Justia Iowa Supreme Court Opinion Summaries

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

In this case from the Supreme Court of Iowa, the appellant, David Gordon, a minor at the time of committing his crimes, was charged with theft in the first degree and willful injury resulting in bodily injury. He pleaded guilty and was sentenced to ten years in prison for the theft conviction and five years for the assault conviction, with the sentences to run concurrently. Gordon appealed the sentence and also filed a motion requesting reconsideration of the sentence under Iowa Code § 902.4. The district court reconsidered the sentence and placed Gordon on probation for up to five years. Gordon then filed a petition for writ of certiorari challenging his resentencing, arguing that the district court had abused its discretion by not granting him a deferred judgment in its initial sentencing, and then by wrongly concluding that it lacked the authority to do so under § 902.4 when resentencing him.The Supreme Court of Iowa affirmed the district court's decisions. The court held that the district court did not abuse its discretion in the initial sentencing. It found that the district court had considered and weighed the arguments for and against a deferred judgment, and had thoroughly explained its reasoning for the sentence imposed. As for Gordon's argument about the district court's power to defer judgment when reconsidering a sentence under § 902.4, the Supreme Court held that a deferred judgment involved more than a sentence. It involved the deferring of a judgment adjudicating guilt as well as a sentence. The court concluded that the district court correctly interpreted its authority under § 902.4 when it determined that it could not defer judgment when reconsidering Gordon's sentence. Therefore, the court affirmed Gordon's conviction and sentence and annulled the writ of certiorari. View "State of Iowa v. Gordon" on Justia Law

This case from the Supreme Court of Iowa involves a juvenile, I.S., who was charged with sexual exploitation of a minor and possession of child pornography. The juvenile court initially waived its jurisdiction over the case, allowing it to be tried in the district court. However, the juvenile court later vacated its waiver and reclaimed jurisdiction over the case. The State sought a review of the juvenile court's decision to vacate its earlier order, arguing that the juvenile court no longer had jurisdiction or authority to modify or vacate the waiver order once it had been issued.The Supreme Court of Iowa held that the juvenile court did not have the authority to reclaim jurisdiction over the case after it had waived it to the district court. The court found that there was no provision in Iowa law for such a "revocation of waiver." The court reasoned that once a case has been transferred or waived to another court, the transferring court loses jurisdiction over the parties. The court also noted that allowing a juvenile court to reclaim jurisdiction could lead to disruption of proceedings and friction between the district and juvenile courts.Therefore, the court sustained the State's writ, vacated the juvenile court's revocation of its waiver of jurisdiction, and remanded the case, with the expectation that any further proceedings would occur in the district court. View "State of Iowa v. Iowa Juvenile Court for Plymouth County" on Justia Law

The case involves an Iowa attorney, Marc Harding, who hired an Indiana-based doctor, Rick Sasso, to provide expert witness services in a potential medical malpractice suit in Iowa. After things did not go as planned, Harding sued Sasso in Iowa to recover a portion of the $10,000 retainer he had paid, plus additional damages. Sasso moved to dismiss the suit, arguing that the Iowa court did not have personal jurisdiction over him. The district court denied the motion, and Sasso appealed. The court of appeals reversed the district court's decision and ordered the case to be dismissed, but the Supreme Court of Iowa granted Harding's application for further review.The Supreme Court of Iowa held that the Iowa court could exercise personal jurisdiction over Sasso. The court found that Sasso had sufficient minimum contacts with Iowa to support the exercise of personal jurisdiction over him with respect to the contract dispute. Sasso had entered into a contractual relationship with Harding, who is an Iowa lawyer, and agreed to evaluate a medical malpractice claim involving Iowa residents and to provide expert testimony at any trial in the medical malpractice case, which would have been venued in Iowa. The court also found that the exercise of jurisdiction would not be unreasonable or offend traditional notions of fair play and substantial justice. Therefore, the Supreme Court of Iowa vacated the decision of the court of appeals, affirmed the district court's order denying Sasso's motion to dismiss, and remanded the case for further proceedings. View "Harding v. Sasso" on Justia Law

