Justia Iowa Supreme Court Opinion Summaries

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

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