Justia Iowa Supreme Court Opinion Summaries

Plaintiffs, fourteen African-Americans, brought a class action suit against the State, including thirty-seven different executive branch departments, under the Federal Civil Rights Act and the Iowa Civil Rights Act. In their complaint, Plaintiffs alleged that the State unlawfully discriminates against African Americans in employment. The district court entered judgment in favor of the State. The Supreme Court affirmed, holding that Plaintiffs did not meet their burden of establishing that the underlying documents did not provide sufficient information to allow employment practices to be separated for meaningful statistical analysis, and therefore, Defendant was entitled to summary judgment under the Iowa Civil Rights Act.View "Pippen v. State" on Justia Law

Dennis Smith was formerly employed by the College of Engineering at Iowa State University (ISU), where he was “subjected to wrongful conduct for an extended period of time in a job he had held for nearly a decade.” Smith filed suit against ISU and the State, alleging, inter alia, that he suffered retaliation for reporting managerial misconduct to ISU’s president. After a jury trial, Smith recovered $500,000 for intentional infliction of emotional distress and $784,027 under a whistleblowing statute. The court of appeals affirmed the intentional infliction of emotional distress award but set aside the statutory whistleblowing award, finding that Smith had failed to prove a causal relationship between his disclosures to the president and any actions of reprisal taken against him. The Supreme Court (1) affirmed the jury’s emotional distress award, holding that Defendants’ conduct toward Smith was outrageous and that the verdict was not excessive; and (2) reduced, but did not set aside, the district court’s award of damages under the whistleblowing statute, where the evidence supported the finding that Smith suffered retaliation for reporting managerial misconduct but where Smith’s loss of his job was not causally linked to his discussion with ISU’s president. View "Smith v. Iowa State Univ. of Sci. & Tech." on Justia Law

Plaintiff developed a neurological disorder from her prolonged use of metoclopramide, sold under the brand name Reglan and as a competing generic formulation. Plaintiff admitted she ingested only generic metoclopramide but sued both the manufacturer of the generic drug and the manufacturers of the branded formulation. The district court dismissed all of Plaintiff’s claims, ruling (1) Plaintiff’s claims against the generic manufacturer were preempted by federal law that requires conformity with the brand manufacturers’ warning labels approved by the Food and Drug Administration (FDA); and (2) Plaintiff’s claims against the brand manufacturers required proof that the brand defendants manufactured or supplied the product that caused Plaintiff’s injury. The Supreme Court affirmed summary judgment for the brand manufacturers and reversed in part summary judgment for the generic manufacturer, holding (1) Plaintiff’s state common law tort claims against the generic manufacturer based on inadequate warnings were not preempted to the extent that the generic manufacturer failed to adopt warning language approved by the FDA for Reglan; and (2) the brand manufacturers are not liable for injuries to those who used only the competing generic formulation. View "Huck v. Wyeth, Inc." on Justia Law

Eagle Point Solar proposed to enter into a long term financing agreement with the City of Dubuque that would provide the City with renewable energy. Under the agreement, Eagle Point would construct a solar energy system, and the City would purchase all of the electricity generated by the system. However, if Eagle Point was a “public utility” under Iowa Code 476.1 or an “electric utility” under Iowa Code 476.22 it would be prohibited from serving customers, such as the City, who were located within the exclusive service territory of Interstate Power and Light Company, another electric utility. The Iowa Public Utilities Board (IUB) concluded that Eagle Point would be a public utility under the proposed business arrangement. The district court reversed, concluding that Eagle Point’s proposed arrangement with the City did not make it an electric utility for purposes of the statutes. The Supreme Court affirmed, holding that Eagle Point was not a public utility under section 476.1 or section 476.22. View "SZ Enters., LLC v. Iowa Utils. Bd." on Justia Law

Susan Heathcote and Carrie La Seur served on the Environmental Protection Commission during a period of time when the Commission considered the adoption of rules to prevent the degradation of Iowa’s water resources. In 2009, the Commission voted to approve two antidegradation rules and procedures, which were approved by the EPA. Plaintiffs sought to overturn the rule and regulation, alleging that Heathcote was disqualified to vote because she engaged in activities in her employment in support of the rule and that La Seur was disqualified to serve on the Commission at the time she voted because she had moved to Montana and lost her status as an elector in Iowa. The district court granted summary judgment to the Commission regarding both Heathcote’s and La Seur’s participation. The Supreme Court affirmed, holding (1) the nature of rulemaking does not disqualify a Commission member from voting to adopt rules she personally and professionally supported; and (2) the disqualification of a Commission member did not invalidate the action taken by the Commission when the disqualification did not undermine the integrity of the process and the public interest supported validating the rule despite the disqualification. View "Iowa Farm Bureau Fed’n v. Envtl. Prot. Comm’n" on Justia Law

