Justia Iowa Supreme Court Opinion Summaries

Police officers stopped Defendant’s vehicle after discovering that the vehicle’s license plate frame covered up the county name on the license plate, which the officers believed violated Iowa Code 321.37(3). As a result of the stop, Defendant was charged with possession with intent to deliver crack cocaine, a drug tax stamp violation, and driving under suspension. A district court judge denied Defendant’s motion to suppress, concluding that the license plate frame violation gave no reason to stop Defendant but that the stop was lawful based on a reasonable suspicion of drug dealing. A different judge who presided at trial upheld the stop based on the license plate violation alone. After a jury trial, Defendant was found guilty as charged. The court of appeals affirmed, which held that the traffic stop was lawful based on reasonable suspicion of drug dealing without deciding the license plate issue. The Supreme Court affirmed the conviction without reaching the issue of whether the traffic stop was lawful based on reasonable suspicion of drug dealing, holding that a license plate frame that covers up the county name violates Iowa Code 321.37(3) and provides a valid basis for a traffic stop. View "State v. Harrison" on Justia Law

Plaintiffs, property owners, filed a lawsuit against the City of Ottumwa alleging that the City negligently managed storm water by approving a development. Plaintiffs alleged this action caused flooding to their downstream home. The jury returned a verdict in favor of Plaintiffs and awarded Plaintiffs damages of $84,400. The Supreme Court reversed, holding that the district court erred by denying the City’s motion for judgment notwithstanding the verdict, as there was not substantial evidence in the record from which a jury could conclude that the City’s negligence caused Plaintiffs’ damages, and therefore, there was insufficient evidence to support submitting the case to the jury. View "Garr v. City of Ottumwa" on Justia Law

After the mother of nine-year-old N.S. and five-year-old J.S. admitted to using methamphetamine, the juvenile court filed an order adjudicating N.S. and J.S. children in need of assistance (CINA) under Iowa Code 232.2(6)(a), (b), and (c)(2). A dispositional hearing was subsequently held, and N.S. and J.S. were placed with their paternal grandmother. The court of appeals reversed, concluding that the State failed to meet its burden of proving that the children should be adjudicated CINA under section 232.2(6)(b). The Supreme Court affirmed the decision of the court of appeals and reversed the order of the juvenile court finding N.S. and J.S. to be CINA under section 232.2(6)(b), holding that a parent’s status as a methamphetamine addict, without more, is not sufficient to establish an imminent likelihood of physical injury to a child under the statute. View "In re Interest of J.S." on Justia Law

At issue in this case was whether a mother who serves as the guardian for her intellectually disabled adult son must obtain court approval before arranging a vasectomy for him. Maria Kennedy was the legal guardian of Stuart Kennedy, a twenty-one-year-old man with intellectual disabilities who lived in a group home. In 2013, Stuart filed a petition to terminate the guardianship. Maria, in turn, petitioned for appointment of an involuntary conservator for Stuart. Concerned that Stuart was having sex with his coworker, Maria took Stuart to the doctor’s office to get a vasectomy. Stuart’s attorney subsequently filed a further petition to terminate or modify the guardianship because Maria had forced Stuart to undergo sterilization. After a combined hearing on the petitions, the probate court (1) declined to terminate Stuart’s guardianship, (2) found Maria did not violate Iowa Code 633.635(2)(b) by arranging for Stuart’s vasectomy without court approval, and (3) ordered Maria’s appointment as Stuart’s conservator. The Supreme Court (1) held that section 633.635(2) required Maria to get prior court approval for Stuart’s vasectomy; but (2) affirmed the guardianship and conservatorship orders entered by the probate court. View "In re Guardianship & Conservatorship of Kennedy" on Justia Law

On March 11, 2014, Anthony Bisignano filed an affidavit of candidacy for Iowa Senate in District 17 with the Iowa Secretary of State. Ned Chiodo filed an objection to the affidavit of candidacy, claiming that Bisignano was disqualified from holding public office based on his prior conviction of the crime of operating while intoxicated (OWI), second offense. A three-person state elections panel denied the objection, and the district court affirmed. The Supreme Court affirmed, holding that a person convicted of the crime of OWI, second offense, is not disqualified from holding a public office in Iowa. View "Chiodo v. Section 43.24 Panel" on Justia Law

