Justia Iowa Supreme Court Opinion Summaries

In this appeal from the court of appeals' decision affirming a default judgment in a foreclosure case the Supreme Court held that, when a defendant is known to be represented by a lawyer, a plaintiff must send a copy of the notice of intent to the defendant in addition to the defendant's lawyer.Plaintiff in this case served a foreclosure lawsuit on an attorney that Plaintiff argued held himself out as Defendant's lawyer in the foreclosure suit. The attorney filed an acceptance of notice on Defendant's behalf, but no one filed any response to the petition. The district court entered a default judgment against Defendant. The Supreme Court reversed and remanded the case, holding (1) Iowa R. Civ. P. 1.972(3) required Plaintiff in this case to mail notice of intent to both Defendant and Defendant's lawyer; and (2) Plaintiff's failure to comply with the rule's notice provisions left the district court without authority to enter the underlying default judgment against Defendant. View "Lincoln Savings Bank v. Emmert" on Justia Law

The Supreme Court vacated Defendant's convictions for sexual abuse in the second degree, holding that the district court erred by giving the jury asymmetrical, particularized noncorroboration instructions focusing on the victims' testimony, requiring a new trial.After a jury trial, Defendant was convicted of two counts of sexual abuse and sentenced to a total of thirty-five years. The court of appeals reversed, holding that while the evidence was sufficient to support the convictions the noncorroboration instructions were improper, requiring a new trial. The Supreme Court granted the State's application for further review and affirmed the court of appeals' remand for a new trial, holding (1) the State presented sufficient evidence to support the convictions; but (2) the noncorroboration instruction given to the jury in this case improperly gained the jury's consideration of the victims' testimony, and the error was prejudicial. View "State v. Ross" on Justia Law

The Supreme Court denied motions sought by Appellants to dismiss their misdemeanor cases on the ground that their no-bond arrest warrants, arrest, and subsequent temporary detentions were unlawful, holding that the district court did not act illegally in denying Appellants' respective motions to dismiss the assault charges filed against them.A magistrate issued arrest warrants for Appellants on charges of simple misdemeanor assault relating to an incident occurring during a business meeting. Appellants were arrested and detained overnight. Appellants made their initial appearances the next morning, posted $100 cash bond, and were released. Appellants then moved to dismiss their cases, but the district court denied their motions to dismiss. The Supreme Court affirmed, holding that there was no basis for dismissing the indictments. View "Howsare v. Iowa District Court for Polk County" on Justia Law

In this interlocutory appeal in a case involving claims for injuries resulting from a high-speed chase, the Supreme Court reversed the decision of the district court denying the State's motion for summary judgment, holding that the State was entitled to summary judgment under Iowa Code 321.231.Law enforcement officer Brett Tjepkes was chasing Scott Grimes, the perpetrator of a multi-state crime spree, when Grimes crashed head-on with another vehicle. Amber Martinez, the sole occupant of the car he hit, suffered serious injuries. Martinez brought suit, alleging that the Officer Tjepkes acted negligently, causing her injuries. The State moved for summary judgment, arguing that Tjepkes could not be held legally liable as the cause of the crash. The district court denied the motion, finding that a disputed issue of fact existed as to whether Tjepkes's actions were reckless. The State brought this interlocutory appeal. The Supreme Court reversed, holding that no reasonable jury could find that Tjepkes's decision to pursue Grimes was reckless. View "Martinez v. State" on Justia Law

