Justia Iowa Supreme Court Opinion Summaries

At issue in this appeal was the constitutionality of the statutory framework under which Iowa taxes the delivery of natural gas at variable tax rates depending on volume and the taxpayer’s geographic location within the state. Plaintiff filed with the Iowa Department of Revenue a claim for a refund of replacement tax Plaintiff paid for certain tax years, asserting that the replacement tax in Iowa Code 437A.5(2) violates the federal Equal Protection Clause, Iowa Const. art. I, 6, and the dormant Commerce Clause because it is based on the natural gas competitive service area in which a taxpayer is located. An administrative law judge denied Plaintiff’s refund claims and rejected the constitutional challenges to the replacement tax. The district court also denied each of Plaintiff’s constitutional challenges. The Supreme Court affirmed, holding (1) a rational basis exists for the variable excise tax imposed on the delivery of natural gas under section 437A.5, and therefore, Plaintiff failed to establish a violation of the Fourteenth Amendment or Iowa Const. art. I, 6; and (2) the natural gas delivery tax framework does not violate the dormant Commerce Clause. View "LSCP, LLLP v. Kay-Decker" on Justia Law

After a jury trial, Defendant was convicted of third-degree burglary for entering a soon-to-be demolished, dilapidated house to obtain scrap metal. Defendant appealed, arguing (1) the evidence was insufficient to support the jury’s conclusion that he entered an occupied structure, (2) the district court erred in submitting the adopted-for-overnight-accommodation and the used-for-the-storage-or-safekeeping-of-anything-of-value alternatives defining occupied structure to the jury; and (3) the district court erred in overruling his motion for mistrial based on alleged prosecutorial misconduct during closing argument. The court of appeals affirmed. The Supreme Court reversed the conviction, holding that the evidence was insufficient to support a conviction for burglary. View "State v. Rooney" on Justia Law

Plaintiff brought a tort action against, among other defendants, a fellow university student (Defendant), claiming monetary damages for his injury. Plaintiff’s damage claim included damages for mental pain and mental disability. Defendant requested Plaintiff to provide him with a release, waiving Plaintiff’s privilege to his mental health records and allowing the student to access the mental health records pertaining to Plaintiff’s treatment for anger management while he was in elementary school. Plaintiff refused. The district court ordered Plaintiff to sign an unrestricted patient’s waiver for records, concluding that Plaintiff waived his privilege to his mental health records by putting his mental well-being at issue in this case and that Defendant’s request did not violate Plaintiff’s constitutional right to privacy. The Supreme Court reversed on interlocutory review upon adopting a protocol balancing a patient’s right to privacy in his or her mental health records against a tortfeasor’s right to present evidence relevant to the injured party’s damage claims. Remanded to the district court to allow the parties to present the appropriate evidence called for by this protocol and to apply the protocol before deciding if Defendant should sign a patient’s waiver. View "Fagen v. Grand View Univ." on Justia Law

Grady Billick sought workers’ compensation benefits for a series of work-related injuries. Roberts Dairy, Billick’s current employer, contended that its liability for Billick’s industrial disability should be apportioned because Billick was previously compensated for his losses of earning capacity arising from previous injuries through settlements with previous employers. The Workers’ Compensation Commissioner concluded that Roberts’s liability for permanent partial disability benefits could not be apportioned under the circumstances of this case. The district court reversed, concluding that the Commissioner misapprehended the relevant statutes. The Supreme Court reversed, holding that there was no error in the Commissioner’s interpretation of the relevant statutes. View "Roberts Dairy v. Billick" on Justia Law

Defendant was charged with theft in the third degree based on her current crime and two prior theft convictions. Defendant moved to strike her 2003 conviction of theft in the third degree as a basis to support the charge of third-degree theft, asserting that the conviction was constitutionally infirm because she was not represented by counsel when she pled guilty and served a term of incarceration. In fact, Defendant was held in jail for one day prior to her initial appearance and then, upon pleading guilty, was sentenced to one day in jail, with credit for time served. The district court denied the motion, concluding that Defendant’s situation was not one in which she faced the possibility of imprisonment requiring the appointment of counsel. Defendant was subsequently found guilty of theft in the third degree. The Supreme Court reversed, holding (1) under the right to counsel provision under Iowa Const. art. I, 10, a misdemeanor defendant has a right to counsel when the defendant faces the possibility of imprisonment; and (2) because Defendant was not provided the assistance of counsel and the State stipulated there was not a valid waiver, the 2003 misdemeanor conviction could not be used as a predicate offense to enhance a later punishment. Remanded. View "State v. Young" on Justia Law

Amish Connection Inc. purchased a business insurance policy from State Farm Fire and Casualty Company that only insured damage “caused by rain” if an insured event first ruptured the roof or exterior walls to allow the rain to enter. The policy covered a store Amish Connection operated in a leased space in a shopping mall. The store was damaged when an interior drainpipe failed, allowing rain from the evening’s rainstorm to flood the store. Amish Connection submitted a claim under its policy. State Farm declined the claim based on the rain limitation of the property. Amish Connection filed suit against State Farm for breach of its insurance contract. The district court granted summary judgment for State Farm based on the rain limitation. The court of appeals reversed, concluding that to the extent the limitation of coverage for damage “caused by rain” was ambiguous, it must be construed against State Farm. The Supreme Court vacated the judgment of the court of appeals and affirmed the judgment of the district court, holding that under the unambiguous terms of State Farm’s policy, damage from rainwater released by a breaking drainpipe during a rainstorm is not an insured loss because the damage was caused by rain within the meaning of the rain limitation. View "Amish Connection, Inc. v. State Farm Fire & Cas. Co." on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder and attempt to commit murder. The trial court imposed a sentence of life imprisonment for the murder conviction and a term of twenty-five years for the attempted murder conviction, to be served consecutively. The court of appeals affirmed, holding (1) the evidence was sufficient to support the convictions, there was no abuse of discretion in the imposition of the sentences, and defense counsel provided effective assistance; and (2) the district court erred in refusing to give an instruction describing the affirmative defense of intoxication, but Defendant was not prejudiced by the refusal. The Supreme Court vacated the portion of the court of appeals’ opinion that concluded that the district court erred in failing to submit the intoxication instruction to the jury and otherwise affirmed, holding that the district court did not abuse its discretion in failing to instruct the jury on how to apply the evidence of intoxication in deciding if the State established the specific-intent elements of the crimes. View "State v. Cordero" on Justia Law

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