Justia Iowa Supreme Court Opinion Summaries

An owner and contractor entered into an agreement for the construction of a new home. During construction, the owner refused to pay the contractor after discovering markups on the cost of materials. In response, the contractor halted construction and filed an action to enforce a mechanic's lien. The contractor subsequently filed a petition to foreclose the mechanic's lien. Although the contractor did not complete construction, the district court found the contractor rendered substantial performance under the contract and entered a judgment against the owner. The court of appeals affirmed. The Supreme Court affirmed in part and vacated in part the court of appeals and reversed the district court, holding that the trial court erred in concluding that the contractor had substantially completed work for the owner. Remanded. View "Flynn Builders, L.C. v. Lande" on Justia Law

Defendant, an alleged embezzler, entered an Alford plea to first-degree theft and entered a deferred judgment on that charge. The subrogated insurer (EMCC) of Defendant's employer brought a civil action against Defendant to recover $66,749 it paid on the theft loss. The district court entered summary judgment in favor of EMCC in that amount, concluding that Defendant's Alford plea precluded her from denying the theft or the amount. Defendant appealed, contending her deferred judgment should have no res judicata effect in the civil case. The Supreme Court affirmed the district court's summary judgment establishing Defendant's liability to EMCC for damages of $10,000 based on issue preclusion and reversed the summary judgment in excess of $10,000, holding (1) the victim of a crime or the victim's subrogated insurer may invoke the doctrine of issue preclusion in a civil action based on the defendant's Alford plea regardless of whether the defendant successfully complies with the conditions for the deferred judgment on the criminal charge; but (2) the preclusive effect of Defendant's Alford plea is limited to $10,000, the minimum amount required to support a charge of first-degree theft, and genuine issues of material fact precluded summary judgment in excess of $10,000. View "Employers Mut. Cas. Co. v. Haaften" on Justia Law

This case presented the question of whether an individual who made voluntary expenditures based on a mother's fraudulent representation that the individual had fathered her child has a cause of action against the mother for recovery of those payments. The district court granted the mother's motion to dismiss the action. The Supreme Court reversed the district court, holding that such a cause of action may be pursued because it is consistent with traditional concepts of common law fraud, there is no prevailing public policy reason against recognizing such a cause of action, and Iowa's statutes do not speak to the issue. Remanded. View "Dier v. Peters" on Justia Law

At issue in this case was whether a subcontractor that properly performs electrical work on a jobsite, then locks up the work and transfers control to the property owner, owes a duty of care to an employee of the owner electrocuted six days later when the owner fails to deenergize the work site in contravention of various warnings and regulations. The district court granted summary judgment to the subcontractor, holding that the subcontractor owed no duty to the employee because it did not have control of the switchgear box when the employee was injured. The court of appeals reversed. The Supreme Court vacated the court of appeals and affirmed the district court, holding that, under the circumstances, the subcontractor owed no duty of care to the employee. View "McCormick v. Nikkel & Assocs." on Justia Law

At issue in this employment case was whether the State was immune from claims under the self-care provision of the Family and Medical Leave Act (FMLA) in state court. The district court denied the State's posttrial motions for a judgment notwithstanding the verdict or a new trial asserting Eleventh Amendment sovereign immunity after a jury awarded damages to a state employee based on a claim for violating the FMLA. The court of appeals affirmed. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the trial court, holding (1) the cloak of immunity granted to the State precludes state employees from suing the State for monetary relief when denied self-care leave under the FMLA; (2) nevertheless, states are bound to follow the self-care provisions of the FMLA, and state employees who are wrongfully denied self-care leave are still permitted to seek injunctive relief against the responsible state official; and (3) the U.S. Department of Labor may bring actions for damages or an injunction on behalf of an employee against a state for violating the self-care provisions. Remanded. View "Lee v. State" on Justia Law

