Justia Iowa Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of kidnapping in the first degree, among other charges. Defendant was a juvenile at the time of the kidnapping. The district court sentenced Defendant to life imprisonment without the possibility of parole for the kidnapping conviction. After the U.S. Supreme Court decided Graham v. Florida, Defendant filed a motion to correct an illegal sentence on the kidnapping conviction, contending that his sentence violated the Eighth Amendment of the U.S. Constitution. The district court agreed that the sentence was unconstitutional and corrected Defendant’s conviction to life in prison with immediate parole eligibility. Defendant appealed, claiming, inter alia, that his sentence was unconstitutional under both the U.S. and the Iowa Constitutions. The court of appeals affirmed Defendant’s conviction and sentence as corrected. The Supreme Court conditionally affirmed, holding that Defendant’s sentence was constitutional under the U.S. Constitution. Because Defendant’s claims that his sentence was illegal under the Iowa Constitution were not fully developed, the Court did not reach those claims. Remanded. View "State v. Hoeck" on Justia Law

Plaintiffs, Klever Miranda and Nancy Campoverde, entered the U.S. without documentation. Klever received a notice of removal order and was represented by attorney Michael Said. Said advised Klever and Nancy to leave the country and then file a document called a Form I-601 waiver, which permits an applicant who is otherwise ineligible to be admitted into the U.S. based on extreme hardship to a qualifying relative. Said told Plaintiffs that once their son Cesar obtained citizenship, he would be a qualifying relative. However, once Plaintiffs left the country and filed the Form I-601, the applications were denied. Plaintiffs later learned that Cesar was not a qualifying relative. Plaintiffs and Cesar brought a legal malpractice action against Said, including a claim for emotional distress damages and punitive damages. The district court allowed only the claim for economic damages to be considered by the jury and found Said negligent. The court of appeals reversed, finding the claims for emotional distress and punitive damages should have been submitted to the jury. The Supreme Court affirmed, holding that the district court erred in concluding that emotional distress and punitive damages were not available to Plaintiffs. Remanded for a new trial.View "Miranda v. Said" on Justia Law

The Iowa Commission on Judicial Qualifications recommended that a magistrate, who had a private practice in addition to his work on the bench, be publicly reprimanded for placing advertisements in phone books featuring his photograph in his judicial robes. The Supreme Court granted the application of the commission, finding that the magistrate violated the provisions of the Iowa Code of Judicial Conduct by attempting to influence potential clients to use his services as an attorney by using his office as an indicator of his trustworthy and responsible nature. The Court then concluded that a public reprimand was the appropriate sanction.View "In re Meldrum" on Justia Law

Plaintiff’s truck was stopped at a red light when it was struck by Defendant’s car. Defendant saw the red light but claimed she didn’t see Plaintiff’s car. Later testing confirmed that Defendant had suffered a stroke that caused a partial loss of vision. During a jury trial, the district court allowed Defendant’s treating neurologist to testify that the stroke preceded the accident and submitted the defense of sudden emergency. The jury found Defendant was not negligent. The court of appeals reversed and remanded for a new trial, concluding (1) the evidence supported a defense of legal excuse, but (2) the trial court erred in instructing the jury on sudden emergency. The Supreme Court vacated the decision of the court of appeals and affirmed the district court’s judgment, holding (1) the district court did not abuse its discretion in allowing Defendant’s medical expert to testify; (2) the evidence was sufficient to submit a legal excuse defense based on Defendant’s sudden medical emergency; and (3) any error in the wording of the sudden emergency instruction was harmless. View "Hagenow v. Schmidt" on Justia Law

Dentist fired his long-time female dental assistant (Employee) at the request of his wife after she discovered Dentist and Employee had been texting. Wife claimed Employee "was a big threat" to the marriage. Employee subsequently brought this action against Dentist, alleging that he discriminated against her on the basis of sex. The district court granted summary judgment for Dentist, concluding that Employee was not fired because of her gender but because she was a threat to Dentist's marriage. The Supreme Court affirmed, holding that Dentist did not engage in unlawful gender discrimination in violation of the Iowa Civil Rights Act when he fired Employee at the request of his wife.View "Nelson v. Knight" on Justia Law