Russell Phillips, an employee of the Chicago Central & Pacific Railroad, filed a negligence action against the railroad. The jury returned a general verdict in favor of Phillips, and the district court awarded Phillips damages. The railroad paid Phillips the amount of the judgment but withheld a portion of the award to pay taxes allegedly due under the Railroad Retirement Act (RRTA). Phillips refused to execute a satisfaction of judgment, arguing that the railroad should have withheld any amount for tax purposes. Subsequently, the railroad moved for an order of satisfaction and discharge of judgment. The district court sustained the motion. The Supreme Court affirmed, holding (1) an award for time lost is subject to tax withholding under the RRTA; and (2) the railroad fully satisfied the judgment. View "Phillips v. Chicago Cent. & Pac. R.R. Co." on Justia Law

Aaron Cannon, a student at Palmer College of Chiropractic, was blind and requested that Palmer make accommodations for his visual disability. Palmer denied the request, explaining that it could not provide the proposed accommodations and curricular modifications because they would fundamentally alter its educational program. Cannon eventually withdrew from the program. Cannon filed a complaint with the Davenport Civil Rights Commission, arguing that Palmer had discriminated against him on the basis of his disability. The Commission granted relief, finding that Palmer had failed to comply with the applicable federal and state disability laws. The district court reversed. The Supreme Court reversed, holding that the Commission did not erroneously interpret or irrationally apply the applicable law in concluding that Palmer failed to establish that Cannon’s suggested accommodations would fundamentally alter its curriculum. View "Palmer College of Chiropractic v. Davenport Civil Rights Comm’n" on Justia Law

John Goodpaster worked as a customer service manager for Schwan’s Home Service, Inc., the largest home delivery frozen foods company in the nation, at Schwan’s Des Moines location. Goodpaster’s duty was to sell and deliver company products, and a basic requirement of Goodpaster’s job was that he drive a commercial vehicle. When Goodpaster began experiencing medical problems, his sales began to decrease, and he was eventually terminated. Goodpaster sued Schwan’s under the Iowa Civil Rights Act (ICRA) for disability discrimination and retaliation, claiming his employment was terminated because he had multiple sclerosis. The district court granted summary judgment in favor of Schwan’s. The Supreme Court reversed, holding (1) multiple sclerosis is a disability contemplated by the ICRA; and (2) a genuine issue of material fact existed regarding whether Goodpaster was qualified to perform the essential functions of his position. Remanded. View "Goodpaster v. Schwan’s Home Serv., Inc." on Justia Law

Plaintiff, who attended school in the New London Community School District, was fourteen years old when Gina Sisk, a teacher who also served as Plaintiff’s track coach, began to engage in improper sexual conduct toward Plaintiff. The alleged abuse occurred in the early 2000s. In 2012, Plaintiff filed a petition against the District asserting several tort claims. Defendants filed a motion for summary judgment, arguing that Plaintiff’s claims were barred by the statute of limitations in the pre-2007 Iowa Municipal Tort Claims Act (IMTCA). The district court denied Defendants’ motions. At issue before the Supreme Court was whether a discovery rule was available to Plaintiff. The Supreme Court reversed, holding (1) the common law discovery rule does not apply to claims under the pre-2007 IMTCA; (2) the limitations provision in Iowa Code 614.8A does not apply to individuals who were fourteen years or older when the alleged sexual abuse occurred; and (3) the absence of a discovery rule in the pre-2007 IMTCA does not violate the Iowa Constitution’s equal protection clause. View "Doe v. New London Cmty. Sch. Dist." on Justia Law

Defendant pleaded no contest to second-degree sexual assault of a child, a felony, in Wisconsin. The Wisconsin trial court deferred judgment of conviction (DJOC), which allowed the Wisconsin court to refrain from entering an adjudication of guilt and a judgment for four years if Defendant agreed to certain terms. Before the termination of the DJOC, the state of Iowa charged Defendant with a violation of Iowa’s felon-in-possession statute, Iowa Code 724.26, which prohibits felons from possessing firearms in Iowa. Defendant filed a motion to dismiss the Iowa charge, arguing that the predicate Wisconsin felony was not a conviction for purposes of section 724.26. The district court denied the motion. The Supreme Court affirmed, holding that district court properly denied Defendant’s motion to dismiss the case where the Wisconsin court found Defendant guilty upon his tendering of a no contest plea and where Defendant had not completed the terms of his deferred judgment on his felony count. View "State v. Olsen" on Justia Law