Justia Iowa Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of first-degree fraudulent practice and sentenced to an indeterminate term of ten years in prison. Defendant appealed, arguing that the trial court erred in its instructions concerning the elements of fraudulent practice and the degrees of fraudulent practice. The Supreme Court reversed, holding (1) in a fraudulent practice case arising under Iowa Code 714.8(4), the jury should be instructed that “false” means the defendant made the entry or alteration with intent to deceive, and the jury was not so instructed in this case, and the error was not harmless; and (2) the jury instructions addressing the degree of fraudulent practice were potentially confusing and contradictory. View "State v. Hoyman" on Justia Law

Appellee, a former high school basketball coach, was convicted of sexual exploitation of a student. Within hours of his sentencing, Appellee filed a notice of appeal, posted the appeal bond, and was released from custody, never having spent a night incarcerated. The Supreme Court reversed Appellee’s conviction on appeal. Thereafter, Appellee filed an application seeking the district court’s determination that he was a “wrongfully imprisoned person” who was entitled to compensation from the State under Iowa Code 663A.1. The district court found that Appellee was a wrongfully imprisoned person under section 663A.1. The Supreme Court reversed, holding that the temporary restraint of Appellee’s liberty on the afternoon of his sentencing while waiting for the delivery of his appeal bond did not constitute imprisonment for which a remedy was available under chapter 663A. View "State v. Nicoletto" on Justia Law

Patron won 185 credits, or $1.85, while playing a penny slot machine at a Casino. However, at the same time, a message appeared on the screen stating, “Bonus Award - $41797550.16.” The Casino refused to pay the alleged bonus, claiming that the slot machine game malfunctioned, and therefore, the bonus award displayed on the screen was not valid. The Patron filed suit against the Casino, asserting breach of contract, estoppel, and consumer fraud. The district court granted summary judgment to the Casino on all three counts. The Supreme Court affirmed, holding (1) the rules of the game formed a contract between the Patron and the Casino, and the Patron was not entitled to the bonus under those rules; (2) the Patron failed to prove the necessary elements of either promissory or equitable estoppel; and (3) the Patron failed to present proof of an ascertainable loss sufficient to warrant recovery on her consumer fraud claim. View "McKee v. Isle of Capri Casinos, Inc." on Justia Law

A physician (Dr. Lindaman) participating in a child abuse assessment of a three-week-old infant (E.N.) treated E.N.’s broken arm and told the investigator for the Iowa Department of Human Services (DHS) that the father’s story of how the injury occurred was plausible. The investigator allowed E.N. to go home with E.N.’s parents. Three weeks later, E.N. suffered massive brain injuries while being cared for by his father. The father was subsequently found guilty of child endangerment. E.N.’s adoptive parents later filed this action individually and on behalf of E.N., alleging that Dr. Lindaman negligently failed to detect and report the child abuse and that Mercy Medical Center-Des Moines was vicariously liable for Dr. Lindaman’s negligence. Defendants moved for summary judgment, asserting that Dr. Lindaman participated in the DHS assessment in good faith and was therefore immune from liability under Iowa Code 232.73. The district court denied summary judgment. The Supreme Court reversed, holding that because undisputed facts established that Dr. Lindaman participated in good faith in the DHS assessment, Defendants were entitled to good-faith immunity under section 232.73. Remanded for the entry of summary judgment in favor of Defendants. View "Nelson v. Lindaman" on Justia Law

Pursuant to a plea bargain, Defendant pled guilty to harassment in the first degree, an aggravated misdemeanor. The district court imposed a sentence, but the sentencing order did not contain the provisions of the plea bargain. Defendant appealed, claiming (1) the district court erred by not stating adequate reasons on the record for the exercise of its sentencing discretion as required by Iowa R. Crim. P. 2.23(3)(d), and (2) she received ineffective assistance of counsel because she did not knowingly and voluntarily enter into her plea agreement. The Supreme Court vacated the sentence and remanded for resentencing, holding (1) the district court’s sentencing order did not comply with Iowa R. Crim. 2.23(3)(d); and (2) because the record did not allow the Court to determine whether Defendant entered into the plea voluntarily and intelligently, the ineffective-assistance-of-counsel issue could not be addressed on direct appeal. Remanded. View "State v. Thacker" on Justia Law

