Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction of one count each of willful injury and intimidation with a deadly weapon, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that the district court erroneously denied his motion to dismiss because the State charged him more than one year after the three-year statute-of-limitations period was over. In response, the State argued that the district court correctly determined that the statute of limitations tolled between May 25, 2016 and September 21, 2020. The Supreme Court agreed with the State, holding that the district court correctly found that the statute of limitations tolled during the relevant period because Defendant was not publicly resident in Iowa. View "State v. Boone" on Justia Law

The Supreme Court vacated Defendant's sentence and remanded this case for resentencing, holding that the district court imposed an illegal sentence by choosing not to impose the requirements set forth in Iowa Code 124.401(5)(f).Pursuant to a plea agreement, Defendant pleaded guilty to possession of methamphetamine, third or subsequent offense, a class D felony, in violation of section 124.401(5). At the sentencing hearing, Defendant asked that he be sentenced to a fine. The State responded that a fine alone would be an illegal sentence under Iowa Code 901.5. The district court orally sentenced Defendant to the minimum fine only. The State filed a motion to correct an illegal sentence. The Supreme Court vacated the sentence, holding that the district court's fine-only sentence was illegal because, in choosing not to impose probation subject to random drug testing and at least a suspended sentence of the minimum forty-eight-hour term of imprisonment required under section 124.401(5)(f), the sentence lacked statutory authorization. View "State v. Iowa District Court for Woodbury County" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of sexual abuse in the third degree, holding that Defendant was not entitled to reversal of his convictions on his allegations of error.The court of appeals affirmed Defendant's convictions but concluded that the trial court lacked jurisdiction to enter a nunc pro tunc order attempting to correct Defendant's sentence and remanding the case for the district court to correct the sentence. The Supreme Court affirmed, holding (1) the State presented sufficient evidence to support the jury's finding that Defendant was previously convicted of an act of sexual abuse for purposes of the sentencing enhancement; (2) the district court did not err in overruling Defendant's challenge brought under Batson v. Kentucky, 476 U.S. 79 (1986); and (3) any error in the court's decision to excuse a juror for cause did not prejudice Defendant. View "State v. Booker" on Justia Law

The Supreme Court affirmed as modified the judgment of the district court denying Defendants' motion to dismiss Plaintiffs' claims of open records violations, holding that Iowa's Open Records Act, Iowa Code chapter 22, may permit Plaintiffs to pursue claims based on untimeliness and that the district court did not err in granting Defendants' motion to dismiss.In 2020 and 2021, Plaintiffs requested public records from Defendants. Plaintiffs brought this suit in December 2021, and in January 2022, Defendants provided responsive records. Defendants filed a motion to dismiss, arguing that the timeliness claims were moot. The district court denied the motion. The Supreme Court affirmed as modified, holding (1) most of the claims concerning production of already-produced records were moot; and (2) with some qualifications, Plaintiffs could pursue claims that Defendants violated chapter 22 through delays in responding to Plaintiffs' open records requests. View "Belin v. Reynolds" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment to Defendants as to some of Plaintiff's claims and the judgment entered on the defense verdicts on Plaintiff's remaining defamation claims, holding that Plaintiff had not shown grounds for reversal.Plaintiff, the former principal at St. Joseph's Catholic School, brought this action against Father Josephs Pins, St. Joseph's Church, and the Diocese of Des Moines after her employment was terminated, alleging fraud and defamation by all defendants and breach of contract against Father Pins. The district court granted summary judgment in favor of Defendants as to Plaintiff's fraud, breach of contract, and defamation claims, and then a jury returned defense verdicts on the remaining defamation claims. The Supreme Court affirmed, holding that Plaintiff was not entitled to reversal on his allegations of error. View "Konchar v. Pins" on Justia Law

The Supreme Court affirmed the judgment of the district court refusing to certify Appellant's case as a class action, holding that, based on the facts and circumstances of this case, the district court did not abuse its broad discretion.Appellant, a horse breeder and owner, brought this putative class action claiming that Prairie Meadows Racetrack and Casino, Inc. breached contracts governing the distribution of winnings among owners and breeders of successful horses. The district court ultimately denied certification. The Supreme Court affirmed, holding that there was no abuse of discretion in the district court's determination that Appellant was not an appropriate class representative and that certification was inappropriate. View "Benda v. Prairie Meadows Racetrack & Casino Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's motion to correct an illegal sentence, holding that the district court did not err in denying Appellant's motion.After a jury trial, Appellant was convicted of domestic abuse assault, third offense. The district court sentenced Appellant to an indefinite period of incarceration not to exceed five years and also imposed a mandatory minimum sentence under Iowa Code 902.13. Appellant filed a motion to correct an illegal sentence, which the district court denied. Appellant then filed a petition for a writ of certiorari, raising for the first time the argument that his sentence was illegal because he was not convicted of a third domestic abuse assault, third offense. The district court denied the motion. The Supreme Court affirmed, holding that Appellant was not entitled to relief. View "Anderson v. Iowa District Court" on Justia Law

The Supreme Court affirmed the rulings of the district court and court of appeals that the workers' compensation commissioner erred in granting Employer's motion for summary judgment and dismissing Employee's review-reopening petition, holding that Employee was permitted to pursue a claim for a permanent injury in a review-reopening proceeding despite an earlier adjudication that her injury was not permanent.Employee was injured during the course and work of her employment. Employee filed a petition seeking workers' compensation for a permanent disability, but the deputy commissioner refused to order additional benefits beyond those that Employer had already paid. Employee filed a petition for review-reopening with the workers' compensation commission. The commission determined that Employee's claim for permanent disability benefits was barred by principles of res judicata. The district court reversed, and the court of appeals affirmed. The Supreme Court affirmed, holding that the agency erred in dismissing Employer's review-reopening petition. View "Green v. North Central Iowa Regional Solid Waste Authority" on Justia Law

The Supreme Court affirmed the judgment of the district court reversing the decision of the workers' compensation commissioner denying the claim filed by the husband of a deceased employee for burial expenses and death benefits as the surviving spouse, holding that the district court did not err.Approximately two and a half years into her marriage Wife left her marital home with Husband, accepted a job in a different city, and moved in with a family friend. Husband and Wife never divorced. Wife was subsequently permanently and totally disabled as a result of a work injury and was awarded workers' compensation benefits. Four years later, Wife died from an overdose. Husband filed a claim for burial expenses and death benefits as the surviving spouse. Employer/Insurer denied the claim. The commissioner upheld the denial, concluding that Husband had willfully deserted Wife without any fault by her and thus was not entitled to benefits under Iowa Code 85.42(1)(a). The district court reversed. The Supreme Court affirmed, holding that there was not substantial evidence to support the commissioner's finding that Husband deserted Wife without fault by her under section 85.42(1)(a). View "Blasdell v. Linnhaven, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court denying the state auditor's application to enforce a subpoena against the Iowa Communities Assurance Pool (ICAP), holding that ICAP is not a governmental subdivision over which the state auditor has statutory authority.To facilitate a reaudit of ICAP, a local government risk pool organized as an unincorporated nonprofit association under Iowa Code 670.7, the state auditor issued a subpoena to ICAP for certain financial records. Because ICAP supplied some, but not all, of the requested records the state auditor applied to the district court to enforce the subpoena and obtain the remainder of the documents. The district court denied the application, concluding that ICAP was not subject to the state auditor's authority because it was not a "governmental subdivision" within the meaning of Iowa Code 11.1(1)(c) and thus was not subject to the state auditor's authority. View "Auditor of State v. Sand" on Justia Law