Justia Iowa Supreme Court Opinion Summaries

Defendant Dontay Sanford was convicted for first-degree burglary for entering the car of a victim who later died from injuries received during the encounter. Sanford was sentenced to an indeterminate term in prison not to exceed twenty-five years. Sanford appealed, claiming there was insufficient evidence that the victim's automobile was an "occupied structure," which is one of the elements of burglary. The Supreme Court affirmed the conviction, holding (1) the State produced sufficient evidence that the victim's vehicle, under the facts of this case, was an occupied structure as that term is defined under the burglary statute; and (2) Sanford's pro se claims on appeal failed. View "State v. Sanford" on Justia Law

This case presented a battle between banks over the proceeds of the sale of cattle by a financially strapped borrower who had financial dealings with both banks. When Security Savings Bank (Security) obtained the proceeds of the sale, Peoples Trust and Savings Bank (Peoples) claimed a security interest in the proceeds and sued for conversion. The district court granted summary judgment in favor of Peoples. After Security appealed, Peoples commenced garnishment proceedings against Security to enforce its judgment, and Security paid the underlying judgment. The court of appeals then determined that Security had waived its right to appeal and dismissed the case. The Supreme Court affirmed, holding (1) a defendant faced with post-judgment garnishment does not waive a pending appeal by paying the judgment in order to avoid further enforcement proceedings; and (2) the district court correctly determined that Peoples had a security interest in the proceeds superior to Security's interest and that Peoples did not waive its superior position through its course of conduct. View "Peoples Trust & Savings Bank v. Sec. Savings Bank" on Justia Law

The Iowa Commission on Judicial Qualifications filed an application for imposition of discipline against Daniel Block, an associate juvenile court judge, for conduct that resulted in his arrest for the crime of operating while intoxicated, first offense. The Commission found Block violated the Iowa Code of Judicial Conduct and recommended he be publicly reprimanded. The Supreme Court granted the application, concluding (2) the conduct of the judge amounted to a substantial violation of the Code of Judicial Conduct; (2) the impact of the conduct as a whole was enough to adversely impact the public confidence in the judiciary; and (3) the appropriate discipline for the unethical conduct in this matter was a reprimand. View "In re Block" on Justia Law

A juvenile court terminated Father's parental rights to his two children. Father appealed, arguing, among other things, that the juvenile court violated his due process rights when it ordered him to provide a fingernail drug test after his termination trial. The court of appeals reversed, principally on the basis that there was no evidence in the record as to the reliability or the accuracy of the fingernail drug test, and that the record, including the fingernail test, lacked clear and convincing evidence to warrant termination of Father's parental rights. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment and order of the trial court, holding (1) the test did not violate Father's due process rights; (2) the evidence including the fingernail test was sufficient to warrant termination; and (3) termination was in the children's best interests. View "In re A.B." on Justia Law

In this real estate dispute, some of the defendants filed a motion for sanctions, alleging Defendant brought the action to harass, cause unnecessary delay, and needlessly increase the cost of litigation. The district court ordered sanctions against Plaintiff's counsel for $1,000. The court of appeals affirmed the sanctions, ordering them payable to the jury and witness fund. The Supreme Court affirmed in part and vacated in part the court of appeals, holding (1) the district court did not abuse its discretion in fixing the amount of the sanction at $1,000; (2) the court abused its discretion by ordering the sanction be paid to the jury and witness fund; and (3) given Rule 1.413(1)'s preference of compensating victims, the district court should enter an order requiring Plaintiff's counsel to pay the sanction in equal sums to the defendants who sought the sanction as partial reimbursement of the legal fees they incurred in defending against the unfounded claims brought against them. Remanded. View "Rowedder v. Anderson" on Justia Law

After the State filed a child in need of assistance (CINA) petition, the juvenile court issued a temporary removal order removing Child from Mother's custody and placing her in foster care. Once the CINA proceeding was dismissed, Mother sued the State and two employees of the Iowa Department of Human Services (DHS) under 42 U.S.C. 1983 and the Iowa Tort Claims Act (ITCA), alleging the DHS social workers wrongfully removed Child from her custody and negligently failed to protect Child from abuse. The district court granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding (1) a social worker is entitled to absolute immunity when the social worker functions in the role of a prosecutor or ordinary witness; (2) a social worker is entitled to qualified immunity when acting in the role of a complaining witness, and for his or her investigatory acts; (3) alleged injured parties cannot maintain an action against a social worker under the ITCA where the alleged parties fail to exhaust the available administrative remedy prior to filing an action in court and where the basis of the complaint is that the social worker engaged in conduct functionally equivalent to misrepresentation or deceit. View "Minor v. State" on Justia Law

Peter Long was convicted of third-degree sexual abuse. Based on two prior convictions for lascivious acts with a child, the district court found that Long had committed a class A felony and sentenced Long to life in prison without the possibility of parole. Long appealed, claiming the district court abused its discretion when it allowed the State to reopen the record after the State had rested and after the defense had made a motion for judgment of acquittal during the enhancement trial. The court of appeals vacated the judgment and remanded the case to the district court to render a verdict on the enhancement based solely on the evidence introduced prior to the reopening of the record. The Supreme Court vacated the court of appeals and affirmed the district court, holding that the district court did not abuse its discretion in reopening the record under the circumstances of this case. View "State v. Long" on Justia Law

Donald Clark was convicted of sexual abuse in the second degree for molesting a fifth-grade student while employed as a guidance counselor at the elementary school. Clark appealed, arguing that his constitutional rights to a fair trial and due process were violated when the trial court failed to grant his request for a continuance and to allow the retaking of depositions based on the late disclosure of an e-mail written by the student. The Supreme Court affirmed Clark's conviction and sentence, holding that the district court did not violate Clark's constitutional rights or abuse its discretion when it refused to allow redepositions or grant a continuance. View "State v. Clark" on Justia Law

Sergio Perez pled guilty to a misdemeanor drug possession charge in 2000. Perez later filed an application for postconviction relief seeking to have his conviction set aside, claiming that he did not receive advice from his attorney regarding the risk of deportation before pleading guilty. The district court denied the application, and the court of appeals affirmed. At the center of this appeal was the U.S. Supreme Court's decision in Padilla v. Kentucky, which decided a criminal defendant has a right to receive advice from counsel regarding the risk of deportation before pleading guilty. The Supreme Court affirmed, holding (1) if Padilla establishes a new rule of constitutional criminal procedure, it does not apply retroactively, and Perez may not rely upon it to set aside an earlier conviction; and (2) if Padilla is not a new rule, Perez's application is time-barred because he could have filed it within three years of the date when his conviction became final and failed to do so. View "Perez v. State" on Justia Law

NextEra Energy Resources, LLC appealed the Iowa Utility Board's decision to grant advance ratemaking principles to MidAmerican Energy Company for a proposed wind generation facility. The district court affirmed the Board. The Supreme Court affirmed, holding (1) the Board properly interpreted and applied Iowa Code 476.53; (2) substantial evidence supported the Board's findings; (3) Iowa Code 476.43 was not applicable to this ratemaking proceeding; and (4) section 476.53 as applied to a rate-regulated public utility that may compete in the wholesale energy market did not violate the Equal Protection clauses of the Iowa or U.S. Constitutions or the Commerce Clause of the U.S. Constitution. View "Nextera Energy Res., LLC v. Iowa Utils. Bd." on Justia Law