Justia Iowa Supreme Court Opinion Summaries

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

On July 22, 2014, the Muscatine County District Court issued an administrative order prescribing a formal procedure through which persons protected by orders of protection entered in criminal proceedings may seek to have them modified or terminated. The Muscatine County Attorney subsequently initiated an original proceeding in the Supreme Court seeking a writ of certiorari, contending that the administrative order exceeded the district court’s authority because it allowed victims in criminal cases to circumvent the County Attorney’s office and directly seek a modification or termination of no-contact orders in criminal cases. The Supreme Court issued a writ of certiorari. The Court then annulled the writ, holding that the administrative order was well within the district court’s authority, as the challenged order did not establish a right to modification or termination of no-contact orders in criminal cases but, rather, simply created a procedure for seeking such relief. View "Ostergren v. Iowa Dist. Court for Muscatine County" on Justia Law

Plaintiffs, Joseph and Suzanna Sanford, filed suit against a beach resort for damages resulting from an injury Joseph received during an assault committed by James Lawler when all the parties were guests of the resort. James was staying at the resort with his parents and siblings, and James’s father assumed responsibility for the cost of the family stay at the resort. As relevant to this appeal, Plaintiffs asserted dramshop liability claims against the resort. The district court granted summary judgment for the resort, concluding that no sale took place because James did not provide any consideration for the alcoholic beverages served to him. The Supreme Court reversed, holding that the district court erred in interpreting the word “sold” in Iowa Code 123.92(1)(a) to only apply to direct sales, as third-party beneficiaries fall within the rubric of a sale for purposes of section 123.92(1)(a), and the sale in this case encompassed the entirety of the contracted goods and services. View "Sanford v. Lawler" on Justia Law

Father and Mother married in 1996 and had two children. The parties divorced in 2006. The divorce decree granted the parents joint legal custody of the children but allocated primary physical care of the children to Mother. After Mother remarried, she moved approximately seventy miles from her Des Moines suburb to a rural home in a new school district. Father filed a petition seeking modification of the physical care and child support provisions of the dissolution decree, asserting that the proposed move would disrupt the children’s lives and interfere with his extraordinary visitation and active role in parenting the children. The district court modified the decree by granting Father primary physical care. The court of appeals reversed. The Supreme Court affirmed, holding that Father failed to prove the children’s move constituted a substantial change of circumstances or that Father’s ability to minister to the needs of the children was superior to Mother’s. Remanded for determination of child support and a visitation schedule based upon the present circumstances. View "In re Marriage of Hoffman" on Justia Law