In this interlocutory appeal, the Supreme Court reviewed the district court's ruling consolidating condemnation appeals from proceedings by two separate condemning authorities taking property from the same parent tract of farmland. The takings were four months apart for unrelated projects. The district court consolidated the landowner's appeals, finding common question of law or fact and a lack of prejudice. The Supreme Court reversed, holding that consolidation was an abuse of discretion, as (1) fact finders must determine just compensation for different types of takings by separate condemning authorities four months apart for unrelated projects; and (2) certain evidence in each case would be inadmissible in the other, thus creating a substantial risk of prejudice and jury confusion. Remanded for separate trials. View "Johnson v. Metro. Wastewater Reclamation Auth." on Justia Law

This case presented the question of whether an officer is justified in activating his emergency lights and blocking a driver into a parking space under the "community caretaking function" exception to the warrant requirement of the Fourth Amendment based solely upon his knowledge that the vehicle has just struck an object in the roadway and suffered minor damage not affecting the drivability of the car. Here the district court denied Defendant driver's motion to suppress the evidence found after the warrantless seizure of Defendant's car, and Defendant was found guilty of OWI. The Supreme Court reversed the district court, concluding that under the circumstances of this case, the community caretaking exception was inapplicable, and the seizure was impermissible. Remanded. View "State v. Kurth" on Justia Law

In this case the Supreme Court considered whether an area education agency (AEA) acted lawfully when it approved for submission to the voters a petition that proposed a consolidation of two community school districts, Preston and East Central. East Central sought to block the measure from being placed before the voters, asserting (1) the AEA approval of the petition for submission to the voters was legally flawed because the AEA failed to comply with a statutory requirement that it develop a plan for the AEA district, and (2) the AEA failed to make a required statutory finding that the consolidation proposed in the petition was in conformity with the plan. The district court rejected the claims. The Supreme Court affirmed, concluding that the AEA acted lawfully in approving submission of the petition to the voters, as (1) the AEA was not required to develop a specific plan of merger between the two school districts prior to approval of submission of a citizen petition to the voters of the districts; and (2) by approving the submission of the issue to the voters, the AEA made an implied finding that all the statutory requisites were met. View "E. Central Cmty. Sch. Dist. v. Miss. Bend Area Educ. Agency" on Justia Law

At issue here was sex offenders serving prison time on a "revocation of release" from a "special sentence" under Iowa Code 903B.2 and whether the maximum time incarcerated was reduced by "earned-time credit" or "jail-time credit." Kris Kolzow began serving his ten-year special sentence released on parole. A parole violation prompted his detention for five and one-half months awaiting a parole-revocation hearing. The administrative parole judge ordered Kolzow to prison "to serve a period not greater than two years" as required by section 903B.2. The Iowa Department of Corrections (IDOC) refused to shorten Kolzow's prison time with earned-time credit or jail-time credit. The district court ruled that both credits applied to reduce the maximum two-year period served in prison on the revocation of release. The Supreme Court affirmed the ruling awarding Kolzow jail-time credit and reversed the ruling awarding him earned-time credit, holding (1) IDOC need not apply earned-time credit to shorten the period incarcerated on a revocation of release; and (2) an offender serving a special sentence under section 903B.2 is entitled to jail-time credit against the maximum periods for revocation of release for each day he is detained awaiting his parole-revocation hearing. View "Kolzow v. State" on Justia Law

Roger Ennenga was arrested for failing to stop his vehicle when police attempted to pull him over and for possession of methamphetamine. The State failed to file a trial information within forty-five days, and Ennenga's counsel did not file a motion to dismiss. Thereafter, Ennenga's counsel allowed him to plead guilty. At issue before the Supreme Court on Ennenga's application for postconviction relief was whether an indictment must be filed in order to be "found" for the purposes of Iowa R. Crim. P. 2.33, which requires the court to dismiss a prosecution if an indictment or trial information is not "found" within forty-five days of the defendant's arrest, and whether failing to ensure an indictment is timely filed amounts to the breach of an essential duty by an accused's counsel. The Court reversed the district court, holding that counsel breached an essential duty in failing to file a motion to dismiss the untimely trial information, and that counsel's failure resulted in prejudice to Ennenga by his plea of guilty. Remanded. View "Ennenga v. State" on Justia Law