Justia Iowa Supreme Court Opinion Summaries

This case was heard by the Supreme Court of Iowa and involved an appeal by a defendant, Demetrias Martin, who was challenging the mandatory minimum term imposed with his sentence for first-degree robbery. The main issue in the case was the use of a risk assessment tool that categorized Martin as a "high" risk for violent recidivism and a "moderate/high" risk for continuous victimization. Martin argued that the district court abused its discretion by relying on these conclusions without any information about how the tool actually arrived at them.In March 2019, Martin was sentenced to twenty-five years in prison with a requirement to serve at least 70% of his sentence under a statutory mandatory minimum. After a retroactive amendment to the robbery sentencing statute in June 2019, Martin was eligible for resentencing with a potential mandatory minimum as low as 50%. The amendment required the district court to consider certain factors when determining the mandatory minimum to impose, including a validated risk assessment.The Supreme Court of Iowa affirmed the decision of the lower courts, holding that the district court did not abuse its discretion in considering the results of the risk assessment tool. The court found that Martin had notice of the risk assessment and had the opportunity to challenge it but failed to do so. The court held that a district court does not abuse its discretion by considering risk assessment information in a presentence investigation report where a defendant has notice of the risk assessment and fails to present evidence exposing some actual unsoundness in it. Therefore, the court rejected Martin's argument and affirmed the sentence imposed by the lower court. View "State of Iowa v. Martin" on Justia Law

In this case, the Supreme Court of Iowa addressed whether the district court erred in ordering the placement of a sexually violent predator in a transitional release program over the State’s objection. The State argued that the offender was ineligible for that program without a relapse prevention plan (RPP) accepted by his treatment provider at the Civil Commitment Unit for Sexual Offenders (CCUSO) as required by Iowa Code section 229A.8A(2)(d) (2022). The district court determined that the offender’s plan, approved by the offender’s expert, satisfied that statutory requirement. The State appealed, asserting that the court erred by substituting its judgment for that of CCUSO’s staff.The Supreme Court of Iowa held that a writ of certiorari is the proper form of appellate review, and granted the petition. On the merits, the court held that the district court erred by substituting its judgment for that of CCUSO’s staff. The court agreed with the State that the offender was ineligible for placement in the transitional release program because his treatment provider at CCUSO had not accepted his proposed RPP. The court also rejected the offender's substantive due process claims. Consequently, the court sustained the writ and vacated the district court’s ruling. View "In Re Detention of Schuman" on Justia Law

In the Supreme Court of Iowa, the case involved a dispute between divorced parents who held joint legal custody of their children. The parents disagreed on whether their children should receive the COVID-19 vaccine. The mother filed an application for vaccination determination after unsuccessful mediation, seeking the district court's authorization to vaccinate the children. The district court dismissed the case, concluding it lacked the authority to act. The court of appeals reversed the decision, instructing the district court to hear the mother's application on the merits.Upon review, the Supreme Court of Iowa vacated the decision of the court of appeals and affirmed the district court's dismissal of the case. The Supreme Court held that the language of Iowa Code section 598.1(3) provides parents with equal participation in decisions affecting their children's medical care. The court found that the mother's application for vaccination determination attempted to circumvent the dissolution decree that gave the parents joint legal custody. Without a request for a modification of the custody agreement, the district court did not have the authority to resolve the parents' dispute. Therefore, the court concluded that the district court did not have the authority to resolve the parties' conflict over vaccinating their children against COVID-19. View "In re Marriage of Frazier" on Justia Law