In this case from the Supreme Court of Iowa, the defendant, Stephen Arrieta, a truck driver, was pulled over at a weigh station after his vehicle failed a "PrePass" check. During the stop, an Iowa Department of Transportation officer requested a K-9 unit to conduct a free air sniff of the truck and trailer. The drug dog alerted to the presence of drugs in the sleeper compartment of the cab, and Arrieta admitted to having marijuana inside. Arrieta was subsequently charged with possession of a controlled substance.Arrieta appealed the denial of his motion to suppress the marijuana. His main argument was that the officer unlawfully extended the time of his stop, known as a Level 3 inspection, to allow the K-9 handler to arrive and search his truck. Arrieta cited Rodriguez v. United States, a Supreme Court case that ruled such extensions of traffic stops without reasonable suspicion of criminal activity are unconstitutional.The Supreme Court of Iowa agreed with Arrieta, finding that he was detained longer than necessary to complete the Level 3 inspection, in violation of the Fourth Amendment. The court concluded that the officer had effectively completed his tasks before the arrival of the K-9 unit and that the 25-minute delay until the K-9 unit's arrival was unjustified. As such, Arrieta was improperly detained when the free air sniff occurred, and any evidence obtained as a result of the search should have been suppressed.The court vacated the decision of the Court of Appeals and reversed and remanded the judgment of the district court. View "State of Iowa v. Arrieta" on Justia Law

In a case before the Supreme Court of Iowa, the defendant, Robert Clark Geddes, was charged with trespass as a hate crime. The defendant had trespassed onto various properties, leaving behind anonymous notes that urged the residents to "Burn that gay flag." The homes targeted by the defendant were displaying LGBTQ+ flags or decals. Geddes appealed his conviction, arguing that the evidence was insufficient and that his convictions violated his rights to free speech and due process.The court rejected the defendant's arguments and affirmed his convictions. The court ruled that Geddes was not being punished for his speech, but rather for his conduct—trespassing onto properties with the intent to commit a hate crime. The court found that the statute under which Geddes was convicted does not criminalize speech, but rather conduct with a specific intent—namely, trespassing on property because of the property owner or possessor's association with persons of a certain sexual orientation. The court also found that there was sufficient evidence to support Geddes's conviction.The court held that the defendant's conduct of surreptitiously entering onto properties to post his harassing notes was not protected under the First Amendment rights. The court noted that hate crime laws are designed to punish conduct, not expression, and Geddes's motive or intent led to the more serious criminal consequence. The court also rejected the defendant's argument that the trespass law was vague or overbroad, finding that it provides sufficient guidance to those enforcing it and does not intrude on protected freedoms. View "State of Iowa v. Geddes" on Justia Law

In the case before the Supreme Court of Iowa, the court reviewed the trial and conviction of Robert Krogmann for attempted murder and willful injury causing serious injury. This was Krogmann's second trial after his initial conviction was overturned on appeal due to an improper asset freeze that interfered with his defense rights. In the second trial, Krogmann appealed his conviction on multiple grounds.The court held that the court of appeals erred in concluding that the trial court should have admitted a video recording of Krogmann's interview with law enforcement. Although the video was not hearsay and should have been admitted, the court held that the exclusion of the video did not affect Krogmann’s substantial rights and was therefore harmless error. The video would not have materially aided Krogmann's diminished capacity defense.The court further held that the trial court did not err in instructing the jury that assault, an element of the crimes charged against Krogmann, is a specific-intent crime, and that diminished responsibility can negate the intent element of assault.The court also upheld the trial court's decision to exclude evidence of a $1.5 million civil settlement between Krogmann and the victim, finding that the evidence was not relevant to the issues in the case.However, the court found that the trial court erred in allowing a witness to testify to the ultimate issue of intent, stating that it is the job of the court, not a paid expert, to explain criminal law to the jury.Lastly, the Supreme Court of Iowa agreed with Krogmann's contention that the court erred in awarding him to pay an expert witness’s fees and expenses in excess of the $150 per day cap in Iowa Code section 622.72.The Supreme Court of Iowa vacated the decision of the court of appeals, affirmed the district court judgment, granted and sustained in part the writ of certiorari, and remanded the case for redetermination of costs. View "Iowa v. Krogmann" on Justia Law