Justia Iowa Supreme Court Opinion Summaries

Defendant was convicted of operating while intoxicated, second offense. Defendant appealed the district court’s denial of his motion to suppress the breath-test result obtained after his arrest, arguing that he had been denied his statutory right to an independent chemical test. The court of appeals reversed, concluding that the district court erred in denying Defendant’s motion to suppress. The Supreme Court affirmed, holding (1) Defendant’s statutory right to an independent chemical test was violated when he made statements that could be reasonably construed as a request for an independent test under Iowa Code 321J.11 but law enforcement denied his request, and (2) the error was not harmless. Remanded for a new trial. View "State v. Lukins" on Justia Law

Rick Bertrand, a Republican, and Rick Mullin, a Democrat, were candidates for the Iowa Senate in the 2010 general election. During campaigning, Mullin approved of a television commercial, titled “Secrets,” which stated that Bertrand was a sales agent for a drug company that marketed a dangerous sleep drug to children. After the commercial aired, Bertrand filed a lawsuit against Mullin seeking injunctive relief and monetary damages based on defamation. The jury returned a verdict of $31,000 against Mullin and $200,000 against the Iowa Democratic Party. Mullin appealed, contending that the district court erred by failing to grant his motion for judgment notwithstanding the verdict. The Supreme Court reversed the judgment of the district court and dismissed the case, holding that sufficient evidence did not support a finding of actual malice. View "Bertrand v. Mullin" on Justia Law

Husband died in 1993, and his will was probated. Wife received almost all of Husband's property pursuant to a residuary clause in the will. In 2011, Wife died. Subsequently, several relatives (Relatives) who had not been formally notified of the 1993 probate proceedings reviewed Husband's will. Relatives brought an action to reopen the estate, claiming that a different residuary clause in Husband's will entitled them to Husband's property. The coexecutors of Wife's estate filed a motion for summary judgment, asserting that the petition was time-barred under Iowa Prob Code 633.488, which states that a party who did not receive formal notice of the final report and accounting has five years from the final report to reopen settlement of an estate. The district court denied the motion, concluding that section 633.489, which allows estates to be reopened without time limit under certain circumstances, governed Relatives' claim. The court of appeals affirmed. The Supreme Court reversed, holding that section 633.488 was the applicable statute in this case. Remanded.View "In re Estate of Sampson" on Justia Law

Defendant was charged with and found guilty of driving under revocation. Defendant appealed, arguing that the district court’s admission of a certified abstract of his driving record and affidavits of the mailing of suspension notices violated his rights under the Confrontation Clauses of the United States and Iowa Constitutions. The court of appeals concluded that the admission of the disputed documents did not violate the Confrontation Clauses. The Supreme Court affirmed, holding (1) the admission of the certified abstract of Defendant’s driving record did not violate the Confrontation Clauses; and (2) the admission of the affidavits of the mailing of suspension notices violated the Confrontation Clauses, but their admission into evidence was harmless error. View "State v. Kennedy" on Justia Law

Plaintiff worked as a service dog trainer but was not disabled. Plaintiff filed a lawsuit against Drake University Law School, where she was a student, alleging that Drake barred her from bringing with her a dog she was training into the classroom and to another event in violation of Iowa Code 216C.11(2). The district court granted Drake’s motion to dismiss after applying the four-factor test adopted from Cort v. Ash for determining whether an Iowa statute provides an implied private right of action, concluding that section 216C.11(2) creates no private enforcement action. The Supreme Court affirmed the judgment of the district court, holding that, under an application of the Cort factors, section 216C.11(2) does not provide a service dog trainer with a private right to sue. View "Shumate v. Drake Univ." on Justia Law

Larysa and Alan Asher filed an action individually and as parents and next friends of their minor child, asserting that Dr. Anthony Onuigbo was negligent in delivering their baby. The jury found in favor of Asher and awarded damages. Onuigbo appealed. The Supreme Court affirmed, holding (1) the district court erred by providing the jury with a causation instruction based upon the Restatement (Second) of Torts rather than an instruction based upon the Restatement (Third) of Torts, as adopted by the Court in Thompson v. Kaszinski, but the error was harmless under the facts and circumstances of this case; and (2) substantial evidence supported submission of two challenged specifications of negligence to the jury. View "Asher v. OB-GYN Specialists, P.C." on Justia Law

