Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed in part and reversed in part the judgment of the district court dismissing Plaintiffs' lawsuit challenging the City of Windsor Heights's attempts to collect automated traffic citation fines not reduced to a judgment in a municipal infraction proceeding, holding that the district court erred in part.At issue was an income offset program authorized pursuant to Iowa Code 8A.504 allowing the department of administrative services to "establish a debt collection setoff procedure for collection of debts owed to the public agency." Plaintiffs brought this action against the City and the City's collection agent challenging the program to enforce civil penalties issued pursuant to the automated traffic enforcement system. The district court dismissed all claims. The Supreme Court reversed in part and remanded the case for further proceedings, holding that the district court erred in dismissing some claims against the City as time-barred. View "Stogdill v. City of Windsor Heights" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Exile Brewing Company's attempt to intervene in the underlying probate matter and striking Exile's motion to vacate, dismiss, and close two estates seeking to pursue certain claims, holding that the probate court did not err in denying the request to intervene and close the estates.During the 1950s and '60s, Ruth Bisignano owned and operated a popular bar in Des Moines. In 2012, Exile named one of its craft beers "Ruthie" and used Ruth's image. Ruthie died in 1993, and her estate was closed that year. Her husband Frank Bisignano died three years later, and his estate was closed in 1999. In 2020, Plaintiff successfully filed petitions to reopen both estates. Subsequently, as administrator of Frank's estate, Plaintiff sued Exile alleging common law appropriation and other claims. Exile filed a motion to vacate, dismiss, and close both estates, arguing that the probate court lacked statutory jurisdiction to reopen the estates. The probate court denied the motion, concluding that Exile had no right to intervene in the probate proceedings. The Supreme Court affirmed, holding that the probate court correctly determined that Exile was an interloper with no ability to challenge the estates' reopening. View "In re Estate of Bisignano" on Justia Law

The Supreme Court affirmed the order of the trial court on interlocutory appeal denying Defendants' remand for a jury in this argument over the requirement that civil enforcement actions brought by the attorney general "shall be by equitable proceedings," holding that the requirement was enforceable and did not violate the jury right preserved by Iowa Const. art. I, 9.The attorney general commenced this action alleging that Defendants had violated the Iowa Consumer Fraud Act (CFA), Iowa Code 714.16, and the Older Iowans Act (OIA), Iowa Code 714.16A, by engaging in false and deceptive conduct and unfair practices in the "sale and advertisement of stem cell and exosome therapy in Iowa." Defendants answered and demanded a jury, but the attorney general moved to strike the jury demand because subsection 714.16(7) requires that civil actions "shall be by equitable proceedings." The district court granted the motion to strike, and Defendants applied for interlocutory review. The Supreme Court affirmed, holding that the district court did not err in striking Defendants' jury demand. View "State ex rel., Attorney General" on Justia Law

The Supreme Court affirmed the judgment of the juvenile court dismissing an attorney's pro se petition to establish an involuntary guardianship of J.W., holding that the juvenile court did not abuse its discretion under the unique circumstances of this case.J.W. was the nine-year-old daughter of Mother, Attorney's former client. Attorney had represented Mother in prior custody disputes involving the child over which he sought to be named the guardian. The juvenile court dismissed the petition on the grounds that Attorney violated his duties to Mother as a former client under the Iowa Rules of Professional Conduct. The court of appeals reversed, concluding that the juvenile court erred in order dismissal as a remedy for any purported ethical violations. The Supreme Court vacated the decision of the court of appeals and affirmed the juvenile court's judgment, holding that dismissal was not clearly untenable. View "In re Guardianship of J.W." on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment to a police detective and his city employer in this case alleging defamation, abuse of process, and malicious prosecution, holding that there was no error.Plaintiff, who was acquitted of a sexual assault charge, sued county prosecutors and city police for allegedly pursuing the case against him. The Supreme Court held that the county prosecutors were entitled to dismissal from the case but rejected the investigating detective's arguments for dismissal on the pleadings. The district court ultimately granted summary judgment to the detective and the city. The Supreme Court affirmed, holding that the district court (1) properly granted summary judgment to the city defendants on Plaintiff's continuing malicious prosecution claim; and (2) did not err in dismissing Plaintiff's direct claims for damages under the Iowa Constitution. View "Venckus v. City of Iowa City" on Justia Law