After a trial, Angela and Patric were divorced pursuant to a dissolution decree that awarded the parties joint legal custody and joint physical care of the parties' two children. Angela appealed, arguing that the district court erred in failing to grant her motion for continuance and in ordering joint physical care. The Supreme Court affirmed, holding that the district court did not err in (1) denying Angela's motion to continue under the circumstances presented in this case, and (2) awarding joint physical care based on the court's finding that joint physical care was in the best interests of the children.View "In re Marriage of Harris" on Justia Law

After a jury trial, Defendant was convicted of sexual exploitation by a school employee in violation of Iowa Code 709.15(3)(a) and (5)(a). At the time of the offense, Defendant was a worker at a local pipe manufacturer who, while not a licensed teacher, coached high school basketball under a coaching authorization. Defendant appealed, arguing that he was not a school employee as the term is used under section 709.15(3)(a), and therefore, he was not subject to criminal prosecution under this statute. The Supreme Court reversed and remanded with instructions to dismiss the case, holding that a coach who holds a teaching or other professional license is subject to the statute, but a mere holder of a coaching authorization without a professional license within the meaning of Iowa Code 272.1(7) does not fall under the sexual exploitation statute. View "State v. Nicoletto" on Justia Law

Appellant was a registered sex offender who was not permitted to loiter within 300 feet of a public library. In 2012, Appellant was arrested for sitting on a park bench located across the street from the main entrance of a public library. Appellant was facing the library and had been sitting on the bench, which was seventy-two feet from the front door of the library, for approximately forty-five minutes. The district court subsequently convicted Defendant of loitering within 300 feet of a public library in violation of Iowa Stat. 692A.113(1)(g). On appeal, Appellant contended that there was insufficient evidence was “loitering” within the meaning of the statute. The Supreme Court reversed the conviction and remanded for new findings, conclusions, and judgment because it was unclear whether the district court applied the appropriate legal standard in this case. View "State v. Showens" on Justia Law

After a jury trial in 2007, Tammy Smith was convicted of child endangerment resulting in serious injury against her four-year-old son. The court of appeals affirmed on appeal. In 2009, Smith applied for postconviction relief based on evidence that her son communicated that his injury occurred when he placed his arm in the washing machine. The court of appeals held that this was newly discovered evidence and remanded for a new trial. On remand, the district court vacated Smith’s conviction and dismissed the case against Smith. In 2011, Smith filed a petition for wrongful imprisonment. The district court found that Smith did not establish by clear and convincing evidence neither she nor anyone else committed the crime of child endangerment. The court of appeals affirmed. The Supreme Court affirmed, holding that substantial evidence supported the district court’s finding that Smith did not establish her wrongful imprisonment action by clear and convincing evidence. View "Smith v. State" on Justia Law

After taking self-care leave under the Family and Medical Leave Act (FMLA), Plaintiff was terminated from her employment with the State. A jury found the State terminated Plaintiff in violation of her rights under the FMLA. The district court awarded Plaintiff money damages and ordered the State to reinstate Plaintiff to her former position. The State appealed and successfully requested a stay of Plaintiff’s reinstatement pending the outcome of the appeal. The Supreme Court subsequently held that sovereign immunity precluded Plaintiff’s judgment for money damages against the State. On remand, the district court once again ordered Plaintiff reinstated and awarded lost wages and benefits from the date of the original reinstatement order, concluding that the State had waived its sovereign immunity by seeking a stay of the reinstatement order and promising to pay Plaintiff’s interim wages and benefits if the Court affirmed the original order. The Supreme Court affirmed, holding (1) Plaintiff’s pleadings were sufficient to preserve her right to Ex parte Young remedies, and the parties litigated the reinstatement remedy by consent; and (2) the Eleventh Amendment to the U.S. Constitution does not bar an award of wages and benefits for the period during which a reinstatement order was stayed. View "Lee v. State" on Justia Law