Justia Iowa Supreme Court Opinion Summaries

The Workers’ Compensation Commission found Employee to be totally and permanently disabled under the odd-lot doctrine and denied Employer and its Insurer (collectively, Employer) certain credits for disability payments previously received by Employee from other sources. The district court affirmed the Commission’s finding that Employee was totally and permanently disabled but reversed on the credit issue. The court of appeals reversed, holding (1) substantial evidence did not support the Commission’s award of permanent total benefits, and (2) the Commission was correct in its decision concerning the credits. On further review, the Supreme Court (1) affirmed the district court’s finding that substantial evidence supported the Commission’s findings that Employee was totally and permanently disabled under the odd-lot doctrine; and (2) reversed the district court’s judgment regarding the issues concerning the credit due Employer. View "Gits Mfg. Co. v. Frank" on Justia Law

Based on a complaint from a district court judge alleging that District Associate Judge Emily Dean arrived at a courthouse in an intoxicated state and could not perform her judicial duties, the Iowa Commission on Judicial Qualifications filed a notice of charges against Judge Dean. After a hearing, the Commission concluded that Judge Dean had violated the rules of judicial conduct and recommended that the judge be suspended for three months without pay. The Supreme Court granted the application of the Commission and held that Judge Dean should be suspended from her judicial without pay but limited the suspension to thirty days. View "In re Dean" on Justia Law

Defendant was a pastor who had sexual relations with four women in his congregation. Defendant was convicted of four counts of sexual exploitation by a counselor or therapist and one count of a pattern or practice to engage in sexual exploitation by a counselor or therapist. The court of appeals reversed and remanded for a new trial, holding that the district court failed properly to instruct the jury on the sexual exploitation statute and that the district court abused its discretion in excluding expert testimony concerning differences between pastoral care and pastoral counseling. The Supreme Court vacated the decision of the court of appeals, concluding that the district court did not err in instructing the jury and excluding the proffered expert testimony. The Court then held (1) the district court erred in denying Defendant’s discovery request for one of the victim’s counseling records and erred in the amount of restitution awarded; and (2) the district courts judgment was correct in all other respects. Remanded. View "State v. Edouard" on Justia Law

The State charged Defendant, a probationer, with burglary and theft after police officers conducted a warrantless search of Defendant’s home. Defendant filed a motion to suppress contending that the search warrant was invalid because it inaccurately described the house to be searched and because an alteration of the warrant based upon a verbal conversation with the issuing judge violated the statutory requirement that search warrant applications be in writing. The district court overruled the motion to suppress, concluding that the search warrant was inadequate but that the warrant was valid because the search was within the contemplation of the probation agreement. The court of appeals affirmed, concluding that the search of the probationer based upon reasonable suspicion of criminal activity and based upon the limited scope of the search was valid under the search and seizure provision of Iowa Const. art I, 8. The Supreme Court reversed, holding that, in accordance with State v. Cullison, the search of Defendant’s home by general law enforcement authorities was unlawful under the Iowa Constitution because the search was based on an invalid warrant. View "State v. Short" on Justia Law

When he was seventeen years old, Appellant committed the crime of first-degree robbery. Appellant was sentenced to a term of imprisonment not to exceed twenty-five years. Appellant was sentenced under a statute that required him to serve at least seventy percent of his sentence before he was eligible for parole. Appellant appealed, arguing that his sentence constituted cruel and unusual punishment. The Supreme Court vacated the sentence and remanded to the district court for resentencing, holding that, for the reasons express in State v. Lyle, filed on this same date, the mandatory sentence violated the prohibition against cruel and unusual punishment under the Iowa Constitution. View "State v. Taylor" on Justia Law

Appellant was a seventeen-year-old high school student when he took a small plastic bag containing marijuana from a fellow student outside the high school. After a jury trial, Appellant was convicted of robbery in the second degree. Appellant was prosecuted as an adult and was sentenced under a statute that required the imposition of a mandatory seven-year minimum sentence of imprisonment. Appellant appealed, arguing that the mandatory minimum was unconstitutional as applied to him. During the pendency of the appeal, the United States decided Miller v. Alabama. The court of appeals affirmed the sentence. The Supreme Court granted review to consider whether Appellant’s sentence was constitutional in light of the cases the Court handed down subsequent to Miller. The Supreme Court vacated the sentence and remanded for resentencing, holding that a statute mandating a sentence of incarceration in a prison for juvenile offenders with no opportunity for parole until a minimum period of time has been served is unconstitutional under the Iowa Constitution. View "State v. Lyle" on Justia Law

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