Justia Iowa Supreme Court Opinion Summaries

The Supreme Court of Iowa affirmed the decision of the Court of Appeals and the District Court in favor of the City of Des Moines, in a case brought by Lime Lounge, LLC. Lime Lounge, a bar, challenged a city ordinance requiring it to obtain a conditional use permit (CUP) to operate. After receiving noise complaints, the City revoked Lime Lounge's CUP, which was upheld in a prior appeal. Lime Lounge then challenged the ordinance arguing it was preempted by Iowa Code, violated equal protection and spot zoning prohibitions. The trial court dismissed Lime Lounge's claims and this decision was affirmed by the Court of Appeals.The Supreme Court of Iowa found that the city's ordinance was not preempted by state law. Rather, it was a proper exercise of the city's zoning authority and did not create a separate local alcohol license. The Court also rejected Lime Lounge's equal protection claim, holding that the city had a legitimate purpose in imposing a CUP on specific businesses selling alcohol. Finally, the Court dismissed the claim of illegal spot zoning, as Lime Lounge failed to prove that the city had engaged in such activity. The Court thus affirmed the dismissal of Lime Lounge's challenge to the ordinance. View "Lime Lounge, Inc. v. City of Des Moines, Iowa" on Justia Law

The appellant, Lawrence George Canady III, had been charged with voluntary manslaughter, willful injury causing bodily injury, and assault causing bodily injury due to his involvement in a fatal nighttime shooting incident. He was not the shooter, but the State alleged that he was beating the victim while another person shot the victim. The appellant challenged the admission of a cell phone video recorded prior to the shooting where he and the shooter were seen singing a rap song containing lyrics that seemed to reference the victim. The district court allowed the video, but the court of appeals reversed the decision, remanding for a new trial.Upon further review by the Supreme Court of Iowa, the court found that the district court did not abuse its discretion in admitting the video. It was relevant to the case as it showed the appellant and the shooter jointly voicing a threat, which could counter the appellant's claim that he was unaware of the shooter's intention. The court also found no error in the admission of a Snapchat photo, as it was relevant to showing that the appellant may have been aware that the shooter had a gun and was willing to use it. The court further held that the evidence was sufficient to support the appellant's voluntary manslaughter conviction.The appellant's argument that his sentences for voluntary manslaughter and willful injury causing bodily injury should be merged was rejected as the offenses did not overlap in elements. Moreover, the court found no error in the sentencing court's consideration of the minutes of testimony or in its imposition of consecutive sentences. The Supreme Court of Iowa vacated the decision of the court of appeals and affirmed the appellant's convictions and sentence. View "State of Iowa v. Canady" on Justia Law

In the Supreme Court of Iowa, the case involved David Jackson, who was involved in a car accident that resulted in the death of another motorist. Jackson was convicted of vehicular homicide by operating while intoxicated, reckless driving, leaving the scene of an accident resulting in death, and operating a motor vehicle without the owner’s consent. Jackson appealed on the basis that the court allowed rebuttal evidence of his medical condition, which he claimed caused him to black out and lose control of the vehicle, over his objections that the evidence was hearsay.The Court concluded that the district court had erred in admitting the testimony of an employee of a healthcare vendor who had reviewed some of Jackson’s post-accident medical records. The court found that the testimony was hearsay and did not fall into the business records exception to the hearsay rule because the testimony was about the records, not the records themselves.The Court affirmed Jackson’s conviction for operating a motor vehicle without the owner’s consent, but vacated his convictions for vehicular homicide (OWI), reckless driving, and leaving the scene of an accident resulting in death, and remanded the case for further proceedings. View "State of Iowa v. Jackson" on Justia Law

