Justia Iowa Supreme Court Opinion Summaries

Lance and Tracy Degeneffe entered into a roofing contract with Home Pride Contractors, Inc. to repair their roof, gutters, and siding after wind and hail damage. Home Pride completed the repairs and billed the Degeneffes, who refused to pay, leading Home Pride to hire an attorney to collect the debt. The Degeneffes sued Home Pride, alleging that its prior counsel engaged in harassing and abusive collection efforts in violation of the Iowa Consumer Credit Code (ICCC).The Iowa District Court for Boone County reviewed cross motions for summary judgment. Home Pride argued it was not subject to the ICCC as it did not extend credit or lend money to its customers. The Degeneffes argued that the roofing contract was a consumer credit sale subject to the ICCC and that Home Pride’s conduct was harassing and abusive under the ICCC. The district court denied Home Pride’s motion and granted the Degeneffes’ motion in part, establishing that the roofing contract constituted a consumer credit sale subject to the ICCC, but left the question of whether Home Pride’s conduct was harassing and abusive for trial.The Iowa Supreme Court reviewed the case to determine whether the roofing contract was a consumer credit sale subject to the ICCC. The court concluded that Home Pride did not grant credit to the Degeneffes, as the contract required full payment upon completion of the work, and the 1.5% monthly interest charge for late payment did not constitute an extension of credit. The court reversed the district court’s entry of partial summary judgment in favor of the Degeneffes and remanded the case for entry of summary judgment in favor of Home Pride. View "Degeneffe, v. Home Pride Contractors, Inc." on Justia Law

A landlord, MIMG CLXXII Retreat on 6th, LLC, owns an apartment building in Cedar Rapids, Iowa. Mackenzie Miller, a tenant, entered a one-year lease in June 2022. The lease required rent to be paid by the first of each month, with a three-day notice period for nonpayment before the landlord could terminate the tenancy and pursue eviction. In December 2022, Miller failed to pay rent, and the landlord served a three-day notice. When the rent remained unpaid, the landlord filed a forcible entry and detainer (FED) action in the small claims division of the Linn County District Court.The small claims court dismissed the FED action, ruling that the Federal CARES Act required a thirty-day notice before eviction, which preempted Iowa's three-day notice law. The landlord appealed to the Iowa District Court for Linn County, arguing that the thirty-day notice requirement was time-limited to the 120-day moratorium period specified in the CARES Act. The district court upheld the small claims court's decision, stating that the plain language of the CARES Act did not include an expiration date for the thirty-day notice requirement.The Iowa Supreme Court reviewed the case and concluded that the thirty-day notice requirement in the CARES Act applies only to rent defaults that occurred during the 120-day moratorium period. The court reasoned that the statute must be read in context with the surrounding provisions, which were temporary measures related to the COVID-19 pandemic. The court also noted the presumption against preemption of state law, particularly in areas traditionally governed by state law, such as landlord-tenant relationships. The Iowa Supreme Court reversed the district court's decision and remanded the case for further proceedings consistent with its opinion. View "MIMG CLXXII Retreat on 6th, LLC v. Miller" on Justia Law

An officer on patrol stopped a vehicle for a traffic infraction after receiving information that the vehicle’s occupants might have been involved in a drug sale. After initially interacting with the driver, the officer waited for backup before removing the occupants and conducting a search with a drug-sniffing dog, which led to the discovery of a gun. The passenger, Tyre Brown, admitted ownership of the gun and was charged with unlawful possession of a firearm. Brown argued that the officer unlawfully prolonged the stop beyond the time necessary to address the traffic infraction, violating his constitutional rights.The Iowa District Court for Polk County denied Brown’s motion to suppress the evidence obtained from the search. Brown was found guilty after stipulating to a trial on the minutes of testimony. Brown appealed the denial of his motion to suppress, and the Iowa Court of Appeals affirmed the district court’s ruling. The court of appeals concluded that the extension of the stop was permissible under the shared-knowledge doctrine and that the officer had smelled marijuana, justifying further investigation.The Iowa Supreme Court reviewed the case and affirmed the lower courts' decisions. The court held that the shared-knowledge doctrine allowed the officer to act on information provided by another officer who had observed a potential drug transaction, thus justifying the extension of the stop. The court found that the extension of the stop to investigate for drugs did not violate Brown’s constitutional rights. Consequently, the district court’s ruling denying Brown’s motion to suppress was affirmed. View "State of Iowa v. Brown" on Justia Law

