Justia Iowa Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of the second-degree murder of his live-in girlfriend. The Supreme Court affirmed, holding that the district court did not reversibly err by (1) failing to submit an instruction on the lesser included offense of voluntary manslaughter, as the evidence of provocation was insufficient to support admission; (2) excluding hearsay evidence relevant to Defendant's diminished-capacity defense based on his posttraumatic stress disorder, as Defendant failed to lay a foundation supporting any exception to the hearsay rule; (3) declining to obtain and review the victim's mental health records for exculpatory information; and (4) denying Defendant's motion for a new trial. View "State v. Thompson" on Justia Law

After Appellant drove her car off the road and destroyed a mailbox, Appellant gave a urine sample that tested positive for controlled substances. Based on the test results, the Iowa Department of Transportation revoked Appellant’s license for 180 days. Appellant contested her revocation, asserting that the prescription-drug defense under Iowa Code 321J.2(11) applied in her case. An administrative law judge denied the appeal, finding that the evidence in this case established the elements of the statutory prescription-drug defense but that the prescription-drug defense did not apply in administrative license revocation proceedings. The district court affirmed. The Supreme Court reversed, holding that the prescription-drug defense is available in license revocation proceedings. View "Bearinger v. Iowa Dep’t of Transp." on Justia Law

Following a jury trial, Defendant, a juvenile, was convicted of first-degree murder and mandatorily sentenced to life without parole. Defendant subsequently pursued numerous postconviction relief actions, including an application to correct his sentence. After the Supreme Court remanded the case to the district court to consider the constitutionality of Defendant's sentence, the U.S. Supreme Court decided Miller v. Alabama, which held that the constitution prohibited a sentencing scheme mandating life in prison without possibility of parole for juvenile offenders. Before Defendant's hearing, the Governor commuted Defendant's sentence to life with no possibility for parole for sixty years. At the hearing before the district court, Defendant argued he should still be resentenced under Miller. The district court (1) concluded that the Governor exceeded his authority by commuting Defendant's sentence because the commutation circumvented the individualized sentencing required under Miller, and (2) resentenced Defendant to life in prison with the possibility of parole after twenty-five years. The Supreme Court affirmed, holding (1) Defendant's commuted sentence still amounted to cruel and unusual punishment; and (2) consequently, the district court properly resentenced Defendant in light of Miller.View "State v. Ragland" on Justia Law

After a jury trial, seventeen-year-old Defendant was convicted of two counts of first-degree robbery and two counts of first-degree burglary. The district court imposed a fifty-year sentence, of which Defendant was required to serve thirty-five years, at which point she would become eligible for parole. The Supreme Court vacated Defendant's sentence, holding (1) Defendant's sentence of a minimum of thirty-five years without the possibility of parole for the crimes involved in this case violated the core teachings of Miller v. Alabama; and (2) an individualized sentencing hearing was required in this case. Remanded. View "State v. Pearson" on Justia Law

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