In a workers' compensation case, an employee was injured and sought compensation from her employer and its insurance carrier. The employee failed to provide her expert witness's evidence in a timely manner, serving them only two weeks before the arbitration hearing began. The employer and its insurance carrier objected, arguing that this late submission of evidence was unfairly prejudicial. The deputy workers’ compensation commissioner agreed with the employer and excluded the evidence. This decision was affirmed by the commissioner, but was later reversed on judicial review by the district court. The court of appeals affirmed the district court’s ruling. However, the Supreme Court of Iowa held that the commissioner’s decision to exclude untimely evidence was entitled to deference. The court found that the commissioner did not abuse his discretion by excluding the untimely evidence since the employee had disregarded multiple deadlines and submitted the reports only about two weeks before the hearing. Moreover, the reports were not from the employee’s treating physicians and the vocational report reached a conclusion that no other expert in the case shared. Therefore, the supreme court vacated the court of appeals decision, reversed the district court decision, and remanded the case back to the district court to enter a judgment affirming the commissioner's decision to exclude the untimely evidence. View "Hagen v. Serta/National Bedding Co., LLC" on Justia Law

The Supreme Court of Iowa ruled that the State University of Iowa, Iowa State University of Science and Technology, and the University of Northern Iowa were required to be members of the Iowa Individual Health Benefit Reinsurance Association (IIHBRA) and therefore had to pay assessments to the association. The universities had argued that they were not members of IIHBRA and that the statute requiring them to pay assessments violated the Iowa Constitution, which prohibits the state from acting as a surety for another. The court rejected these arguments, finding that the statutory scheme did not violate the constitution and that the universities, as providers of health benefit plans, were indeed members of IIHBRA. The court also ruled that IIHBRA was statutorily authorized to impose late payment fees against its members. However, the court denied IIHBRA's request for attorney fees and costs. The court affirmed in part, reversed in part, and remanded the case for further proceedings. View "Iowa Individual Health Benefit Reinsurance Ass’n v. State University of Iowa" on Justia Law

The Supreme Court of Iowa reviewed a case where a plaintiff, James Penny, brought a lawsuit against the City of Winterset and a police officer, Christian Dekker, for damages caused by a collision. Officer Dekker was responding to an emergency call and had his overhead lights and siren on. He was traveling northbound and James Penny was traveling westbound when their vehicles collided at an intersection. As a result of the collision, Penny sustained several injuries. The district court granted summary judgment in favor of the defendants, concluding that the police officer's conduct was not reckless. However, the Court of Appeals reversed this decision.On further review, the Supreme Court of Iowa found that Officer Dekker's conduct did not rise to the level of recklessness under Iowa law, affirming the district court's grant of summary judgment. The court noted that while Officer Dekker did not come to a complete stop at the stop sign, he was not required to do so under Iowa Code section 321.231(3)(a) if he slowed down to a speed "necessary for safe operation." The court concluded that while it may have been negligent for Officer Dekker not to have perceived the lights to his right as coming from Penny's vehicle rather than a farmhouse, this failure did not rise to the level of recklessness. Thus, the court vacated the decision of the Court of Appeals and affirmed the district court's judgment. View "Penny v. City of Winterset" on Justia Law

In this case, the Supreme Court of Iowa was asked to interpret and apply three provisions of the Iowa Code relating to workers' compensation. The plaintiff, Corey Tweeten, worked on his father's farm and sustained a right arm injury on July 25, 2017. He filed a claim for workers’ compensation benefits on January 21, 2020, more than two years after the incident. The defendants, his father's farm and their insurance carrier, appealed a district court order partially granting Tweeten's claim.The Supreme Court was called upon to interpret three provisions of the Iowa Code: (1) whether a compromise settlement between a claimant and the Second Injury Fund precludes further benefits from the employer, (2) whether the discovery rule tolls the statute of limitations for filing a claim for workers’ compensation benefits, and (3) how amendments to the Iowa Code affect reimbursement for independent medical examinations.The Supreme Court of Iowa held that the compromise settlement between Tweeten and the Second Injury Fund did not bar Tweeten's claims against his employer and their insurance carrier. The Court reasoned that the compromise settlement concerned a dispute over whether a previous injury triggered the Second Injury Compensation Act, separate from the claim against the employer for the current injury. Therefore, the compromise settlement did not bar the separate and distinct claim against the employer.Regarding the second issue, the Court ruled that the discovery rule as previously applied by the courts did not survive the 2017 revisions to the relevant section of the Iowa Code. The Court held that the two-year statutory period begins to run when the employee knows or should know that an injury is work-related, without regard to whether the injury is also serious enough to be compensable. As such, the plaintiff's claim was time-barred, as he knew he had a right-arm injury that was work-related more than two years before he sought benefits.Finally, the court held that the plaintiff was not entitled to reimbursement for the independent medical examination under Iowa Code section 85.39, since the injury for which he was examined was not compensable.The court reversed the lower court's decision and remanded the case for further proceedings. View "Tweeten v. Tweeten" on Justia Law