In this case, the Iowa Supreme Court reviewed a dispute involving property owners David and Jeanie Vaudt and Wells Fargo Bank, which held the mortgage on neighboring property owned by Fredesvindo Enamorado Diaz and Denice Enamorado. The Vaudts had installed a landscaping barrier that encroached on the Enamorado's property. When the Enamorados disputed the boundary, the Vaudts filed a petition to quiet title, claiming boundary by acquiescence and adverse possession. Wells Fargo moved to dismiss the claims, arguing they were time-barred by a one-year statute of limitations related to property transfers by trustees. The district court agreed with Wells Fargo, citing a previous Iowa Supreme Court ruling (Heer v. Thola).The Vaudts appealed, asking the Supreme Court to overrule Heer. They argued their claims arose from the conduct of the Enamorados' predecessors in interest, not the transfer of property by the trustee's deed. The Supreme Court agreed with the Vaudts, stating that Heer incorrectly interpreted the statute of limitations, which applies specifically to claims arising from transfers by trustees, not to all adverse claims. The court overruled Heer, rejecting its broad application of the one-year statute of limitations to boundary-by-acquiescence claims.The court reversed the district court's dismissal of the Vaudts' claims, remanding the case for further proceedings. View "Vaudt v. Wells Fargo Bank, N.A." on Justia Law

A case was brought before the Supreme Court of Iowa involving Kadin Miller, who was convicted of harassment after he posted a video of himself and his ex-girlfriend engaged in consensual sexual intercourse on a pornography website without her consent. This act was done to "annoy" and "get back at" his ex-girlfriend after their relationship ended on bad terms. As a result of his conviction, Miller was sentenced to two years in prison and was required to register as a sex offender. The main issue in the appeal was whether the State proved beyond a reasonable doubt that Miller was required to register as a sex offender pursuant to Iowa Code chapter 692A.Under Iowa law, individuals convicted of any sex offense are required to register as a sex offender if they reside, are employed, or attend school in the state. The law sets forth a comprehensive list of sex offenses that require an offender to register as a sex offender. However, the crime Miller was convicted of, harassment in the first degree, is not a per se sex offense. For non-per se sex offenses, an offender is required to register only if the state proves “beyond a reasonable doubt” to “a judge or jury” that the offense was “sexually motivated.”In this case, the Supreme Court of Iowa concluded that the State did not prove beyond a reasonable doubt that Miller's crime was sexually motivated. The court found that the district court's reasoning did not focus on the relevant statutory inquiry—whether the crime was sexually motivated—and instead focused on whether Miller had a sexual interest in the video. The court also noted that there was no evidence to support the district court's finding that Miller's commission of the crime of harassment was done for the purpose of his own sexual gratification. As such, the Supreme Court of Iowa reversed the district court's finding that Miller's crime was sexually motivated, and therefore, Miller was not required to register as a sex offender. View "State of Iowa v. Miller" on Justia Law

In this case, the Supreme Court of Iowa upheld the conviction of the defendant, Sydney Leiann Slaughter, for gambling and making a false claim of winnings. The defendant falsely claimed that she won a slot machine jackpot of $4,000 when her boyfriend was the actual winner. The court found that there was sufficient evidence to show that the defendant had the requisite intent to defraud and had not made a wager contingent on winning a gambling game. The court also held that expert testimony regarding the definition of a "wager" was admissible, and found that the lower court’s error of admitting reference to case law in the expert’s testimony was harmless. The Supreme Court of Iowa affirmed the decision of the Court of Appeals in part and vacated it in part, ultimately affirming the judgment of the District Court. View "State of Iowa v. Slaughter" on Justia Law

The Supreme Court of Iowa was asked to consider whether the Iowa Constitution supports a legislative privilege that protects legislators from compelled production of documents related to legislation. The court concluded that the Iowa Constitution does indeed contain a legislative privilege that protects legislators from compelled document production, particularly in relation to communications with third parties about the legislative process. The case arose from subpoenas served on several Iowa legislators by the League of Latin American Citizens of Iowa (LULAC). LULAC sought discovery of communications related to recent legislative changes to voting procedures. The legislators objected to the subpoenas, arguing they were protected from compelled document production by a legislative privilege under the Iowa Constitution. The court ruled that the privilege extends to communications with third parties where the communications relate directly to the legislative process of considering and enacting legislation. However, the court did not decide whether this legislative privilege was absolute or qualified, as it concluded that the requested documents were not relevant to LULAC's claims and were therefore protected by the legislative privilege, regardless of its extent. The court reversed the district court's judgment granting in part LULAC's motion to compel and remanded with instructions to quash the subpoenas. View "Smith v. Iowa District Court for Polk County" on Justia Law