The Supreme Court affirmed the judgment of the district court denying the motion filed by the Council Bluffs Water Works' to dismiss the claim brought by Jim and Angela Sutton for strict liability, holding that the district court did not err in failing to dismiss Suttons' strict liability claim.After an underground water main broke near the Suttons' home the Suttons sued Water Works for the ensuing damage to their house, alleging strict liability and negligence. Water Works moved to dismiss the strict liability claim on the grounds that the Iowa Municipal Tort Claims Act, Iowa Code ch. 670, did not permit a strict liability claim against it. The district court denied the motion, and Water Works filed an application for interlocutory appeal. The Supreme Court affirmed, holding that the Act does not allow a claim for strict liability against a municipality for damage caused by an underground water main break. View "Sutton v. Council Bluffs Water Works" on Justia Law

On interlocutory appeal and cross-appeal of a ruling on a motion to dismiss the state constitutional tort and common law claims arising out of a warrantless arrest of Plaintiff's spouse the Supreme Court affirmed in part and reversed in part, holding that the district court erred in denying Defendants' motion to dismiss Plaintiff's claims for intentional infliction of emotional distress (IIED) and trespass.Plaintiff brought this lawsuit against law enforcement officials and their employers asserting state constitutional tort claims, as well as common law claims for assault, trespass, and intentional infliction of emotional distress. Defendants filed a motion to dismiss. The district court granted the motion as to the state constitutional tort claims but denied it as to the common law claims. Plaintiff applied for, and Defendants' cross-applied for, interlocutory appeal. The Supreme Court (1) affirmed the district court's dismissal of Plaintiff's state constitutional tort claims and assault claim, holding there was no error; and (2) reversed the denial of Defendants' motion to dismiss the IIED and trespass claims, holding that there was sufficient evidence to support this claim. View "White v. Harkrider" on Justia Law

The Supreme Court dismissed this direct appeal brought by the Iowa Department of Human Services (HDS) from a district court ruling requiring Iowa's Medicaid program to pay for sex reassignment surgery for two transgender adults and affirmed the denial of fees on cross-appeal, holding that the appeal was moot.Petitioners, adult transgender Iowans who were denied preauthorization for sex reassignment surgeries through the Medicaid program, appealed their managed care organization's denial of coverage to DHS. DHS affirmed the denials. The district court reversed, concluding that Iowa Code 216.7(3), an amendment to the Iowa Civil Rights Act (ICRA) violated the guarantee of equal protection under the Iowa Constitution. DHS appealed, but, thereafter, agreed to pay for Petitioners' surgeries. The Supreme Court dismissed the direct appeal as moot and affirmed the district court's order denying any fee award, holding that the court erred in denying Petitioners' request for attorney fees. View "Vasquez v. Iowa Dep't of Human Services" on Justia Law

The Supreme Court affirmed the summary judgment of the district court concluding that a condominium owner-landlord owed no duty of care with respect to a downspout that discharged water directly onto a shared driveway, holding that the owner-landlord had no common law, contractual, or statutory duty to keep the driveway clear.The condominiums at issue in this case were subject to a horizontal property regime pursuant to Iowa Code ch. 449B, which, in turn, was governed by a document referred to as the declaration. Shelly and Cameron Barnes leased a condominium unit from CDM Rentals, LLC. After Shelly fell on ice on the shared driveway the Barneses brought this negligence lawsuit. The district court granted summary judgment for CDM on the ground that CDM lacked control over the common areas. The Supreme Court affirmed, holding (1) regarding premises liability, CDM lacked control of the driveway and downspout under the declaration; and (2) the district court correctly concluded that the Uniform Residential Landlord and Tenant Act, Iowa Code ch. 562A, requires landlords to maintain common areas but only to the extent the landlord has control over those areas. View "Barnes v. CDM Rentals, LLC" on Justia Law

The Supreme Court affirmed the judgment of the district court denying a request for a qualified domestic relations order (QDRO), holding that without a divorce or separate maintenance proceeding under Iowa Code chapter 598 Iowa district courts cannot enter QDROs for the sole purpose of transferring a plan covered by the Employee Retirement Income Security Act of 1974 (ERISA).Plaintiff sought to have her late husband's 401(k) profit-sharing plan, which was governed by ERISA, transferred into her name. To complete such a transfer, ERISA requires the parties to obtain a QDRO pursuant to Iowa domestic relations law, but at the time the petition was filed the parties were married and opposed to seeking a domestic relations order through divorce or separate maintenance proceedings. The district court refused to grant the order on the grounds that it lacked the authority to do so. The Supreme Court affirmed, holding that, in the absence of a domestic relations matter such as a divorce, married couples cannot obtain a QDRO for the sole purpose of moving funds in an ERISA plan to the non-participating spouse. View "Wallace v. Wildensee" on Justia Law