Justia Iowa Supreme Court Opinion Summaries

Plaintiff was injured when she crashed on her bicycle while riding on a sidewalk abutting the grounds of the University of Iowa in Iowa City. Plaintiff filed a negligence action against the City, claiming that an alleged defect in the sidewalk caused the accident. The City filed a motion to add the State as a third-party defendant, citing the City’s ordinance requiring an abutting property owner to maintain the sidewalk in a safe condition. The district court granted the motion. The City then filed a cross-claim against the State seeking contribution. The district denied the State’s motion to dismiss the City’s cross-claim, concluding (1) the City’s contribution claim was not excluded from the Iowa Tort Claims Act (ITCA) and adequately pled a claim under the ITCA; and (2) an ordinance can establish a duty, the breach of which supports a negligence claim. The Supreme Court affirmed, holding (1) the City’s ordinance was not preempted by Iowa Code 364.12(2); (2) the potential imposition of indemnity under the ordinance does not give rise to an unlawful tax; and (3) the City’s claim against the State was within the scope of ITCA for purposes of waiver of sovereign immunity. View "Madden v. City of Iowa City" on Justia Law

Claimant, an undocumented worker, underwent surgery in 2007 to correct work-related hernias. Claimant returned to work, but in 2008 Employer terminated Claimant's employment. In 2007, Claimant filed for workers' compensation benefits. A deputy commissioner awarded running healing period benefits from the date of the work-related injury until Claimant reached maximum medical improvement. The Iowa Workers' Compensation Commissioner affirmed the deputy's decision. The district court affirmed, holding that substantial evidence supported the running award of healing period benefits, the Commissioner was correct in starting healing period benefits at a date prior stipulated date, and Claimant's return to work did not cut off any of her benefits. The Supreme Court affirmed in part and reversed in part, holding (1) an undocumented worker is entitled to healing period benefits under the Iowa Workers' Compensation Act; (2) the district court did not err in affirming on the issues of substantial evidence and the starting date of Claimant's benefits; and (3) Claimant was not entitled to healing period benefits while she was working. Remanded. View "Staff Mgmt. v. Jimenez" on Justia Law

After a jury trial, Defendant was convicted of third-degree sexual abuse. Six years later, the Supreme Court overturned Defendant's conviction and sentence and remanded for a new trial. The second trial resulted in Defendant's acquittal. Defendant subsequently filed an application to be declared a wrongfully imprisoned individual pursuant to Iowa Code 663A.1. The district court granted the application. The State appealed. The Supreme Court reversed and remanded, holding (1) Defendant was eligible to bring a wrongful imprisonment claim when he was acquitted on retrial; (2) the district court erred by failing to consider testimony that had been presented at Defendant's two criminal trials in making the wrongful imprisonment determination, even though the State did not show the witnesses were no longer available; and (3) while substantial evidence supported the district court's finding of innocence on the existing record, a remand was necessary for the court to consider the full record, including the prior testimony.View "State v. DeSimone" on Justia Law

Kenneth and Melissa were married for over twenty years when they sought a divorce in 1994. In 2011, Kenneth filed a second petition for modification, requesting termination or reduction of his weekly spousal support and monthly medical insurance payments to Melissa. After a modification trial, the district court modified the decree to (1) require that Kenneth, instead of making weekly support payments indefinitely, continue making weekly payments until he reached the age of sixty-seven, or until Melissa remarried, or until either party died; and (2) eliminate the requirement that Kenneth subsidize Melissa's monthly health insurance premium. The Supreme Court affirmed the district court's judgment as modified and (1) reduced Kenneth's obligation to pay weekly spousal support; and (2) terminated Kenneth's monthly obligation to contribute to the cost of Melissa's health insurance.View "In re Marriage of Michael" on Justia Law

The administrators of Decedent’s estate listed residential real estate for sale. Decedent’s common law spouse objected to the proposed sale, claiming it was her marital home. The district court recognized the surviving spouses’s common law rights but nonetheless approved the sale. The buyers took possession and made improvements to the home. Thereafter, the court of appeals reversed and remanded for consideration of the homestead interest of the spouse. On remand, the district court gave the surviving spouse the option of taking possession of the home upon paying the buyers a substantial part of the cost of their improvements to the home or receiving the proceeds from the estate’s sale of the real estate. The Supreme Court affirmed as modified, holding (1) the surviving spouse could retake possession upon payment of the approximate value of the home before the improvements were made less any credit to which she was entitled from the buyers for rent during the period the spouse had been dispossessed; and (2) the spouse could transfer title to the buyers and receive the proceeds from the estate’s sale of the home plus credit for rent from the date of the conveyance to the buyers until the date of judgment. View "In re Estate of Waterman" on Justia Law

