Justia Iowa Supreme Court Opinion Summaries

Defendant was seventeen years old when he committed first-degree murder. Defendant was sentenced to life without parole, as required by Iowa law. Defendant later filed a motion to correct an illegal sentence. Before the trial court heard the motion and shortly after Miller v. Alabama was decided, Iowa’s Governor commuted the sentences of all juveniles previously convicted of first-degree murder to a life sentence with the possibility of parole after sixty years. The trial court then granted Defendant’s motion to the extent his sentence was imposed without “individualized consideration of the circumstances.” The court upheld Defendant’s sentence of life with parole eligibility after sixty years as commuted by the Governor. The Supreme Court vacated the sentence, holding (1) a court must use certain factors when it sentences a juvenile offender for first-degree murder; and (2) because the district court did not have the benefit of this decision when it sentenced Defendant, this case must be remanded for resentencing. View "State v. Seats" on Justia Law

In this battle between two domestic producers of chondroitin sulfate, Plaintiffs filed suit claiming trade-secrets violations against Defendants. Before the Supreme Court was an interlocutory appeal on a discovery issue. The district court entered a protective order requiring the redesignation of Plaintiffs’ standard operating procedures from “attorneys’ eyes only” to “confidential,” which would allow these materials to be disclosed to the defendants themselves. The Supreme Court reversed, holding that, while removing the “attorneys’ eyes only” designation may have been appropriate, the district court’s rationale for ordering redesignation was insufficient. Remanded for further consideration. View "Sioux Pharm, Inc. v. Eagle Labs., Inc." on Justia Law

In 2010, two teenage boys drowned at the Pella Aquatics Center. Plaintiffs, the parents of the children, filed a claim for negligence against the City of Pella under the state-created danger doctrine. The district court granted summary judgment for the City on all of Plaintiffs’ negligence claims with one exception, concluding that the City was entitled to immunity under Iowa Code 670.4(12). The court denied summary judgment on that part of the claim in which the parents alleged that the City’s employee’s acts constituted the criminal offense of involuntary manslaughter. The Supreme Court reversed in part, holding (1) Plaintiffs adequately alleged that the City violated administrative rules constituting criminal offenses under the Iowa Code, and if the City violated these rules, is was not entitled to immunity; and (2) Plaintiffs must prove by a preponderance of the evidence that the City’s acts or omissions constituted involuntary manslaughter to remove it from the immunity granted by section 670.4(1). View "Sanon v. City of Pella" on Justia Law

After Defendant was released on parole, Defendant’s parole officer made a home visit to check on Defendant and conducted a search of Defendant’s bedroom. The search uncovered evidence used to prosecute and convict Defendant of the crime of possession of a controlled substance as a habitual offender. Defendant appealed the denial of his motion to suppress, arguing that the evidence was obtained in violation of the State Constitution. The Supreme Court adopted a special-needs exception that authorizes parole officers to search the home of a parolee without a warrant for purposes of parole supervision and then affirmed, holding that, under the special-needs exception to allow narrowly tailored parolee searches, Defendant’s constitutional rights were not violated in this case. View "State v. King" on Justia Law

In 2013, the Iowa Board of Medicine passed a rule establishing standards requiring physicians who prescribe or administer abortion-inducing drugs to personally perform a physical examination and to be physically present when the abortion-inducing drug is provided. Planned Parenthood challenged the rule as both improperly enacted and in violation of the Iowa Constitution. The district court denied Planned Parenthood’s claims and upheld the rule addressing each of Planned Parenthood’s challenges. The Supreme Court reversed, holding (1) the Board’s rule violates the controlling “undue burden” test announced by the U.S. Supreme Court as the federal constitutional test; and (2) therefore, the rule violates the Iowa Constitution under the less stringent Iowa constitutional standard advanced by the Board. View "Planned Parenthood of the Heartland, Inc. v. Iowa Bd. of Med." on Justia Law

After a jury trial, Defendant was found guilty of theft in the first degree. Defendant appealed the denial of his motion to suppress the search of his trailer, arguing that there was no probable cause to support the search warrant. Defendant also raised numerous claims of ineffective assistance of trial counsel. The court of appeals reversed and remanded the case for a new trial, concluding that there was no probable cause to support the search warrant. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding (1) the district court properly denied the motion to suppress because the issuing judge had a substantial basis for concluding there was probable cause to support the search warrant; and (2) the record was inadequate to reach the merits of Defendant’s ineffective-assistance-of-counsel claims. View "State v. McNeal" on Justia Law

After a jury trial, Defendant was found guilty of second-degree murder. Defendant appealed, arguing that his conviction should be vacated because of juror misconduct and juror bias and because of assorted errors in the district court’s evidentiary rulings. The court of appeals reversed Defendant’s conviction on the issue of juror bias. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the trial court, holding (1) the evidence does not support a finding of juror misconduct in this case; (2) the district court did not abuse its discretion in finding that a juror was not actually biased when, prior to the verdict, the juror clicked “like” on a Facebook comment by the victim’s stepmother which stated, “Give me strength”; and (3) the district court did not commit prejudicial error in its evidentiary rulings. View "State v. Webster" on Justia Law

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