Justia Iowa Supreme Court Opinion Summaries

Magistrate Douglas A. Krull, in his private practice, represented a mother in a pending action against her ex-husband to modify child custody provisions of their dissolution decree. A police officer sought a search warrant in a burglary investigation targeting the parties’ son, and Krull signed the warrant to search the home of his client. The Iowa Commission on Judicial Qualifications recommended that the Supreme Court publicly reprimand Krull based on its finding that Krull violated three disciplinary rules governing part-time judicial magistrates by signing the search warrant. The Supreme Court imposed the recommended sanction of a public reprimand, holding (1) by signing the warrant, Krull violated the Iowa Code of Judicial Conduct; and (2) because Krull was previously admonished for signing a warrant to search the home of a party in a civil case he was handling in his private practice, a public reprimand was the appropriate sanction here. View "In re Krull" on Justia Law

In 2011, the City of Sioux City enacted an automatic traffic enforcement (ATE) ordinance. In 2012, a vehicle registered to Appellant was detected by ATE equipment traveling at an excessive speed. As a result, the City issued a citation to Appellant. Appellant moved to dismiss the citation on constitutional grounds, claiming enforcement of the ordinance violated the due process clauses of the Iowa and U.S. Constitutions, the inalienable rights clause of the Iowa Constitution, and the Iowa municipal home rule amendment. The magistrate entered an order finding Defendant liable for the violation. The district court affirmed. The Supreme Court affirmed, holding that the ATE ordinance is not unconstitutional. View "City of Sioux City v. Jacobsma" on Justia Law

Plaintiffs filed an amended petition against two attorneys who prepared documents in connection with the sale of real and personal property, alleging that Defendants negligently performed legal services in negotiating, drafting, and providing legal advice in connection with the documents. The district court granted Defendants’ motion for summary judgment on statute of limitations grounds. The Supreme Court reversed, holding that summary judgment should not have been granted in favor of either attorney because (1) with regard to the first attorney, the district court identified the incorrect date at which Plaintiffs suffered actual damage; and (2) with regard to the second attorney, a fact question remained for trial. View "Vossoughi v. Polaschek" on Justia Law

After a jury trial, Defendant was convicted of domestic abuse assault causing bodily injury. The Supreme Court vacated the judgment of the court of appeals and affirmed, holding (1) trial counsel was not ineffective in failing to object on Confrontation Clause grounds to the testimony of a law enforcement officer regarding the complaining witness’s out-of-court statements; and (2) the record was insufficient to determine whether trial counsel should have objected to and move to strike as hearsay the officer’s unsolicited testimony regarding another witness’s out-of-court statement. View "State v. Tomkins" on Justia Law

After a jury trial, Defendant was found guilty of first-degree arson. On appeal, Defendant requested a judgment of acquittal or, alternatively, a new trial, claiming that the evidence was insufficient to support the conviction and that his pretrial counsel operated under a conflict of interest due to his representation of a prosecution witness. The court of appeals reversed, holding that Defendant’s pretrial counsel’s conflict of interest required reversal of Defendant’s conviction. The Supreme Court vacated the decision of the court of appeals and affirmed the district court’s judgment of conviction and sentence, holding that, where the district court replaced the conflicted defense attorney with a conflict-free attorney more than three months before trial, and there was no showing that the previous conflict had ongoing adverse effects on the representation, a new trial was not required. View "State v. Vaughan" on Justia Law

Defendant was convicted of first-degree kidnapping allegedly arising out of a sexual assault. The court of appeals affirmed the conviction. Defendant appealed, raising eight allegations of error. The Supreme Court affirmed in part and vacated in part the decision of the court of appeals and reversed the conviction, holding (1) there was insufficient evidence in the record to support the kidnapping conviction; (2) Defendant was not entitled to relief on his claim that he was improperly denied access to barrier-free contact with his counsel prior to trial; and (3) the remaining arguments raised by Defendant on appeal were properly resolved by the court of appeals. View "State v. Robinson" on Justia Law

An Iowa plaintiff sued a nonresident corporation (Defendant) for unfair competition and civil conspiracy. Defendant filed a motion to dismiss for lack of personal jurisdiction. The district court denied the motion, concluding that general jurisdiction was established because Defendant’s passive website held Defendant out as having a manufacturing facility in Sioux Center, Iowa. In fact, the Sioux Center facility was owned and operated by a separate Iowa defendant that supplied the product to Defendant. The Supreme Court affirmed the order denying Defendant’s motion to dismiss but on an alternative ground, holding (1) the district court erred by exercising general jurisdiction over Defendant based solely on the inaccurate statement on Defendant’s website, as there was no proof that Defendant was “essentially at home” in Iowa to establish general jurisdiction; but (2) the totality of Defendant’s contacts with Iowa were sufficient to subject it to specific jurisdiction on claims related to those contacts. View "Sioux Pharm, Inc. v. Summit Nutritionals Int’l, Inc." on Justia Law

In this case involving a violent domestic altercation, Defendant was charged with kidnapping in the first degree, attempted murder, and willful injury causing bodily injury. The jury was instructed on each of the offenses. The attempted murder instruction included assault with intent to inflict serious injury as a lesser included offense. The jury acquitted Defendant of kidnapping and attempted murder but found him guilty of the lesser included charge of assault with intent to inflict serious injury as well as the willful injury causing bodily injury charge. The district court sentenced Defendant to terms of imprisonment for the willful injury conviction and for the assault conviction. Defendant appealed, arguing that the district court erred in sentencing him for two separate crimes because the assault conviction should have merged with the willful injury conviction under Iowa’s merger statute. The Supreme Court vacated Defendant’s conviction of assault with intent, holding that, under the unique circumstances of the instructions given in this case, the offenses of willful injury and assault with intent should merge. Remanded for sentencing on the willful injury conviction. View "State v. Love" on Justia Law

Plaintiff, individually, and on behalf of her children, sued two physicians for medical malpractice. During the ensuing trial, one of the jurors fainted while she was sitting in her chair in the jury box. One of the defendant physicians immediately rose to assist the juror, after which the juror recovered and was excused. Plaintiffs moved for a mistrial, which the trial court denied. The jury subsequently returned verdicts for the physicians. The court of appeals reversed and ordered a new trial as to both physicians. The physician who did not help the ailing juror sought further review. The Supreme Court reversed the court of appeals as to the appellant, holding that the district court did not abuse its discretion when it allowed the jury verdict to stand as to the physician who had not rendered medical assistance because nothing in that physician’s behavior during the incident could have “engendered any particular good will in her favor.” Remanded. View "Jack v. Booth" on Justia Law

In its order dissolving the marriage of Steven Gust and Linda Gust, the district court required Steven to pay traditional child support in the amount of $1400 and then in the amount of $2000 per month upon termination of child support, for life. Steven appealed, challenging the spousal support amount as excessive in amount and duration. The Supreme Court affirmed, holding (1) the award of traditional spousal support of unlimited duration in the amount of $2000 per month was fair in this case; and (2) the district court did not err in not fashioning a spousal support order that took into account Steven’s future retirement, as the question of whether Steven’s child support should be modified upon his retirement must be made in a modification action when retirement is imminent or has actually occurred. View "In re Marriage of Gust" on Justia Law