initially granted the University an ex parte temporary injunction against Modern Piping, preventing arbitration of specific disputes. Modern Piping intervened and successfully had the injunction dissolved. The University appealed this decision but was unsuccessful. Meanwhile, the parties arbitrated the original disputes, resulting in the University paying Modern Piping over $16 million pursuant to the arbitration award.The Supreme Court of Iowa held that the restitution awarded to Modern Piping was not a proper remedy for a claim for wrongful injunction and could not stand. The court affirmed the $21,784.50 award to Modern Piping for fees and costs but reversed the $12,784,177.00 award for restitution. The court found that Modern Piping's claim for restitution was not directly correlated to the injunction, and therefore, it was not entitled to recover restitution in the form of a broad-reaching unjust enrichment claim. The case was remanded for entry of an order consistent with this directive. View "The University of Iowa v. Modern Piping, Inc." on Justia Law

The case revolves around the Kirkwood Institute's request for public records from the Office of the Auditor of State in Iowa. The Institute sought emails between the Auditor's office and two investigative reporters. The Auditor's office withheld ten email chains, citing Iowa Code § 11.42 and § 22.7(18), which protect certain types of information. Kirkwood sued, arguing that the Auditor's office failed to show that these exceptions applied to the withheld emails. Additionally, Kirkwood claimed that the Auditor's office failed to disclose an eleventh email chain that had been quoted in a reporter's blog.The district court granted summary judgment in favor of the Auditor's office, holding that the ten email chains were exempt from production and that no violation occurred with the late turnover of the eleventh email chain. Kirkwood appealed this decision.The Supreme Court of Iowa affirmed in part, reversed in part, and remanded the case. The court found that there was a factual issue as to whether the delay in producing the eleventh email was reasonable. It also found that the district court erred in granting summary judgment on the Auditor's office's withholding of nine emails under § 11.42, as it was not immediately apparent that these emails were received in the course of an audit or examination. However, the court affirmed the district court's decision regarding the tenth email withheld under § 22.7(18), agreeing that it fell within the exception created in this statute. View "Kirkwood Institute, Inc. v. Sand" on Justia Law

The case involves William and Mary Goche, LLC; Global Assets, LLC; and Joseph Goche (collectively “Goche”), who own land in three different drainage districts in Kossuth County. The Kossuth County Board of Supervisors administers these districts. Goche alleged that the board of supervisors administered the districts in a way that specifically caused him harm. He brought a suit against the board of supervisors, current and former supervisors, and engineering firm Bolton & Menk, Inc., asserting claims for breach of fiduciary duty and seeking punitive damages for the defendants’ alleged breaches.The defendants moved to dismiss the claims, arguing that they owed no fiduciary duty to Goche as an individual landowner within the drainage districts. The district court granted the motions, leading to Goche's appeal. However, in the appeal, Goche abandoned his breach of fiduciary duty claims and instead contended that he is entitled to proceed against the defendants on a standalone cause of action for punitive damages.The Supreme Court of Iowa disagreed with Goche's argument. The court clarified that punitive damages are a form of damages available to a plaintiff incidental to a recognized cause of action and not a freestanding cause of action. The court also noted that Goche conceded that the defendants owed him no fiduciary duty in the administration of the drainage districts or in providing engineering services to the districts. Therefore, the court affirmed the judgment of the district court, dismissing Goche's claims. View "William and Mary Goche, LLC v. Kossuth County Board of Supervisors in their capacity as Trustees of Drainage Districts 4, 18, and 80" on Justia Law

Jesse McCollaugh was found guilty of child exploitation after his wife discovered videos on his phone of her 15-year-old sister using the bathroom, which McCollaugh had secretly recorded. The videos showed the minor partially nude, unaware she was being filmed. McCollaugh admitted to recording the videos and having a sexual problem. He was charged with one count of sexual exploitation of a minor, to which he pleaded not guilty. After a bench trial, the district court found McCollaugh guilty and sentenced him to a prison term not exceeding two years, and required him to register as a sex offender.Before the Supreme Court of Iowa, McCollaugh appealed his conviction, arguing that the evidence was insufficient to support his conviction because it failed to establish that the minor had the purpose of engaging in nudity to arouse or satisfy the sexual desires of a person who may view the visual depiction. The Supreme Court disagreed with McCollaugh's interpretation of the statute, stating that the relevant "purpose" that the State must prove is identified after the word "purpose" in the definition, not before. The court held that the State must prove the purpose of purchasing or possessing a visual depiction of the nude minor—not the minor’s purpose in being nude. The court found sufficient evidence to prove McCollaugh’s purpose for taking the videos was for his sexual gratification and affirmed his conviction. McCollaugh also argued that the district court relied on an improper factor in its sentencing order, but the Supreme Court found no evidence that the district court relied on the improper factor and affirmed the sentence. View "State v. McCollaugh" on Justia Law

