Justia Iowa Supreme Court Opinion Summaries

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

The Supreme Court reversed the judgment of the district court concluding that Defendants discriminated against prospective tenants in violation of municipal law by steering prospective tenants of a protected religion or national origin away from their rental properties, holding that there was insufficient evidence against Defendants under the proper jury instruction.The Des Moines Civil and Human Rights Commission brought this action alleging that Defendants, a husband and wife who owned rental properties together, engaged in housing discrimination. The jury found the husband was liable for steering and imposed a civil penalty of $50,000 against him. The Supreme Court reversed and remanded for dismissal of the steering charge against the husband, holding that the district court's instructions misled the jury to the husband's detriment. View "Des Moines Civil & Human Rights Comm'n v. Knueven" on Justia Law

The Supreme Court affirmed Defendant's convictions for two counts of possession of a controlled substance with intent to deliver and two counts of failure to possess a tax stamp, holding that the district court did not err in denying Defendant's motion to suppress.Officers entered Defendant's apartment without a warrant over the objections of the occupants. They then obtained a search warrant, finding evidence resulting in criminal charges. Defendant filed a motion to suppress, arguing that the initial warrantless entry was unconstitutional. The district court denied the motion, concluding that the search was justified under the emergency aid doctrine. The Supreme Court affirmed, holding that the emergency aid doctrine permitted the police officers' entry into the residents to render emergency aid to a possible shooting victim hidden inside. View "State v. Youm" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of operating a motor vehicle while intoxicated, second offense, harassment of a public official, and interference with official acts, holding that the district court did not err in denying Defendant's motion to suppress.Defendant was out drinking when his wife called him. When Defendant arrived home, his wife had been arrested for child endangerment and was handcuffed in a squad car. Knowing Defendant was agitated, the followed him inside his home where a social worker was interviewing three children in her investigation of child endangerment. At issue was whether the police needed a warrant to enter the home to protect the social worker. The Supreme Court affirmed, holding that the officers' warrantless entry under these exigent circumstances did not violate Defendant's rights pursuant to the Fourth Amendment or Iowa Const. I, 8. View "State v. Torres" on Justia Law

The Supreme Court reversed the decisions of the district court and employment appeal board affirming the decision of the department of workforce development denying Appellant's claim for unemployment benefits, holding that Appellant's claims on appeal were unavailing.Appellant, an apprentice electrician, attended a week-long training as part of his apprenticeship curriculum, and his employer didn't pay him for that week. Appellant filed a claim for unemployment benefits under Iowa Code 96.4(3), arguing that he met the statute's criteria that he be able to work, available for work, and actively seeking work. The department of workforce development denied the claim, and the employment appeal board and district court affirmed. The Supreme Court affirmed, holding that the board's decision that Appellant had not established his eligibility for benefits was not an erroneous interpretation of the law, unsupported by substantial evidence in the record, or an abuse of the board's discretion. View "Dornath v. Employment Appeal Bd." on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Plaintiff's claims against Defendants for wrongful termination, workplace harassment, and age discrimination, holding that the district court properly granted summary judgment on all claims.Plaintiff, an at-will employee, was promptly fired after he texted his plant manager "FUCK You!" and "Believe who and what you want" following the manager's criticism of his job performance. In response to Plaintiff's complaint, Defendants moved for summary judgment on the grounds that Plaintiff was lawfully fired for insubordination. The district court granted summary judgment in favor of Defendants. The Supreme Court modified the McDonnell-Douglas burden-shifting framework for summary judgment on discrimination claims under the Iowa Civil Rights Act to align with the causation standard at trial and adopted and applied the good-faith "honest believe rule" to affirm Defendant's decision to terminate Plaintiff's employment for insubordination. View "Feeback v. Swift Pork Co." on Justia Law

The Supreme Court affirmed Defendant's conviction of murder in the first degree, holding that Defendant was not entitled to relief on his allegations of error.In 2019, police charged Defendant with murder in the first degree for a murder committed in 1979. The charges were based on the results of a DNA test that was performed on a drinking straw that the police retrieved from an eating establishment where Defendant had eaten. A jury found Defendant guilty and sentenced him to prison. The Supreme Court affirmed, holding (1) the district court did not err by denying Defendant's motion to suppress evidence about DNA that police found on the straw that Defendant discarded or to analyze DNA attached to the straw; (2) the district court did not abuse its discretion by declining to give an instruction regarding federal sentencing law; and (3) the evidence was sufficient to support Defendant's conviction. View "State v. Burns" on Justia Law

The Supreme Court reversed in part the judgment of the court of appeals affirming the district court's dismissal of the medical malpractice action brought by the Estate of Roberta Butterfield against Chautauqua Guest Home, Inc., a nursing home, holding that the Estate was not required to serve a certificate of merit affidavit on Chautauqua in this case.While the Estate brought its action it did not serve a certificate of merit on Chautauqua. Chautauqua filed a motion to dismiss the claims against it with prejudice under Iowa Code 147.140. The district court granted the motion, and the court of appeals affirmed the dismissal of the Estate's claims. The Supreme Court reversed in part, holding (1) the certificate of merit requirement set forth in section 147.140 does not apply to plaintiffs who need experts solely for causation, as opposed to the standard of care or breach; and (2) remand was required to establish which of the Estate's claims survived the failure to file the certificate of merit. View "Estate of Butterfield v. Chautauqua Guest Home, Inc." on Justia Law