The Supreme Court reversed the decision of the district court refusing to quash subpoenas that required production of documents and testimony for use in a Louisiana products liability lawsuit, holding that the subpoenas imposed undue burdens on Dethmers Manufacturing Company, an Iowa firm.The plaintiff in the products liability used Iowa's interstate discovery procedures to serve subpoenas on Dethmers, who was not a party to the Louisiana suit. The subpoenas required Dethmers to produce twenty-two categories of documents and testimony that were "extraordinarily broad." After Dethmers unsuccessfully moved to quash the subpoenas Dethmers brought this appeal. The Supreme Court reversed and remanded for entry of an order quashing the subpoenas, holding that the subpoenas were overly burdensome on their face and should be quashed. View "In re Subpoena Issued to Dethmers Manufacturing Co. v. Mittapalli" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment in favor of Defendant and dismissing Plaintiff's claim that Iowa's tax-sale statute violates due process because it doesn't require personal service of a written notice that the taxpayer will lose his or her land, holding that the court did not err.Plaintiff stopped paying property taxes on a parcel of farm land he obtained, and the parcel was sold at a tax sale. Defendant paid Defendant's overdue taxes and received a certificate of purchase. When Plaintiff did not redeem the parcel Defendant sent Plaintiff notice by regular mail and certified mail to the parcel itself and to Plaintiff's last known address. After ninety days the county treasurer issued a tax sale deed to Defendant. Plaintiff brought this action claiming he did not timely receive actual notice of the tax sale proceedings and that Iowa Code 447 violates constitutional due process guarantees because it does not require effective notice. The district court granted summary judgment for Defendant. The Supreme Court affirmed, holding that Plaintiff failed to show a due process violation in this case. View "Kluender v. Plum Grove Investments, Inc." on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for voluntary manslaughter, holding that the circuit court committed no instructional error or constitutional violation in the underlying proceedings.On appeal, Defendant argued, among other things, that the district court erred in instructing the jury on a "stand your ground" defense, which confused the jury about his actual justification defense. The Supreme Court affirmed, holding (1) Defendant was not entitled to relief on his argument that the stand-your-ground defense wasn't in play, and thus that the stand-your-ground instruction was erroneously given; and (2) including the term "illegal activity" in the instructions did not violate Defendant's right to due process. View "State v. Ellison" on Justia Law

The Supreme Court vacated the decision of the court of appeals reversing the order of the district court granting summary judgment in favor of Wapello County in this property dispute, holding that the district court correctly concluded that the parties' agreement allowed the County to remove a group of vehicles on Landowners' property.Landowners were operating a vehicle repair and salvage business on residential property in Wapello County when the County notified Landowners of its' intent to clean up the alleged nuisance. The parties entered into a settlement agreement, under which Landowners agreed to allow the County to enter the property to remove any remaining "derelict vehicles" to the "satisfaction of the County" at the expiration of ninety days. At the conclusion of the ninety-day period, the County had the vehicles remaining on the property removed. Landowners brought this lawsuit, alleging breach of the agreement. The district court granted summary judgment for the County. The Supreme Court affirmed, holding (1) an objective standard applied to the County's determination of its satisfaction under the agreement; and (2) the removal of the vehicles did not breach that objective standard. View "McNeal v. Wapello County" on Justia Law

The Supreme Court reversed the judgment of the court of appeals modifying a dissolution decree to award a payee spouse seven years of transitional spousal support, holding that, under the circumstances, the court of appeals erred in modifying the decree to award transitional spousal support.Rachael and David Sokol married in 2002 and had two children. In 2019, Rachael petitioned for dissolution of the marriage. As to spousal support, the district court ordered Rachael to pay David $3,000 per month in rehabilitative spousal support for four years. After the district court entered its decree David appealed, arguing, as relevant to this appeal, that the length of the marriage warranted traditional, rather than rehabilitative, spousal support. As to spousal support, the court of appeals modified David's award from rehabilitative support at $3,000 per month for four years to transitional support at $5,000 per month for seven years. The Supreme Court reversed the court of appeals' modification of the district court's spousal award and reinstated the original award, holding that the modification of the decree was inconsistent with caselaw regarding both the category and duration of spousal support. View "In re Sokol" on Justia Law

The Supreme Court reversed the district court's ruling granting Defendant's motion to suppress statements she made during a custodial interview, holding that some deception by law enforcement in this case did not exceed what the legal system tolerates.Defendant's husband died of strangulation after being zip-tied in a chair in his residence. Defendant claimed that her husband had tied himself up. During an interview at the police station, police officers told Defendant falsely that doctors were still working to save her husband's life. An hour and half into the interview the officers corrected their deception. The officers also made various reassurances and suggestions to the woman. The trial court granted Defendant's motion to suppress. The Supreme Court reversed, holding (1) the officers' lie about whether her husband had been pronounced dead did not affect Defendant's essentially knowing and voluntary waiver of her Miranda rights; and (2) the officers' expressions of sympathy did not amount either to express or implied promises of leniency that would create a fair risk of a false confession. View "State v. Park" on Justia Law