In Iowa in 2021, a mother of six, Paula Cole, left her five oldest children, ranging in age from 12 to five, asleep at home while she left to go to Walmart for groceries, taking her youngest, an infant, with her. While she was gone, a disagreement arose between two of the children, leading one to leave their apartment building. A neighbor, with whom the family had an open-door policy, helped the children and eventually called 911 due to the disagreement and the child leaving the building. Upon return, Cole was charged with child endangerment. She was convicted and appealed the decision. The court of appeals affirmed the conviction, but Cole sought further review from the Supreme Court of Iowa.The Supreme Court of Iowa reversed the conviction, holding that Cole did not create a risk that violated section 726.6(1)(a), which defines child endangerment as knowingly acting in a manner that creates a substantial risk to a child's physical, mental, or emotional health or safety. The court concluded that while leaving her children home alone could potentially pose risks, these were not risks created by Cole's decision to go shopping, but rather, they were ordinary risks of everyday life. The court also noted that no evidence suggested the home was unsafe, the older children could help care for the younger ones, and a neighbor was available to assist. The court stressed that not all risks children encounter are created by their parents or caregivers, and life inherently poses risks. Additionally, the court stated that a parent does not create a risk if the risk is part of the background risk of ordinary life. View "State of Iowa v. Cole" on Justia Law

In Iowa, the defendant, Jesse Jon Harbach, was involved in a single-vehicle rollover accident. Based on observations at the scene, an officer applied for a warrant to draw blood from Harbach. The test revealed methamphetamine but no alcohol. Harbach moved to suppress the evidence from the blood draw, arguing that the officer's claims of smelling alcohol and observing Harbach with bloodshot eyes and slurred speech were false. The district court agreed, suppressing the evidence. The state appealed, and the Supreme Court of Iowa reversed the decision, stating that the officer's observations of the defendant's physical state and the smell of alcohol were sufficient to establish probable cause for the search warrant. The court held that the officer's affidavit did not contain intentionally or recklessly false statements and the remaining content established probable cause for the issuance of the warrant. View "State of Iowa v. Harbach" on Justia Law

In this case, decided by the Supreme Court of Iowa, Justin Loew, an employee of Menard, Inc., appealed the district court's decision that denied his claim for workers' compensation benefits. Loew had previously received benefits for a 20% functional impairment to his lower back caused by a work-related injury in 2015, which had been calculated using the industrial method and resulted in a 30% reduction in his earning capacity. In 2018, Loew suffered a second work-related injury to his lumbar spine which increased his functional impairment to 28%. Under the 2017 changes to the workers' compensation law, Loew's compensation for this injury was to be based solely on his functional impairment, since he returned to work at the same or greater wages. However, the workers' compensation commissioner denied Loew any additional benefits for his second injury, reasoning that Menard was entitled to offset the prior payment based on reduced earning capacity against the new claim for functional impairment.The Supreme Court of Iowa disagreed with the commissioner's reasoning and reversed the district court's judgment. The court held that it was incorrect to offset compensation based on loss of earning capacity (from the first injury) against compensation based on functional impairment (from the second injury), as these are incommensurables. Further, the court found that the commissioner erred in interpreting Iowa Code section 85.34(7) to preclude compensation for Loew's new permanent partial disability, as this statute only limits an employer's liability for preexisting disabilities that have already been compensated. Loew was seeking compensation for a new permanent partial disability, not a preexisting one, hence Menard was liable for this new disability. The court remanded the case back to the commissioner for further proceedings consistent with its opinion. View "Loew v. Menard, Inc." on Justia Law