Justia Iowa Supreme Court Opinion Summaries

After Plaintiff visited her mother at a residential home staff members reported that Plaintiff may have mistreated her mother. The officer who investigated the allegations arrested Plaintiff and charged her with simple misdemeanor assault. A jury acquitted Plaintiff of the charge. Plaintiff then filed this civil action against the arresting officer and the city that employed him, alleging negligence, false imprisonment, and malicious prosecution. The district court granted summary judgment in favor of the defendants. The court of appeals reversed as to the false imprisonment claim. The Supreme Court vacated the decision of the court of appeals, concluding that reasonable ground existed to arrest Plaintiff for the indictable offense of dependent adult abuse, and therefore, Plaintiff’s false imprisonment claim failed as a matter of law. View "Veatch v. City of Waverly" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree and other criminal offenses. The Supreme Court affirmed, holding (1) Defendant failed to preserve for appeal his argument that an instruction given to the jury that it may not consider a lesser offense unless it unanimously found Defendant not guilty of the greater offense was a misstatement of the law; (2) certain instructions concerning the various inferences and conclusions the jury was permitted to draw did not constitute reversible error; and (3) Defendant was not denied effective assistance of counsel for failing to argue that the contested instructions were improper. View "State v. Ambrose" on Justia Law

Defendant was in custody of a residential facility commonly referred to as a halfway house when he was charged with knowingly possessing marijuana on the grounds of a facility “under the management of the department of corrections” pursuant to Iowa Code 719.7(3)(c). After a jury trial, Defendant was convicted. Defendant appealed, arguing that his trial counsel provided ineffective assistance for specifically failing to assert that the evidence was insufficient to establish that the residential facility was an institution under the management of the Department of Corrections (Department). The Supreme Court reversed, holding that defense counsel was ineffective as a result of his failure to assert that there was insufficient evidence to show the residential facility was an institution under the management of the Department, and Defendant was prejudiced by the failure to his counsel to assert the claim. View "State v. Halverson" on Justia Law

Appellant was the established father of J.C., although he was not the child’s biological father. After the juvenile court adjudicated J.C. a child in need of assistance (CINA), the State filed a petition to terminate the parental rights of Mother and the child’s biological father. The juvenile court dismissed Appellant as a party, concluding that because he was neither the child’s biological father nor her adoptive father, Appellant was not a necessary party in the pending CINA proceedings and termination of parental rights proceedings. The Supreme Court affirmed, holding that the juvenile court correctly dismissed Appellant as a necessary party to the juvenile proceedings because, although Appellant was J.C.’s established father, he was not her parent under Iowa law. View "In re Interest of J.C." on Justia Law

Defendant pled guilty to two counts of incest and was sentenced to two consecutive terms of incarceration not to exceed five years. The Supreme Court remanded the case for resentencing on the grounds that the district court had relied upon an improper sentencing consideration. Upon resentencing, the district court again sentenced Defendant to two consecutive terms of incarceration not to exceed five years. In so doing, however, the court again referred to the impermissible sentencing factor. The Supreme Court vacated the sentence, holding that although the district court attempted to disclaim the reference to the impermissible sentencing factor, Defendant’s sentence must be vacated and remanded for resentencing to protect the integrity of the judicial system from the appearance of impropriety. View "State v. Lovell" on Justia Law

Kevin Fink filed a petition requesting alternate medical treatment for knee injuries allegedly sustained during the course of his employment with Denison Municipal Utilities (DMU). The workers’ compensation commissioner sent DMU a notice providing that DMU was required to file a first report of injury pursuant to Iowa Code 86.12. When DMU failed to file the first report of injury, the deputy commissioner assessed $1,000 against DMU. The district court reversed the $1,000 assessment, concluding that the deputy commissioner incorrectly interpreted section 86.12 as authorizing the commissioner to demand DMU to file a first report of injury, that the first report of injury was not required by section 86.11, and therefore, the record lacked substantial evidence to support the assessment against DMU. The Supreme Court reversed, holding (1) in this case, DMU was required to file a first report of injury; and (2) the deputy commissioner’s decision that DMU failed to make a sufficient showing of good cause to avoid the $1,000 assessment pursuant to section 86.12 was supported by substantial evidence. View "Denison Mun. Utils. v. Iowa Workers’ Comp. Comm’r" on Justia Law

