Justia Iowa Supreme Court Opinion Summaries

In 2001, Calvin Matlock was confined to the Civil Commitment Unit for Sexual Offenders (CCUSO). In 2013, the district court found the State failed to meet its burden to prove Matlock’s mental abnormality made him likely to engage in predatory acts that constitute sexually violent offenses if discharged. The court then ordered Matlock released with supervision. Matlock appealed, arguing that, once the court found he no suffered from a mental abnormality that made him likely to engage in acts of sexual violence, release with supervision violated his due process rights. The Supreme Court (1) affirmed the part of the district court judgment releasing Matlock with supervision, holding the statutory scheme found in Iowa Code 299A did not violate the Due Process Clauses of the state or federal Constitutions so long as Matlock continued to suffer from a mental abnormality and the testimony supports the need for supervision upon release; but (2) remanded for a determination that the State proved the terms of supervision were consistent with due process principles, holding that the record was insufficient for the Court to determine whether the specific release conditions ordered by the district court comported with Matlock’s due process rights. View "In re Detention of Matlock" on Justia Law

In 2008, the district court placed Stephen Curtiss in the Civil Commitment Unit for Sexual Offenders (CCUSO). In 2011, the district court found the State failed to meet its burden to prove Curtiss was likely to commit a sexual offense if discharged and ordered Curtiss released with supervision. While released with supervision, Curtiss committed several violations of his release conditions. After a hearing, the district court found the State met its burden to prove that Curtiss had violated his release plan and returned him to CCUSO in the full commitment side of the facility. The Supreme Court affirmed, holding that, pursuant to Iowa Code 229A, the district court properly returned Curtiss to the secure side of CCUSO upon revocation of his release. View "In re Detention of Curtiss" on Justia Law

Defendant was charged with first-degree murder. The district court appointed two attorneys from the Des Moines adult public defender’s office to represent Defendant. When the two attorneys discovered that other attorneys in their office had previously represented three of the State’s witnesses on unrelated matters, the attorneys requested a determination whether a conflict of interest existed requiring their disqualification. After a hearing, the district court concluded that a conflict of interest disqualified all attorneys employed at the public defender’s office from serving as Defendant’s counsel in this case. The Supreme Court reversed, holding that the prior representations of the witnesses in unrelated matters by other members of the public defender’s office did not represent an actual conflict or a serious potential conflict that justified disqualification of the attorneys. View "State v. McKinley" on Justia Law

After the State withdrew its first plea offer and proposed a second, less favorable plea offer, Defendant accepted the second plea offer and pleaded guilty to second-degree burglary and assault with intent to commit sexual abuse not resulting in injury. The district court imposed an indeterminate term of imprisonment not to exceed fourteen years. Defendant filed this petition for postconviction relief asserting several claims of ineffective assistance of counsel. Specifically, Defendant claimed that he received ineffective assistance as a result of counsel’s failure to accurately inform him of the terms and potential sentencing outcomes of the State’s first plea offer. The district court denied the petition on all grounds. The Supreme Court affirmed, holding (1) counsel may have failed to perform an essential duty when he did not accurately inform Defendant of the exact terms and sentencing outcomes of the first plea offer, but (2) because Defendant did not show he would have accepted the first plea offer had counsel accurately informed him of its exact terms and potential sentencing outcomes, Defendant failed to establish the necessary prejudice to succeed on his ineffective assistance of counsel claim. View "Dempsey v. State" on Justia Law

Jim Book, the owner of an auto repair shop in Iowa, bought from an Iowa retailer four Treadstone tires manufactured in China by Doublestar Dongfeng Tyre Company, Ltd. Jim’s son, Dylan Book, was airing up one of the tires when it exploded, causing severe and permanent injuries. Dylan, through his mother, filed a products-liability action in Iowa seeking recovery from Doublestar and Voma Tire Corporation, a national tire distributor that sold several of Doublestar’s tires. Doublestar moved to dismiss for lack of personal jurisdiction. The district court granted the motion. The Supreme Court reversed, holding that the Federal Constitution permits the exercise of personal jurisdiction over a high-volume, foreign manufacturer, such as Doublestar, whose allegedly dangerous product purchased in Iowa injured a resident here. View "Book v. Voma Tire Corp." on Justia Law