In the case before the Supreme Court of Iowa, the plaintiff, Renee Hummel, brought a medical malpractice suit against the defendants, Adam B. Smith, Adam Smith, M.D., P.C., and Tri-State Specialists, L.L.P. The defendants requested an interlocutory review of a lower court order that denied their motion to strike and for summary judgment. The issue at the heart of the defendants' motion was that the expert who signed the plaintiff's certificate of merit did not have an active license to practice medicine.The Supreme Court of Iowa reversed the lower court's decision and remanded the case. The court determined that an expert who signs a plaintiff's certificate of merit in a medical malpractice case must have an active license to practice medicine. Therefore, the lower court erred in denying the defendants' motion to strike and for summary judgment on the basis that the plaintiff's certificate of merit was signed by an expert without an active medical license. View "Hummel v. Smith" on Justia Law

In this case, Scott Olson, an employee of BNSF Railway Company, sued the company under the Federal Employers' Liability Act, seeking damages for injuries he sustained in a workplace accident. A jury found in favor of Olson and awarded him significant damages. The railway company appealed, alleging three specific instances of error by the district court. The Supreme Court of Iowa vacated the decision of the court of appeals, which had granted a new trial, and affirmed the district court's judgment. The court held that the railway company did not properly preserve its challenge to the verdict form for appeal, as the company had failed to object to the form until after the jury returned its verdict. The court also ruled that the district court did not err by allowing Olson to present new negligence claims during the trial that were not alleged in the pleadings or identified during discovery, as the company was clearly on notice that Olson alleged that the company failed to reasonably train all employees as one of the specific allegations of negligence at trial. Lastly, the court found that the company was not prejudiced by Olson's counsel's alleged misconduct during his rebuttal closing argument. View "Olson v. BNSF Railway Company" on Justia Law

In the Supreme Court of Iowa, the appellants, the estate and family of Deanna Dee Fahrmann, had filed a wrongful-death action against ABCM Corporation and two of its employees, alleging nursing home malpractice. The appellants failed to serve a certificate of merit affidavit, required under Iowa Code section 147.140, signed by a qualified expert within sixty days of the defendants’ response to the claim. Instead, they served initial disclosures, signed only by their counsel, that named their expert within the statutory sixty-day deadline. After the deadline, the defendants moved to dismiss the case for noncompliance, and the appellants served a certificate signed by their expert and argued that they substantially complied with the statute. The district court dismissed the case based on the mandatory language of the statute.On appeal, the Supreme Court of Iowa affirmed the lower court's decision to dismiss the case. The court held that the plaintiffs' initial disclosure, signed only by their counsel, did not comply with or substantially comply with the certificate of merit requirement under section 147.140 of the Iowa Code. The law unambiguously required the plaintiffs to timely serve a certificate of merit affidavit signed under oath by a qualified expert stating the expert’s familiarity with the applicable standard of care and its breach by the defendants unless the parties extend the deadline by agreement or the plaintiffs show good cause to move for an extension within the sixty-day deadline. The plaintiffs' untimely service of a certificate signed by their expert did not constitute substantial compliance with the statute. Therefore, dismissal was mandatory under the plain language of the statute. View "The Estate of Deanna Dee Fahrmann v. ABCM Corporation" on Justia Law