In 2017, the Franklin County Board of Supervisors undertook a project to deepen and widen the drainage ditch known as Drainage District No. 48 (DD48). The project affected several landowners, who sought damages for the reconstruction. The district court ruled that the Board had not abandoned the original right-of-way easement from 1906, limiting right-of-way damages to the expanded areas beyond the original boundaries. The court also awarded severance damages for the diminution in value of the remaining property due to the inability to traverse the ditch with farming equipment. Additionally, the court ordered the conveyance of a 4.01-acre landlocked parcel to the Board, with compensation for its full value.The Iowa District Court for Franklin County ruled in favor of the landowners, awarding both right-of-way and severance damages. The court of appeals affirmed the damages awards but reversed the order to convey the 4.01-acre parcel, remanding for further proceedings. The Board sought further review to determine the entitlement to severance damages.The Iowa Supreme Court reviewed the case and concluded that the Board held a permanent right-of-way easement for the drainage ditch, which had not been abandoned. Therefore, the landowners were only entitled to right-of-way damages for the expanded areas beyond the original boundaries. The court held that the plaintiffs were not entitled to severance damages for the diminution in value of their remaining property, except for the 4.01-acre parcel that became landlocked in 2017. The court affirmed the district court’s award for the landlocked parcel but reversed the severance damages for the other properties. The case was remanded for entry of a damages award consistent with the appraisal committee’s initial calculation. The Board was not entitled to a deed for the 4.01-acre parcel. View "Abbas v. Franklin County Board of Supervisors" on Justia Law

Isaiah Duffield was required to register as a sex offender due to a juvenile adjudication for sexual abuse. In April 2022, he was charged with sexual abuse in the third degree, second or subsequent offense, and failure to comply with the sex offender registry. After the charges were severed and amended, Duffield entered a guilty plea to the lesser offense of failure to register, an aggravated misdemeanor. The district court sentenced him to a term of incarceration not to exceed two years and a fine of $1,025, which was suspended. The court ordered the sentence to be served consecutively to a sentence in a separate sexual abuse case.Duffield appealed to the Iowa Court of Appeals, arguing that the district court abused its discretion in imposing the $1,025 fine and failed to state its reasons for imposing consecutive sentences. The court of appeals upheld the fine, reasoning it was within the statutory range and Duffield did not establish any irregularity. However, the court agreed that the district court erred in failing to state reasons for consecutive sentences and remanded the case to a different judge to decide whether the sentences should be served concurrently or consecutively.The Iowa Supreme Court reviewed the case and focused on the consecutive sentencing issue. The court held that the district court erred in failing to state its reasons for imposing consecutive sentences. The court vacated Duffield’s sentence and remanded the case for a plenary resentencing hearing, emphasizing that the resentencing should not be limited to the consecutive sentencing issue alone. The court also concluded that resentencing before a different judge was not required, as there was no taint in the sentencing process. The decision of the court of appeals was vacated, the conviction was affirmed, the sentence was vacated, and the case was remanded for resentencing. View "State of Iowa v. Duffield" on Justia Law

Lukouxs Brown was charged with first-degree murder after allegedly killing a coworker. Before his arraignment, his counsel observed signs of mental illness, including hearing voices and a history of schizophrenia. The district court found probable cause to believe Brown was not competent to stand trial and ordered a psychiatric evaluation. Dr. Arnold Andersen diagnosed Brown with a schizophrenia-like disorder and substance abuse disorders, concluding he was not competent but could potentially be restored to competency. Brown was committed to the Iowa Medical and Classification Center (IMCC) for treatment.After eight months of treatment, Dr. Andersen reported that Brown remained incompetent and unlikely to be restored to competency within a reasonable time. The district court, however, allowed the State to obtain a separate psychiatric evaluation, which concluded that Brown was competent. The district court found Brown competent to stand trial and reinstated the criminal proceedings. Brown filed an interlocutory appeal, arguing the district court erred in its competency determination and in allowing the State to obtain a separate evaluation.The Iowa Court of Appeals reviewed the case de novo, found Brown was not competent, and remanded the case for further treatment. The State sought further review, challenging the standard of review and the district court's decision to allow a separate evaluation. The Iowa Supreme Court reaffirmed the de novo standard of review for competency determinations, emphasizing the protection of constitutional rights. The court also held that Iowa Code does not permit separate psychiatric evaluations at the dispositional phase of competency proceedings. The court vacated the Court of Appeals decision, reversed the district court order, and remanded the case for further proceedings consistent with its opinion. View "State of Iowa v. Brown" on Justia Law

Alison Dorsey ran an in-home daycare in Cass County, Iowa. In 2019, an eleven-week-old baby at her daycare died, leading to Dorsey being charged with first-degree murder and child endangerment resulting in death. Her first trial in Cass County ended in a hung jury. The State then requested a change of venue, which the district court granted, moving the second trial to Pottawattamie County. Dorsey was subsequently convicted of second-degree murder and child endangerment resulting in death.The Iowa District Court for Cass County initially handled the case, where the first trial ended in a mistrial due to a hung jury. Following this, the State filed a motion to change the venue, citing concerns about pretrial publicity and the difficulty of seating an impartial jury in Cass County. The district court granted the motion, and the second trial was held in Pottawattamie County, where Dorsey was convicted. Dorsey appealed the decision, challenging the change of venue among other issues.The Iowa Supreme Court reviewed the case and concluded that the district court abused its discretion by granting the State's motion for a change of venue without attempting to seat a second jury in Cass County. The court emphasized that the district court should have used the voir dire process to assess potential juror bias before deciding to move the trial. The court found that the pretrial publicity was not sufficiently pervasive or inflammatory to justify the venue change without this step. Consequently, the Iowa Supreme Court reversed Dorsey's conviction and remanded the case for a new trial in Cass County. View "State of Iowa v. Dorsey" on Justia Law