This case involved three small school districts, Northeast Community School District, East Central Community School District, and Preston Community School District. In 2010, the school boards of Northeast and East Central entered into a whole grade sharing agreement. Thereafter, citizens from Preston and East Central voted to reorganize their districts and merge the districts together into a new school district called Easton Valley Community School District (Easton). The Easton school board subsequently sent a notification of cancellation of the agreement to the superintendent of Northeast, claiming that when East Central ceased to exist the agreement was null. Northeast filed a petition for declaratory action and mandamus and then amended its petition alleging repudiation of the agreement. The district court granted summary judgment for Easton, concluding (1) the agreement and the reorganization were valid but that the two were in direct conflict, and (2) the East Central school board did not have the ability to bind Easton as its successor corporation. The Supreme Court reversed, holding that the agreement could bind the reorganized school district. View "Northeast Cmty. Sch. Dist. v. Easton Valley Cmty. Sch. Dist." on Justia Law

In 2006, Cable One, Inc., which offers cable television and internet access, began offering Voice over Internet Protocol (VoIP) service to its residential customers in Sioux City. In 2008 and 2009, the Iowa Department of Revenue determined that Cable One should be assessed based on the value of its telephone operating property in the state. Cable One appealed, arguing that it was not a telephone company subject to taxation under Iowa Code chapter 433 because VoIP is not the equivalent of telephone service. An administrative law judge (ALJ) in the Iowa Department of Inspections and Appeals entered summary judgment in favor of Cable One, concluding that the company did not fit the “historical context of a ‘telephone company.’” The Iowa State Board of Tax Review agreed with the ALJ that Cable One was not subject to assessment under chapter 433. The district court affirmed. The Supreme Court reversed, holding (1) wiring that was originally installed for cable television purposes but is now also used to provide VoIP service is a “telephone line”; and (2) therefore, Cable One, which operates these lines, is subject to central assessment for property tax purposes as a telephone company. View "Kay-Decker v. Iowa State Bd. of Tax Review" on Justia Law

Defendant pleaded guilty to possession of a controlled substance pursuant to a plea agreement. The district court deviated from the recommended sentence in the plea agreement. However, the court did not give its reason for Defendant’s sentence in the written sentencing order. The court of appeals affirmed the sentence because, under current caselaw, Defendant waived his appeal rights as to his sentence by waiving reporting of the sentencing hearing. The Supreme Court affirmed in part and vacated in part the court of appeals, holding (1) a defendant who waives reporting of sentencing and fails to provide a recreated record does not waive error when the sentencing judge fails to indicate on the written record the reasons for the sentence imposed; and (2) the district court did not err by deviating from the plea agreement in this case. View "State v. Thompson" on Justia Law

Plaintiff, a contractor-developer, bought a residential lot from a realtor in order to build townhomes for sale. Plaintiff filed a complaint against the original developers whose contractor had performed purportedly substandard soil work, alleging that the lot had improperly compacted backfill which required significant additional work to get it ready for construction. Plaintiff sued under the theory of breach of the implied warranty of workmanlike construction. The district court granted summary judgment for Defendants, concluding that the implied warranty did not apply to the sale of a lot without a dwelling. The court of appeals affirmed. The Supreme Court affirmed, holding that the implied warranty of workmanlike construction does not apply to a for-profit developer’s purchase of a lot with no dwelling, regardless of the work performed by the seller to make the lot buildable. View "Rosauer Corp. v. Sapp Dev., LLC" on Justia Law