Justia Iowa Supreme Court Opinion Summaries

Pursuant to a plea agreement, Defendant pleaded guilty to second-degree murder and first-degree robbery. Defendant was sixteen years old at the time he committed the offenses. The district court imposed a seventy-five-year aggregate sentence, of which Defendant was required to serve 52.5 years. Defendant's alleged actions took place before the Supreme Court's decision in Miller v. Alabama. On appeal, the Supreme Court affirmed Defendant's convictions but vacated his sentence, holding (1) Defendant's 52.5-year minimum prison term triggered the protections to be afforded under Miller - namely, an individualized sentencing hearing to determine the issue of parole eligibility; and (2) a district court must recognize and apply the core teachings of Roper v. Simmons, Graham v. Florida, and Miller in making sentencing decisions for long prison terms involving juveniles. Remanded.View "State v. Null" on Justia Law

In 2009, Scott Schulte and Marisel Del Valle (together, Appellants) executed a promissory note and, as security for the note, a mortgage on real property. The note and mortgage were later assigned to BAC Home Loans Servicing. In 2010, BAC filed a foreclosure petition alleging Appellants were in default, and the district court entered a decree of foreclosure. In 2012, Bank of America, as successor by merger to BAC, filed a notice of rescission of foreclosure and, contemporaneously, filed a motion to set aside decree. Appellants opposed the motion to set aside decree, arguing that neither the motion nor the notices of rescission were timely filed within one year of the entry of judgment as required by Iowa R. Civ. P. 1.1012 and 1.1013 and were therefore time barred. The district court found the rescission notices timely filed, concluding that a two-year limitations period applied under Iowa Code 654.17, and accordingly, granted Bank of America’s motion to set aside the decree. The Supreme Court affirmed, holding that the district court did not err when it confirmed that the rescission action was timely filed and granted the motion to set aside decree. View "Bank of Am., N.A. v. Schulte" on Justia Law

In 2005, James House began working as a commercial truck driver for Mike Brooks, Inc. In 2007, House slipped and fell in any icy parking lot while retrieving cargo and injured his back. House returned to work but experienced regular back pain after doing so. In 2008, House pushed open a heavy door and experienced an increase in pain and a burning sensation in the area of his 2007 back injury. House filed a petition for workers’ compensation benefits. A deputy commissioner found House had sustained a permanent total disability (PTD) and rejected Brooks’ contention that the 2008 incident resulted in an injury distinct from the 2007 injury. The commissioner affirmed the award of PTD benefits, including the finding that House’s injury and resulting PTD were caused by the 2007 incident. The district court affirmed. The court of appeals reversed, concluding that the commissioner’s finding of causation was not supported by substantial evidence. The Supreme Court vacated the court of appeals and affirmed the district court’s decision, holding that substantial evidence supported the causation finding made by the commissioner. View "Mike Brooks, Inc. v. House" on Justia Law

Travis and Alfronia Sisson divorced in 2008. The next year, Alfornia was diagnosed with an incurable blood cancer. In 2011, Travis filed an action to modify the divorce decree, and Alfronia responded with her own claim for modification. The district court (1) denied Travis’s request to modify the custody arrangement; (2) modified alimony by increasing the monthly amount, retroactive to the date Alfronia filed her application to modify; (3) extended the spousal support payments for the remainder of Alfronia’s life; and (4) ordered Travis to pay one-half of the medical expenses incurred by Alfronia not covered by her insurance plan. The Supreme Court affirmed as modified, holding that Alfronia established a change in circumstances to support a modification of spousal support. View "In re Marriage of Sisson" on Justia Law

As a condition of her employment, Employee signed an agreement to arbitrate claims with Employer. Employee later filed a complaint with the Iowa Civil Rights Commission (ICRC), alleging that Employer had discriminated against her because of her pregnancy. The ICRC subsequently filed a statement of charges with the Iowa Department of Inspections and Appeals (DIA). Employer filed a motion to dismiss the ICRC’s charges or, in the alternative, compel arbitration. The DIA denied Employer’s motion on the ground that ICRC was not a party to the arbitration agreement and, consequently, not bound by it. On judicial review, the district court remanded instructions for the ICRC to dismiss the matter pending arbitration by the parties, concluding that the Federal Arbitration Act (FAA) preempted state law. The Supreme Court reversed, holding the FAA did not require arbitration of this proceeding because it was brought by an entity that was not bound to arbitrate under generally applicable principles of contract law, where the ICRC was not a party to the agreement and its interest was not derivative of Employee’s. View "Rent-A-Center, Inc. v. Iowa Civil Rights Comm’n" on Justia Law

