Justia Iowa Supreme Court Opinion Summaries

The Workers’ Compensation Core Group of the Iowa Association for Justice filed a petition for declaratory order with the Workers’ Compensation Commissioner seeking a determination whether Iowa Code 85.25(2) mandates that employers or insurance carriers defending workers’ compensation claims must immediately provide copies of surveillance videos, photographs, and reports concerning a claimant’s physical or mental condition relative to the claim. The Commissioner concluded that section 85.27(2) overrides the work product immunity, thus requiring the disclosure of surveillance materials upon request from a claimant before the claimant is deposed. The district court affirmed. The Supreme Court reversed, holding that section 85.27(2) does not affect privileges and protections related to the litigation process such as the work product doctrine because the statute is limited to health-care-related privileges such as the physician-patient privilege. Remanded. View "Iowa Ins. Inst. v. Core Group of the Iowa Ass’n for Justice" on Justia Law

At issue in this case was whether the front steps of a single-family home are a public place under Iowa’s public intoxication statute. Defendant was charged with public intoxication in violation of Iowa Code 123.46 after she was found intoxicated on the front steps of her home. After a jury-waived trial, the district court concluded that Defendant’s front stairs were a public place, and therefore, Defendant was guilty of public intoxication. The Supreme Court reversed, holding (1) the front steps of a single-family home are not a public place under section 123.46(2) unless the home’s residents make them public by extending a general invitation to the public at large to come upon the property; and (2) the evidence did not show that Defendant extended such an invitation to the public in this case. Remanded for the district court to dismiss the public intoxication charge. View "State v. Paye" on Justia Law

Employee was injured while working for Employer. Employee filed a workers’ compensation claim and submitted a report from a physician from whom she received an examination that was not authorized by Employer. The deputy workers’ compensation commissioner concluded that Employee suffered a permanent partial disability to her back and taxed as a cost against Employer the expense of the examination and report under the administrative rule governing the assessment of costs in a hearing. The district court affirmed, holding that the reimbursement was proper. The court of appeals reversed, concluding that the reimbursement would be inconsistent with Iowa Code 85.39. The Supreme Court affirmed, holding that the commissioner may not tax the fees of a physician arising from the evaluation of an employee done outside the process set forth in section 85.39 as “costs incurred in the hearing” when the employee submits a written report of the evaluation at the hearing. View "Des Moines Area Reg’l Transit Auth. v. Young" on Justia Law

After Susan Thatcher was diagnosed with terminal cancer, she filed a petition for dissolution of her marriage to Ronald Thatcher. Susan subsequently filed a motion to bifurcate dissolution, requesting that the Supreme Court first dissolve the marriage and decide the issues of the parties’ property and debts at a later date. The day before Susan’s death, the district court granted the motion to bifurcate and dissolved the marriage, with the division of property to be “determined at a later date.” Ronald appealed. The Supreme Court reversed the order of bifurcation and decree of dissolution, holding that Iowa Code 598.21(1) requires the marital dissolution and division of property to be contemporaneous. Remanded. View "In re Marriage of Thatcher" on Justia Law

In 2013, the General Assembly appropriated funds for the operation of the Iowa Juvenile Home (IJH) in Toledo for the 2014 fiscal year, but five months into 2014, the Iowa Department of Human Services (DHS) decided to close the home. Plaintiffs - two state senators, two state representatives, and the president of a labor organization representing employees at the IJH - sued Defendants - the Governor and the director of DHS - seeking, inter alia, a determination that Defendants’ refusal to spend appropriated funds to continue operating the IJH was unconstitutional. The district court entered a temporary injunction preventing closure of the IJH. While Defendants’ appeal was pending, the General Assembly declined to fund ongoing operations of the IJH for the 2015 fiscal year. The Supreme Court reversed the district court and remanded with instructions to dismiss the case, holding that the case was moot because the Legislature was no longer appropriating funds for the operation of the IJH. View "Man v. Branstad" on Justia Law

In 2006, Appellant was injured while working at Wal-Mart. In 2009, Appellant was injured while working at Warren Properties. Appellant filed a complaint against Warren Properties to recover compensation for her 2009 injury. The deputy workers’ compensation commissioner awarded benefits based on a finding of two successive injuries to the back and a shoulder injury and applied the full-responsibility rule with no apportionment for the preexisting disability. The workers’ compensation commissioner affirmed. The district court affirmed in part and reversed in part, holding that the commissioner erred in failing to apportion Appellant’s preexisting disability that arose from the 2006 injury when calculating the benefits owed by Warren Properties for the 2009 injury. The court remanded to the case for a determination as to whether the 2009 injury resulted in any new back disability. The Supreme Court affirmed in part, reversed in part, and remanded, holding that an employer who is liable to compensate an employee for a successive unscheduled work injury is not liable to pay for the preexisting disability that arose from employment with a different employer or from causes unrelated to employment if the employee’s earning capacity was not evaluated both before and after the successive injury. Remanded. View "Warren Props. v. Stewart" on Justia Law

Employers filed a petition against the City claiming that a city ordinance prohibiting discrimination by all employers violated their constitutional rights. The Supreme Court held that the antidiscrimination ordinance exceeded the City’s home rule authority and remanded. On remand, Employers argued that the City was liable under 42 U.S.C. 1983 as a matter of law for attempting to enforce the antidiscrimination ordinance in violation of Employers’ rights of freedom of speech and freedom of association and their federal constitutional rights of due process and equal protection. The district court granted summary judgment for the City. The Supreme Court affirmed, holding (1) the ordinance did not violate Employers’ federal constitutional rights; and (2) the district court did not abuse its discretion when it allowed Employers to amend their petition. View "Baker v. City of Iowa City" on Justia Law

Appellant pleaded guilty to fraudulent practice in the fourth degree. The district court granted Appellant a deferred judgment and placed him on probation. After Appellant was discharged from probation he filed a petition for writ of habeas corpus alleging that he received ineffective assistance of counsel due to counsel’s failure to adequately inform him of adverse immigration consequences resulting from his guilty plea. The district court summarily denied habeas corpus relief. The court of appeals affirmed. The Supreme Court affirmed, holding that Appellant was not entitled to relief because he failed to comply with the pleading requirements of Iowa Code 663.1(1) and because there were insufficient facts to sustain a writ of habeas corpus. View "State v. Hernandez-Galarza" 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

Dolphin Residential Cooperative, Inc. owned an apartment complex in Iowa City that consisted of twenty-two buildings comprising four hundred residential units. The Iowa City assessor classified the multiunit apartment buildings as commercial property for tax assessment purposes. Dolphin challenged this classification, arguing that because it was a multiple housing cooperative, organized under chapter 499A of the Iowa Code, the property should have been classified as residential property. The Iowa City Board of Review denied Dolphin’s request to reclassify the property, determining that because Dolphin was not properly organized under chapter 499A, Dolphin failed the organizational test for residential cooperatives adopted by the Supreme Court in Krupp Place 1 Coop, Inc. v. Board of Review. On appeal, the district court granted summary judgment in favor of Dolphin, concluding that Dolphin met the organizational test set forth in Krupp and ordering the Board to reclassify the subject property as residential property for tax assessment purposes. The Supreme Court reversed, holding that Dolphin was not properly established under section 499A.1(1), and therefore, the district court erred when it granted summary judgment to Dolphin and denied summary judgment to the Board. View "Dolphin Residential Coop., Inc. v. Iowa City Bd. of Review" on Justia Law