The Iowa Department of Transportation (IDOT) hired a general contractor, which was a “targeted small business” (TSB), for two public construction contracts. The general contractor subcontracted with three subcontractors, which the general contractor failed to pay in full. The subcontractors sued IDOT and the general contractor. The district court granted IDOT’s motion to dismiss and entered default judgments against the general contractor, ruling that, in absence of a bond, the subcontractors’ remedy against the state was limited to the funds IDOT retained on its contract with the general contractor. The subcontractors appealed, arguing that Iowa Code 573.2, the statute that governs subcontractors’ remedies for unpaid work on public improvements when the state waives the performance bond for a general contractor that is a TSB, allowed broader recovery rights and required IDOT to step into the TSB’s shoes to pay the balances owed them. The Supreme Court reversed, holding that section 573.2 operates as a waiver of sovereign immunity that allows subcontractors to recover from IDOT the unpaid balances TSBs owe for work on public improvements. Remanded. View "Star Equip., Ltd. v. State" on Justia Law

Defendant pleaded guilty to attempted murder and was sentenced to twenty-five years in prison. Defendant appealed, claiming his counsel provided ineffective assistance because counsel permitted him to plead guilty without an established factual basis for each element of the crime. The court of appeals vacated Defendant's conviction and sentence and remanded the case, concluding that the guilty plea colloquy failed to establish a factual basis for the underlying charge. The Supreme Court vacated the court of appeals' decision and affirmed the conviction and sentence of the district court, holding that the minutes of testimony provided an adequate factual basis to support Defendant's guilty plea. View "State v. Finney" on Justia Law

The Attorney General brought an action against Corporation, which sold memberships in buying programs giving members the option to purchase various goods and services at discounted rates, alleging violations of the Buying Club Membership Law (BCL) and the Iowa Consumer Fraud Act (CFA) and seeking civil penalties for consumer frauds committed against the elderly. The district court concluded (1) many of Corporation's marketing and sales practices violated the BCL and CFA; (2) Corporation did not commit consumer frauds against the elderly; and (3) application of the BCL to Corporation's solicitation practices did not violate the dormant Commerce Clause. The court awarded more than $25 million in consumer reimbursement, civil penalties, and attorney fees. The Supreme Court affirmed in part, reversed in part, and modified, holding (1) Corporation's telemarketing and Internet practices violated the CFA; (2) Corporation's solicitations and its memberships offering one or more discount features were subject to the terms of the BCL; (3) application of the BCL to Corporation's solicitations did not violate the dormant Commerce Clause; (4) affirmed the reimbursement award for BCL violations as modified; and (5) reversed the ruling that the State was not entitled to civil penalties for consumer frauds committed by the elderly.View "State ex rel. Miller v. Vertrue, Inc." on Justia Law

Plaintiff was a construction supply business that entered into a dispute with City over a project upgrading City's wastewater treatment facility. After City excluded Plaintiff from its list of preapproved material suppliers, Plaintiff filed this action seeking a declaration that City's preapproval process violated Iowa's public construction bidding statute and constitutional guarantees of equal protection and due process. In addition, Plaintiff sought relief under the Open Records Act, claiming that City's significant delay in responding to Plaintiff's open records request violated the Open Records Act. The district court rejected each of Plaintiff's claims. The Supreme Court (1) affirmed the judgment dismissing Plaintiff's public biding and constitutional claims, as (i) Plaintiff lacked standing to challenge City's preapproval process, and (ii) Plaintiff's constitutional claims failed on the merits; and (2) reversed the district court's ruling denying Plaintiff relief under the open records law, as City's substantial and inadequately explained delay in responding to Plaintiff's open records request violated the law. View "Horsfield Materials, Inc. v. City of Dyersville" on Justia Law

Melissa and Scott Mihm entered into a stipulation and agreement for dissolution of their marriage. The stipulation included an agreement to a child support amount below what was provided by the child support guidelines (the guidelines). The district court incorporated the stipulation into its decree of dissolution. Scott later filed a motion to modify the divorce decree, and Melissa counterclaimed seeking an increase in child support. The district court concluded (1) there had been no substantial change in circumstances justifying a modification of Scott’s child support obligation, and (2) the agreement, which was made by the parties with full knowledge that the child support was not based upon the guidelines, should not be modified unless “for the direst of needs.” The Supreme Court reversed and remanded on the issue of child support, holding (1) the original child support order did not provide a proper basis on which to base a decision on modification of child support because it was not consistent with law or rules governing child support; and (2) Melissa showed there had been a substantial change in circumstances since the entry of the underlying decree, warranting a child support modification. View "In re Marriage of Mihm" on Justia Law