Plaintiff, an employee of BNSF Railway Company, was injured due to the railroad’s negligence. Because of his injury, Plaintiff was no longer able to work at his job. Plaintiff, who was almost fifty-nine years old, sued BNSF under the Federal Employers’ Liability Act (FELA) seeking $755,000 in economic damages, claiming that he planned to work until he was sixty-six years old. BNSF, in turn, attempted to introduce evidence that Plaintiff was eligible to retire on full benefits at age sixty and that most railroad employees in Plaintiff’s position retire at age sixty. The district court excluded the railroad’s evidence based on its reading of the federal collateral source rule applicable to FELA cases. A jury subsequently awarded $1.25 million, including pain and suffering, to Plaintiff. The Supreme Court reversed and remanded for a new trial on damages, holding (1) when a railroad employee makes a claim of lost earning capacity based on a hypothetical retirement age, federal law does not bar the introduction of evidence as to when railroad employees in the plaintiff’s position typically retire; and (2) BNSF was improperly precluded from presenting this excluded statistical evidence, and the error was not harmless. View "Giza v. BNSF Ry. Co." on Justia Law

After Plaintiff, an at-will employee, reported a forgery on the part of supervisors at an assisted living facility, the facility terminated Plaintiff's employment. The Department of Inspections and Appeals later concluded that certain state-mandated documents relating to the facility's dementia training program had been forged. Plaintiff subsequently filed an action against the facility for wrongful discharge. The jury returned a verdict for Plaintiff, finding the facility terminated her in retaliation for whistleblowing and a willful and wanton disregard for the rights or safety of others. The jury also awarded punitive damages. The court of appeals (1) affirmed the court's finding that the public-policy exception to the at-will employment doctrine protected Plaintiff's employment from retaliatory termination, but (2) reversed the court's decision to submit the issue of punitive damages to the jury. The Supreme Court affirmed, holding (1) an employer's retaliatory discharge of Plaintiff violated public policy; and (2) the district court should not have submitted the punitive damages claim to the jury because at the time of Plaintiff's discharge, the Court did not recognize a public-policy exception to the at-will employment doctrine based upon a violation of administrative rules.View "Dorshkind v. Oak Park Place of Dubuque II, LLC" on Justia Law

Mother and Father were the parents of A.M. Following A.M.’s birth, the hospital staff expressed concerns about the couple’s ability to care for A.M. due to Mother’s lack of interest in feeding the baby and Father’s “ability to safely hold and care for the baby." Two days after A.M.’s birth, the juvenile court granted the State’s request for the temporary removal of A.M. from Mother and Father’s custody. The juvenile court adjudicated A.M. a child in need of assistance, and the Department of Human Services developed a case permanency plan with the goal for A.M. to be returned to Mother’s home. The State later filed a petition for the termination of Mother’s and Father’s parental rights to A.M. After a trial, the juvenile court terminated parental rights to A.M. The Supreme Court affirmed the juvenile court’s order after noting that this “was a difficult case,” holding that termination was in A.M.’s best interests. View "In re A.M." on Justia Law

Appellants owned residential real estate in West Des Moines. In 2011, the Dallas County Board of Review established an assessment value of Appellants’ property for tax purposes. In 2012, the Board established a new, greater value for the property. Appellants filed a petition with the Board protesting the assessment. The petition stated that the protest was lodged against the 2011 property valuation. At a hearing before the Board, Appellants stated that they wished to protest the valuations for both 2011 and 2012. The Board denied Appellants’ protest, concluding that it lacked subject matter jurisdiction because the 2011 protest was untimely. The district court affirmed. The Supreme Court reversed, holding (1) Appellants’ petition was sufficient to invoke the jurisdiction of the Board and bring Appellants’ protest within the Board’s authority to review; and (2) the Board had the authority to entertain a request for amendment of Appellants’ petition and relate it back to the original filing. Remanded. View "Allen v. Dallas County Bd. of Review" on Justia Law

In 2002, David Buchwald pleaded guilty to a single count of lascivious acts with a child. Upon his release from prison in 2004, Buchwald was required to register as a sex offender for ten years. In 2011, Buchwald petitioned for modification of this requirement. After determining that Buchwald met the requirements of the statutory registration modification provision, the district court granted modification and reduced the duration of Buchwald’s registration obligation to five years. Because five years had elapsed before Buchwald petitioned for modification, the district court ordered Buchwald removed from the registry. The State filed a petition for writ of certiorari, arguing that the district court erred in determining that Buchwald was eligible for modification under the provision. The Supreme Court granted the petition and transferred the case to the court of appeals. Upon further review, the Supreme Court annulled the writ, holding that the district court’s modification and removal order was legal under the statutory provision. View "State v. Iowa Dist. Court for Story County" on Justia Law