Orange City passed an ordinance requiring periodic inspections of rental properties. If entry for inspection is refused, the ordinance allows the city inspector to seek legal remedies, including obtaining an administrative search warrant. Certain owners and renters of rental units challenged the ordinance, claiming it violated article I, section 8 of the Iowa Constitution because it did not require the city to show traditional probable cause before seeking a warrant.The Iowa District Court for Sioux County ruled in favor of the challengers, declaring the ordinance's mandatory inspection requirement unconstitutional and enjoining the city from seeking administrative warrants under the ordinance. The court awarded nominal damages to the plaintiffs.The Iowa Supreme Court reviewed the case and disagreed with the lower court's ruling. The court noted that in a facial challenge, the challenger must prove that the ordinance is unconstitutional in all its applications. The court found that there are scenarios where the ordinance could operate constitutionally, such as when traditional probable cause is present, when non-warrant legal remedies are pursued, or when inspections are conducted by certified third-party inspectors, exempting the property from city inspections. Therefore, the facial challenge could not succeed.The Iowa Supreme Court reversed the district court's decision and remanded the case for further proceedings consistent with its opinion. The main holding was that the ordinance's inspection regime could operate constitutionally in certain circumstances, thus the facial challenge to the ordinance failed. View "Singer v. City of Orange City" on Justia Law

Artell Young, a federal supervised releasee, was subject to a search condition allowing federal probation officers to search his person, vehicle, or home upon reasonable suspicion of contraband or release condition violations. After receiving information that Young was dealing drugs and possessing a firearm, federal probation officers searched his home, finding small amounts of crack cocaine, powdered cocaine, and marijuana. The federal authorities turned the case over to Iowa authorities, leading to Young's conviction on several drug offenses.In the Iowa District Court for Polk County, Young moved to suppress the evidence from the search, arguing it violated the Fourth Amendment and article I, section 8 of the Iowa Constitution. The district court upheld the search, citing the "special needs" exception under both the Fourth Amendment and article I, section 8. The court also noted that the search was conducted by federal officers under federal standards, thus not subject to Iowa constitutional standards. Young was convicted by a jury of three counts of possession of a controlled substance and sentenced to six years in prison.The Iowa Supreme Court reviewed the case, focusing on whether the search violated article I, section 8 of the Iowa Constitution. The court held that the constitutionality of the search should be evaluated by the law of the sovereign that conducted the search—in this case, federal law. The court affirmed the district court's decision, concluding that the search was lawful under federal standards and that the evidence obtained was admissible in the state prosecution. The court rejected Young's claim of an illegal search and affirmed his convictions. View "State of Iowa v. Young" on Justia Law

On the night of October 9, 2021, Wichang Chawech was at a bar in Des Moines with friends. After altercations between his friends and other patrons, Chawech pulled out a 9 mm pistol and fired a shot, grazing a man's jaw and fatally wounding a woman. Chawech was charged with first-degree murder, attempted murder, willful injury causing serious injury, and intimidation with a dangerous weapon. He pleaded not guilty and raised defenses of justification, self-defense, and defense of others. The jury found him guilty of lesser included offenses for the first two counts and the charged offenses for the latter two counts. They also found that he was in possession of a dangerous weapon during the offenses.The Iowa District Court for Polk County sentenced Chawech to consecutive terms for counts I, III, and IV, totaling twenty-two years, with a mandatory minimum of ten years due to the dangerous weapon enhancement under Iowa Code section 902.7. The court ordered the sentence for count II to run concurrently. Chawech appealed, arguing insufficient evidence, improper merger of counts II and III, and an illegal mandatory minimum sentence due to the enhancement not being charged in the trial information.The Iowa Court of Appeals affirmed the convictions and sentences, except for agreeing that counts II and III should merge. They vacated the sentence for count II and remanded for an appropriate order. Chawech sought further review, focusing on the sufficiency of evidence and the mandatory minimum sentence.The Iowa Supreme Court reviewed the case, focusing on the mandatory minimum sentence. They concluded that the challenge to the sentencing enhancement was an illegal-sentence challenge, not subject to error preservation principles. However, they found that the trial information and jury instructions met the requirements of Iowa Rule of Criminal Procedure 2.6(6) and the U.S. Constitution. Thus, the mandatory minimum sentence was upheld. The court affirmed the decision of the Court of Appeals in part, vacated in part, and remanded the case for further proceedings consistent with their opinion. View "State of Iowa v. Chawech" on Justia Law