The defendant, Christopher James Wilson, was charged with two counts of indecent exposure after he was seen masturbating in public by two women, E.H. and T.A., at a gas station. Wilson followed the women to another location where he continued his actions. He was subsequently arrested and charged. After a jury trial, he was convicted on both counts and sentenced to an enhanced sentence under Iowa Code section 901A.2(1) to an indeterminate prison term of two years for the first count and an indeterminate prison term of two years for the second count. The sentence for count one was ordered to run consecutively to the sentence for count two.Wilson appealed his conviction and sentence, arguing that the unit of prosecution for indecent exposure is per exposure, not per viewer. Therefore, he contended that there was insufficient evidence to convict him on two separate counts of indecent exposure. He also argued that the district court did not provide sufficient reasons for imposing a consecutive sentence under Iowa Rule of Criminal Procedure 2.23(3)(d).The Supreme Court of Iowa affirmed the lower court's decision. The court held that the unit of prosecution for indecent exposure is one count per viewer, not one count per exposure. Therefore, there was sufficient evidence to support a conviction on two counts of indecent exposure. The court also found that the district court provided sufficient reasoning for imposing a consecutive sentence. The court noted that the district court's reasoning for imposing consecutive sentences may be the same reasons the court relied on for the imposition of incarceration. The court concluded that the district court's statement that the only appropriate sentence was to send Wilson to prison for as long of a period of time as possible implied that the sentences should run consecutively. View "State v. Wilson" on Justia Law

The case involves Clayton Curtis Brown, who was convicted of possession of a firearm as a felon, aggravated eluding, and driving while barred. The charges stemmed from an incident where Brown eluded a police officer's attempt to initiate a traffic stop. The officer later found the car abandoned and discovered a loaded handgun under the driver's seat and ammunition in the center console and under the front passenger seat. Brown's personal items were also found in the car.The Iowa Court of Appeals reversed Brown's convictions for possession of a firearm as a felon and aggravated eluding, concluding there was insufficient evidence to show that Brown knowingly possessed the handgun. Brown also contested the sufficiency of the evidence to support his convictions, arguing that the State failed to prove his identity as the driver of the car that eluded the officer.The Supreme Court of Iowa disagreed with the lower court's decision. The court held that the State's evidence, including the officer's testimony, the location of the firearm, and the presence of Brown's personal effects in the car, was sufficient to support the jury's conclusion that Brown had constructive possession of the firearm. The court also found that there was sufficient evidence to support the jury's determination that Brown was driving the car when it eluded the officer. Therefore, the Supreme Court of Iowa vacated the portion of the court of appeals decision reversing those convictions and affirmed the district court judgment in full. View "State of Iowa v. Brown" on Justia Law

This case involves a dispute within the Hora family over the operation of their family farm, Hora Farms, Inc. (HFI). Two brothers, Brian and Gregg Hora, brought a derivative action as minority shareholders against their father, Keith Hora, and brother, Kurt Hora, alleging breach of fiduciary duties based on their management of the farming operation. The brothers claimed that Keith and Kurt mismanaged the farm's operations, resulting in financial losses and unaccounted-for corn inventory. They also alleged that Keith used HFI's credit card for personal expenses.The case was initially heard in the Iowa District Court, where it was determined that neither Keith nor Kurt breached fiduciary duties owed to the corporation. The court found that the brothers' concerns were primarily related to poor recordkeeping and longstanding business practices, rather than intentional wrongdoing. The court also concluded that Keith's use of the corporate credit card for personal expenses was part of his compensation and was fair to HFI.The brothers appealed the decision to the Iowa Court of Appeals, which reversed the district court's decision on two specific issues. The appellate court concluded that Keith engaged in self-dealing by using HFI's credit card for personal expenses and that he enabled Kurt to misappropriate corn from the farm. The court also found that Kurt breached his duty to HFI by misappropriating corn for his personal use.The case was then reviewed by the Supreme Court of Iowa. The court vacated the decision of the Court of Appeals and affirmed the judgment of the District Court. The Supreme Court found that Kurt, as an employee and not an officer or director of HFI, did not owe fiduciary duties to the corporation. The court also concluded that Keith did not violate any fiduciary duties owed to HFI in his oversight of Kurt. The court determined that the brothers failed to prove that Keith or Kurt violated fiduciary duties owed to HFI. View "Hora v. Hora" on Justia Law

The case involves Tracy White, an employee of the Iowa Department of Human Services (DHS), who filed a lawsuit against the State of Iowa and DHS under the Iowa Civil Rights Act (ICRA) alleging a hostile work environment. White's complaints about her supervisor led to his termination, but she remained employed at the agency. The jury awarded her $260,000 for past emotional distress and $530,000 for future emotional distress. The State appealed, arguing that the evidence was insufficient to prove White's hostile work environment claim, that the district court erred by admitting certain evidence and incorrectly instructing the jury, and that the future emotional distress damages were excessive.The district court had denied the State's pretrial motion to exclude certain evidence, referred to as "me too" evidence, as unduly prejudicial. This evidence consisted of reports of alleged discrimination experienced by other employees, which White, as a supervisor, had received and relied on to support her own hostile work environment claim. The State argued that such evidence, of which White was unaware, could not prove that she personally experienced a hostile work environment.The Supreme Court of Iowa agreed with the State, concluding that the harassment White personally experienced was not objectively severe or pervasive enough to alter the terms or conditions of her employment. The court held that the district court erred by denying the State's motion for judgment notwithstanding the verdict (JNOV). The court reversed the judgment for White and remanded the case for entry of an order granting the State's motion for JNOV. View "White v. State" on Justia Law