Plaintiffs initiated suit in federal district court against Defendant, their former employer, alleging employment discrimination. Plaintiff’s complaint included claims that Defendant had violated Iowa Code 216.6A, Iowa’s equal pay law. Defendants moved for partial summary judgment, arguing that Plaintiffs’ claims under section 216.6A should be dismissed to the extent that they arose before the effective date of that provision. After hearing oral arguments, the district court certified two questions to the Supreme Court to clarify Iowa law with respect to wage discrimination claims. The Supreme Court answered (1) section 216.6A applies on a prospective basis only to conduct occurring after its effective date; and (2) plaintiffs may recover damages for wage discrimination under the preexisting law, Iowa Code 216.6, and recoverable damages for loss of income are based on discriminatory wage payments that occurred within 300 days before the plaintiff filed a complaint with the civil rights commission. View "Dindinger v. AllSteel, Inc." on Justia Law

Following a jury trial, Defendant was found guilty of six drug-related crimes. After Defendant was sentenced, the court of appeals reversed one of Defendant’s convictions, and Defendant received a resentencing hearing on the five convictions that were not reversed. The new sentence was the same as the original sentence with the only difference being that the new sentence did not include one of the five-year sentences as a result of the reversal of the single conviction. The Supreme Court affirmed the sentence of the district court, holding (1) the sentencing court did not abuse its discretion in imposing the sentence; and (2) the record was not adequate to address Defendant’s ineffective assistance of counsel claim. View "State v. Hopkins" on Justia Law

The Iowa Department of Economic Development (IDED) and Ghost Player, LLC executed a contract for tax credits under which Ghost Player believed it would receive certain tax credits for a documentary film it produced. CH Investors, LLC was a third-party beneficiary to the contract. The IDED declined to issue the contracted tax credit for some of the investments and expenditures of Ghost Player. Ghost Player and CH Investors subsequently filed a breach of contract action against the IDED. The district court dismissed the action on the grounds that Ghost Player failed to exhaust its remedies under the Iowa Administrative Procedure Act. The Supreme Court affirmed, holding that the district court (1) was without authority to hear the case because the IDED actions in this case required Ghost Player to exhaust its administrative remedies prior to filing a case in district court; and (2) correctly found the process used by the IDED in processing the claim did not offend due process principles under the State or the Federal Constitutions. View "Ghost Player, LLC v. State" on Justia Law

Wellmark, Inc., an Iowa-based health insurer that belongs to the national Blue Cross and Blue Shield (BCBS) network, contracted with health care providers in Iowa to provide services at certain reimbursement rates. Wellmark agreed to make those rates available both to self-insured Iowa plans that it administers and to out-of-state BCBS affiliates when those entities provide coverage for services provided in Iowa. Plaintiffs, a number of Iowa chiropractors, sued Wellmark, claiming that Wellmark had abused monopoly power in violation of the Iowa Competition Law. The Supreme Court affirmed the district court’s dismissal of some of the chiropractors’ antitrust claims and remanded on Plaintiffs’ remaining claims. On remand, Plaintiffs stipulated that their remaining antitrust claims regarding the agreements between Wellmark and both the self-insuring employers and the out-of-state BCBS affiliates were being asserted on a per se theory. The district court rejected Plaintiffs’ per se theories and entered summary judgment for Wellmark. The Supreme Court affirmed, holding that Wellmark’s arrangements with the self-insured employers and out-of-state BCBS licensees did not amount to per se violations of Iowa antitrust law. View "Mueller v. Wellmark, Inc." on Justia Law

After a jury trial, Defendant was convicted of two counts of sexual abuse in the second degree and one count of lascivious acts with a child. Defendant appealed, arguing, among other things, that trial counsel was ineffective in failing to object to a lascivious-acts jury instruction that he claimed was not supported by sufficient evidence. The court of appeals affirmed. The Supreme Court addressed only Defendant’s claim regarding counsel’s response to the lascivious-acts instruction and let the court of appeals’ affirmance on the remaining issues stand as the final decision of the Court. The Supreme Court affirmed, holding that Defendant failed to establish that he suffered prejudice as a result of counsel’s failure to object to the lascivious-acts instruction, and therefore, his ineffective-assistance-of-counsel claim must fail. View "State v. Thorndike" on Justia Law