Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's judgment of sentence and confirmed what it held in State v. Wilbourn, 974 N.W.2d 58 (Iowa 2022) and State v. Treptow, 960 N.W.2d 98 (Iowa 2021), that if good cause is lacking to bring a criminal appeal, an appellate court has no jurisdiction, and the appeal must be dismissed.Defendant pleaded guilty to second-degree theft and was sentenced to three consecutive five-year sentences of imprisonment. The court of appeals affirmed the sentence after finding good cause to address Defendant's challenge to his sentence under Iowa Code 814.6(1)(a)(3). The court declined to address Defendant's assertion that there was an inadequate factual basis to support his guilty plea to theft based on a lack of good cause. The Supreme Court affirmed in part and vacated the judgment in part, holding (1) because the court of appeals had jurisdiction over this appeal it should have also addressed Defendant's challenge to the factual basis supporting his guilty plea; and (2) even though this Court had jurisdiction over Defendant's appeal, it lacked the authority to resolve his factual basis challenge. View "State v. Rutherford" on Justia Law

The Supreme Court affirmed the judgment of the district court ruling that an Employer's refusal to collect dues from Union members' paychecks was a breach of certain collective bargaining rights and awarding money damages to Union, holding that there was no error.Union brought suit against Employer alleging that Employer breached its contracts by failing to deduct dues. The district court granted summary judgment in favor of Union as to Employer's liability for breach of contract for refusing to deduct dues. After a bench trial on the issue of damages the court awarded $1,046,835 to Union. The Supreme Court affirmed, holding (1) Employer breached the contracts' written terms by failing to collect dues; and (2) the money damages remedy was appropriate and without legal error. View "UE Local 893/IUP v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant, following a jury trial, of murder in the second degree, obstructing prosecution, and abusing a corpse, holding that the district court did not abuse its discretion by giving a verdict-urging instruction in this case.On appeal, Defendant argued that the district court coerced the jury's verdict by giving a verdict-urging instruction after the court was informed that the jury was divided 11-1 and that one juror was not following the judge's instructions. The court of appeals vacated Defendant's convictions, concluding that the jury's verdict was coerced. The Supreme Court vacated the court of appeals' opinion and affirmed Defendant's convictions, holding that the court of appeals erred in its coercion analysis and that the jury's verdict was not coerced under the circumstances. View "State v. Church" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions for first-degree robbery and willful injury causing serious injury, holding that Defendant was not entitled to relief on his allegations of error.Defendant's convictions stemmed from his role in the baseball bat attack of a man outside his apartment complex, and a surveillance camera captured some of the altercation. The Supreme Court held (1) there was sufficient evidence to convict Defendant of first-degree robbery based on the victim's testimony and the corroborating surveillance video evidence of the attack; (2) the district court's failure to merge the convictions was not erroneous; and (3) Defendant was not prejudiced by the district court's decision to continue the trial for nine days due primarily to juror illness. View "State v. Brown" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of first-degree robbery and willful injury causing serious injury, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued, among other things, that the district court imposed an illegal and unconstitutional sentence by failing to merge his two convictions. The Supreme Court affirmed, holding (1) there was sufficient evidence to convict Defendant of willful injury causing serious injury; and (2) the district court did not err by not merging the willful injury causing serious injury conviction with the first-degree robbery conviction because there are additional elements of willful injury causing serious injury that are not encompassed within the elements of first-degree robbery under the dangerous weapon alternative. View "State v. Cook" on Justia Law

The Supreme Court affirmed the judgment of the district court ordering Respondent's continued hospitalization following his court-ordered psychiatric treatment, holding that respondents in proceedings brought under Iowa Code chapter 229 do not have a federal constitutional right to represent themselves and forego the legal representation required by the statute.Respondent, who had a history of self-harm, suicide threats, and refusal to take his medications, was ordered to be involuntarily hospitalized under chapter 229. A series of subsequent court orders left Respondent's commitment in place for the next two years. Thereafter, Respondent moved to terminate his commitment and asked to proceed pro se. The district court denied Respondent's motion to proceed pro se and ordered his continued hospitalization. The Supreme Court affirmed, holding (1) the Sixth Amendment right to counsel and right to self-representation in criminal cases do not apply to Chapter 229 proceedings; and (2) the district court's factual findings were supported by substantial evidence and binding on appeal. View "In re V.H." on Justia Law

The Supreme Court affirmed the order of the juvenile court granting the State's delinquency petition against Defendant and its motion to waive jurisdiction to allow for Defendant's prosecution as an adult, holding that the juvenile court did not abuse its discretion in granting the waiver and that there was sufficient evidence to support Defendant's conviction.One month after his seventeenth birthday Defendant committed second-degree sexual abuse. The juvenile court issued an order waiving jurisdiction, concluding that there were not reasonable prospectives for rehabilitating Defendant if the juvenile court retained jurisdiction and that the waiver was in the bests interests of Defendant and the community. Defendant was found guilty after a jury trial. The Supreme Court affirmed, holding (1) a rational fact finder could determine beyond a reasonable doubt that Defendant committed second-degree sexual abuse based on the evidence presented; and (2) the juvenile court's waiver decision was supported by the evidence and reasonable. View "State v. Erdman" on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that Desira Johnson, a teacher at the West Des Moines Community Schools (the District), was not subject to individual liability under the Iowa Civil Rights Act (ICRA) on Plaintiff's claim of constructive discharge, holding that there was no error.Plaintiff, a teacher's associate who worked with special education students in the District, sued the District and Johnson, alleging that Johnson engaged in racial discrimination, leading to Plaintiff's constructive discharge in violation of the ICRA. The jury returned a defense verdict in favor of the District. The Supreme Court affirmed, holding (1) the district did not err in overruling Plaintiff's Batson challenge to Defendants' peremptory strike of the only Black potential juror; (2) the district court did not err in granting Johnson's motion for directed verdict for correction of errors at law; and (3) Plaintiff was not entitled to relief on her allegations of error in the district court's evidentiary rulings. View "Valdez v. West Des Moines Community Schools" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court in this wrongful discharge action, holding that the district court did not err in denying the motion to dismiss Plaintiff's claims against the State but erred in denying the motion to dismiss the claims against the Governor and the Governor's communications director.In her complaint, Plaintiff alleged that she was forced out of her employment with the Iowa Department of Public Health because she refused to stifle certain public records requests to the Department. In their motion to dismiss, Defendants argued, among other claims, that qualified immunity barred Plaintiff's claims. The district court denied the motion. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) correctly denied Plaintiff's motion to dismiss the claims against the State; but (2) erred in denying Plaintiff's motion to dismiss her claims against the Governor and his communications director for wrongful discharge under Iowa Code 70A.28 and wrongful discharge in violation of public policy. View "Carver-Kimm v. Reynolds" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing Plaintiff's claim alleging she suffered permanent lung injury from toxic vapors that spread throughout the building where she worked, holding that Plaintiff did not present evidence to create a dispute of material fact as to the element of causation.A maintenance worker at the multistory medical office building where Plaintiff worked used a chemical drain cleaner to clear a clogged restroom sink on a lower level. Plaintiff claimed that her inhalation of the fumes the building aggravated her preexisting asthmatic condition and permanently caused reduced pulmonary function. The district court granted Defendant's motion to dismiss, concluding that there was insufficient evidence presented that the chemical fumes caused the lung injury alleged by Plaintiff. The Supreme Court affirmed, holding that Plaintiff presented insufficient evidence about whether the dose of toxin to which she was exposed was capable of causing her alleged permanent injury. View "Uhler v. Graham Group, Inc." on Justia Law