When she was sixteen years old A.J.M. was adjudicated delinquent by the juvenile court. The delinquency was based on the crime of sexual abuse in the second degree, an offense covered under the sex offender registry statute. The juvenile court opted to wait to decide whether A.J.M. should be required to register as a sex offender until she successfully completed sexual offender treatment. After a final review hearing, the juvenile court discharged A.J.M. and waived the requirement for her to register as a sex offender, concluding that A.J.M.’s failure to overcome her problems was the fault of the State. The Supreme Court affirmed the decision of the juvenile court to discharge A.J.M. but concluded that the record was not sufficient for the Court to properly review the juvenile court’s exercise of discretion to waive the requirement for A.J.M. to register as a sex offender. Remanded. View "In re Interest of A.J.M." on Justia Law

Plaintiff, the workers’ compensation commissioner, filed an amended petition against the State and individual defendants named in their official and individual capacities. Plaintiff’s claims stemmed from his refusal to resign upon the Governor-elect’s demand for resignation and Plaintiff's subsequent reduction in salary. The attorney general provided a certification certifying that the individual defendants were acting within the scope of their employment at the time of the allegations contained in the amended petition, and therefore, certain immunities applied to various counts of the petition. The district court dismissed those counts alleging that the individual defendants acted outside the scope of their employment, concluding that the attorney general’s certification was applicable to all of Plaintiff’s claims. The Supreme Court reversed, holding (1) the Iowa Tort Claims Act applies only to torts committed by state employees when acting within the scope of their employment; and (2) therefore, the attorney general’s certification was not applicable to Plaintiff’s common law claims alleging that the individual defendants acted outside the scope of their employment. Remanded. View "Godfrey v. State " on Justia Law

In the underlying action, Plaintiff filed a personal injury action against Defendants, the State, and a volunteer driver for the Iowa Department of Human Services. The Supreme Court held that Defendants were entitled to summary judgment under the statute of limitations and the volunteer-immunity provisions of the Iowa Tort Claims Act. Plaintiff subsequently filed this malpractice action against her attorney (Attorney) in the underlying case. The jury returned a verdict finding Attorney was negligent and that his negligence caused damage to Plaintiff. The Supreme Court affirmed on appeal and reversed on cross-appeal, holding (1) the driver's volunteer immunity did not preclude the State's respondeat superior liability for Attorney's negligence, and therefore, Plaintiff's legal malpractice claim against Attorney did not fail because she could have recovered in the underlying case had the claim been timely filed; (2) Attorney could not reduce the malpractice-damage award by the contingent fee he would have taken if the underlying action had been successful because he did not earn the fee and because Plaintiff must pay new counsel who prosecuted the malpractice action; and (3) Plaintiff was entitled to interest running from the date by which her underlying action should have been tried, absent Attorney's negligence.View "Hook v. Trevino" on Justia Law

The Iowa Supreme Court Attorney Disciplinary Board filed a complaint against Attorney Doe based on sexual misconduct allegations by the attorney's client, Jane Doe. The Grievance Commission of the Iowa Supreme Court scheduled a hearing on the matter. Jane's attorney requested a continuance of the scheduled hearing so that she could be present when Jane testified before the Commission. The Commission President quashed Jane's attorney's appearance and denied her request for a continuance, stating that witnesses testifying before the Commission were not entitled to have an attorney present during the proceedings and that that absence of Jane's attorney from the hearing would cause no unfairness to Jane. The Supreme Court reversed the Commission's order, holding that a person called upon to be a witness before the Commission may be represented by counsel for the limited purpose of protecting rights personal to the witness in the proceeding.View "Iowa Supreme Court Attorney Disciplinary Bd. v. Attorney Doe No. 762" on Justia Law

The City of Waterloo agreed to transfer to a residential developer property the City originally acquired for use as a road right-of-way. Taxpaying residents of the City challenged the legality of the proposed transfer, arguing that the City failed to follow statutory procedures for the sale of unused right-of-way, including compliance with certain appraisal, notice, right-of-first refusal and public bid requirements. The district court dismissed the case, concluding that the subject property was not unused right-of-way. The Supreme Court reversed, holding that the property was unused right-of-way, and therefore, the City could not sell or transfer it to the developer without first following the procedure prescribed in Iowa Code 306.23. View "Hartog v. City of Waterloo" on Justia Law