AFSCME Iowa Council 61, which represents certain State employees in collective bargaining, entered into negotiations with the State regarding its 2013-2015 collective bargaining agreement. The State proposed deleting certain contract provisions from the existing contract that addressed outsourcing of work performed by public employees. AFCME disputed the State’s classification of this provision as a permissive bargaining subject, arguing that the provision was a procedure for staff reduction and therefore a mandatory subject of bargaining. The Iowa Public Employment Relations Board (“PERB”) concluded that the predominate purpose of the proposal was to designate a process for implementing a staff reduction due to outsourcing, and therefore, the proposal was subject to mandatory bargaining. The district court reversed. The Supreme Court affirmed in part and reversed in part, holding (1) to the extent the primary purpose of the proposal was to preclude the State from reducing staff in response to outsourcing, it was a permissive rather than a mandatory subject of bargaining; but (2) if, on remand, PERB determined that the State was permitted to reduce employment resulting from outsourcing, then the proposal may be found to be a mandatory subject of bargaining. View "AFSCME Iowa Council 61 v. State, Dep’t of Admin. Servs." on Justia Law

John Corrado and his company (collectively, Corrado) and Life Investors Insurance Company of America (LICA) entered into a settlement agreement following a dispute. The agreement purported to bear Corrado's signature, but Corrado challenged the signatures' validity. The U.S. district court granted summary judgment to LICA, concluding that Corrado ratified the parties' contract. The U.S. court of appeals reversed. On remand, the district court found the settlement agreement authenticated. The Iowa Supreme Court answered a certified question of law by holding that if a party receives a copy of an executed contract with that party's signature thereon, even where it is not known who applied the party's signature to the contract or whether the signature was authorized, and the party does not challenge the signature or otherwise object to the contract and accepts benefits and obligations under the contract for at least six years, then the party has ratified the contract and is therefore bound by its terms. View "Life Investors Ins. Co. of Am. v. Estate of Corrado" on Justia Law

Plaintiff filed suit against the Defendants, county and municipal officials, alleging that he was wrongfully assaulted and arrested by certain law enforcement officers and deputies. The district court concluded that Defendants were entitled to immunity because they were acting on behalf of the state in an official capacity and that the Iowa Tort Claims Act (ITCA) barred Plaintiff's claims for assault, battery, false arrest, and malicious prosecution. The Supreme Court reversed, holding that any immunity conferred by the ITCA did not protect Defendants from being sued under the Iowa Municipal Tort Claims Act (IMTCA), which applies to political subdivisions and their employees, and that the IMTCA does not bar claims for assault, battery, false arrest, and malicious prosecution. Remanded.View "Thomas v. Gavin" on Justia Law

Dennis Hagenow was injured in an automobile accident with Betty Schmidt. Hagenow and his wife (Plaintiffs) filed an uninsured motorist claim with American Family Mutual Insurance Company. American Family denied the claim, determining that Schmidt’s vehicle was not an uninsured motor vehicle under Plaintiffs’ policy. Plaintiffs subsequently filed a breach of contract action against American Family. American Family moved for summary judgment, arguing (1) because Schmidt had automobile insurance at the time of the collision, she was not an uninsured motorist (UM) under the policy; and (2) Plaintiffs were not “legally entitled to recover” under the policy because a jury in Plaintiffs’ underlying action against Schmidt found Schmidt not liable for Plaintiffs’ damages. The district court denied the motion. The Supreme Court reversed, holding (1) Plaintiffs were not “legally entitled to recover” under Iowa law or their UM policy; and (2) Schmidt’s vehicle was not an uninsured motor vehicle under the terms of Plaintiffs’ UM provision. Remanded. View "Hagenow v. Am. Family Mut. Ins. Co." on Justia Law