A police officer stopped Defendant’s vehicle based upon a suspicion that Defendant was operating a vehicle without proper illumination. Defendant was subsequently arrested for, and charged with, driving while intoxicated. Defendant filed a motion to suppress, alleging that the arresting officer lacked reasonable suspicion to make a traffic stop and that, after his arrest, his rights under Iowa Code 804.20 were violated because the officer failed properly to inform him of the purpose of a phone call. The district court denied the motion. A jury subsequently found Defendant guilty of operating a motor vehicle while intoxicated. The Supreme Court affirmed, holding (1) the deputy had a reasonable suspicion that there was no working license plate light on Defendant’s vehicle; and (2) law enforcement officers are not required to explain that a purpose of the phone call is to obtain advice regarding whether to submit to a chemical test. View "State v. Lyon" on Justia Law

Defendant was arrested for public intoxication. The State filed a criminal complaint 120 days later charging Defendant with operating while intoxicated (OWI). The complaint arose from the same incident that resulted in the public intoxication arrest. Defendant filed a miss to dismiss the ensuing trial information charging him with OWI, claiming that the State was required to indict him under the speedy indictment rule for OWI within forty-five days of his arrest because he maintained a reasonable belief that he had been arrested for OWI at the time. The district court dismissed the motion and found Defendant guilty of OWI. The public intoxication charge was dismissed. The court of appeals reversed, concluding that the State was required to indict Defendant for OWI within forty-five days of the arrest because the officers could only have arrested Defendant for the crime of OWI. The Supreme Court vacated the court of appeals and affirmed the district court, holding that the speedy indictment rule is not triggered for a prosecution of a public offense by an arrest that resulted in an earlier prosecution of a separate offense arising from the same incident. View "State v. Penn-Kennedy" on Justia Law

This case was the companion interlocutory appeal with facts that mirrored Iowa Dep’t of Human Servs. v. DeWitt Bank and Trust Co., decided on the day of this opinion. As in DeWitt Bank, the Iowa Department of Human Services filed an application for relief against defendant healthcare providers under Iowa Code 249A.44. The district court appointed a receiver. Bank Iowa, a lender that held perfected security interests in Defendants’ property, intervened and challenged the receiver’s applications for fees and expenses. The district court concluded that receivership expenses should be paid out of property in which the Bank had prior lien interests. The Supreme Court reversed based on the reasoning set forth in DeWitt Bank, holding that Iowa follows the common law rule that a receiver may be charged against a third party’s security interest only to the extent the secured creditor has received a benefit from the receivership or the secured creditor has consented to the receivership. Remanded. View "Iowa Dep’t of Human Servs. v. Morse Healthcare Servs., Inc." on Justia Law

DeWitt Bank & Trust Company (Bank) held perfected security interests on real and personal property of Community Care, Inc. (CCI). When the Iowa Department of Human Services (DHS) determined that CCI had committed Medicaid fraud, DHS filed an application for injunctive relief under Iowa Code 249A.44. The district court enjoined CCI from transferring property or taking action inconsistent with DHS’s right to recover overpayments of medical assistance from CCI. CCI subsequently ceased operations, and the district court appointed a receiver for CCI. The Bank sought clarification that the receiver’s fees and expenses would not be paid out of CCI assets in which the Bank had a prior perfected security lien. The district court denied substantive relief, concluding that Iowa law requires the expenses of the receiver to be paid before secured creditors. The Supreme Court reversed, holding (1) Iowa law does not authorize a receiver to be paid out of assets that are subject to a prior perfected line; and (2) rather, Iowa follows the common law rule that the costs of a receiver may be charged against a third party’s security interest only to the extent the secured creditor has received a benefit from the receivership or the secured creditor has consented to the receivership. View "Iowa Dep’t of Human Servs. v. Cmty. Care, Inc." on Justia Law

The Clarke County Reservoir Commission, comprised of several agencies located in Clarke County, decided to move ahead with plans to build a new public reservoir for drinking water. The Commission filed a declaratory action seeking a declaration that the proposed reservoir was a public use that would allow the Commission to condemn private land. Defendants, landowners whose property was to be condemned for the project, alleged that the Commission did not have the legal authority to initiate this condemnation proceeding because the Commission included private members that lacked eminent domain authority. The district court ruled for the Commission, concluding that the project qualified as a public use and that the Commission, as then constituted, was a proper acquiring agency. The Supreme Court reversed, holding that the district court erred by ruling that the Commission, with private members, had eminent domain powers. View "Clarke County Reservoir Comm’n v. Abbott" on Justia Law