Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court concluding that Defendant was not entitled to a new trial after the Supreme Court remanded the case with instructions for the district court to hold a hearing under Iowa R. Evid. 5.412, holding that the district court did not abuse its discretion.After a jury trial, Defendant was found guilty of assault with intent to commit sexual abuse toward K.S. and other crimes and sentenced to a term of imprisonment. On appeal, Defendant argued that the district court erred by failing to conduct a rule 5.412 hearing before deciding whether to exclude evidence that K.S. had previously made false allegations of sexual abuse. The Supreme Court reversed and conditionally remanded with directions for the district court to conduct an in camera rule 5.412 hearing. On remand, the district court held a hearing and declined to grant a new trial. The Supreme Court affirmed, holding that the district court did not abuse its discretion by concluding that Defendant had failed to prove that K.S. had made prior false claims of sexual abuse. View "State v. Trane" on Justia Law

In this case stemming from a commercial lease dispute between Landlord and Tenant the Supreme Court held that both parties breached the lease agreement but that only the tenant's breach was material.At issue in this case was which party was first to materially breach the lease agreement at issue and whether the other's material breach discharged either party's obligations to perform under the agreement. The district court ruled for Landlord on breach of contract claims and awarded her damages. On reconsideration, the district court determined that Landlord materially breached the lease and reduced her damages. The Supreme Court reversed, holding (1) both Tenant and Landlord breached the commercial lease; (2) Tenant's breach was material, and Landlord's breach was not; and (3) Tenant's material breach suspended Landlord's duty to perform during a cure period, and once that period ended, Landlord's duty to perform was discharged. View "Dolly Investments, LLC v. MMG Sioux City, LLC" on Justia Law

The Supreme Court held that In re T.H., 913 N.W.2d 578 (Iowa 2018) applies only to juvenile sex offenders whose cases are prosecuted and resolved in juvenile court and declined Defendant's invitation to apply its holding to a juvenile offender who is prosecuted and convicted in district court.At age seventeen, Defendant confessed to sexually abusing three children. Defendant was convicted on four class B felony counts and, at age twenty, was sentenced to terms of imprisonment. The court suspended the prison sentences, placed Defendant on probation, and imposed the special sentence of lifetime parole applicable to class B felonies under Iowa Code section 903B.1. The court further required Defendant to register as a sex offender under Iowa Code 692A.103(1). Defendant appealed, arguing that it is unconstitutional under In re T.H. to require a juvenile to register as a sex offender. The Supreme Court reversed in part, holding (1) In re T.H. does not apply to juvenile sex offenders prosecuted in district court; (2) registration under chapter 692A is not part of the "sentence" that can be suspended under section 901.5(13); and (3) Iowa Code 901.5(13) allowsed the district court to suspend Defendant's Iowa Code 903B.1 special sentence in whole or in part. View "State v. Hess" on Justia Law

The Supreme Court affirmed Defendant's conviction of robbery in the first degree and felony murder with robbery in the first degree serving as the predicate felony, holding that the district court did not err or abuse its discretion.During the course of a robbery, Defendant beat Jeremy McDowell, who was high on methamphetamine, with a bat. McDowell died of a cardiac arrhythmia either during or immediately after the beating. On appeal from his convictions, Defendant argued that did not intend to cause McDowell's death, and therefore, the evidence was insufficient to convict him. The Supreme Court affirmed, holding (1) there was substantial evidence supporting the district court's verdict; (2) the evidence was sufficient establishing Defendant caused McDowell's death; and (3) the district court did not manifestly abuse its discretion in denying Defendant's motion for a new trial. View "State v. Stendrup" on Justia Law

The Supreme Court reversed Defendant's conviction for second-degree sexual abuse, holding that Defendant's constitutional right to a public trial was violated when the trial court closed his trial during the COVID-19 pandemic.Defendant was set to stand trial on felony charges in March 2020, but his trial was repeatedly rescheduled due to COVID. The district court ultimately concluded that allowing anyone in to attend Defendant's trial, including his family and friends, violated COVID protocols previously set by the Supreme Court. The district court also rejected the option of live-streaming the trial. The jury subsequently convicted Defendant of second-degree sexual abuse. The Supreme Court reversed, holding that the district court's exclusion of all members of the public from Defendant's trial violated Defendant's constitutional rights, requiring a new trial. View "State v. Brimmer" on Justia Law

In this interlocutory appeal, the Supreme Court reversed the decision of the district court ordering certain records produced to Plaintiff in discovery before trial, holding that the district court erred by relying on civil discovery rules to compel production of the records at issue.Plaintiff's daughter was killed in a motorcycle accident. Plaintiff brought a tort action against the driver of the motorcycle and settled without subpoenaing the county sheriff's investigative reports. After a criminal investigation and prosecution of the driver was complete Plaintiff brought this enforcement action under Iowa Code chapter 22 against the county sheriff's department seeking to obtain its complete investigation file. The district court ordered the records produced to Plaintiff in discovery before trial without ruling on their confidentiality. The Supreme Court reversed, holding that the district court erred in compelling disclosure of the sheriff's investigation materials to Plaintiff's counsel. View "Vaccaro v. Polk County" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court convicting Defendant of first-degree burglary, first-degree robbery, assault causing serious injury while participating in a public offense and willful injury causing serious injury, holding that remand was required for entry of an order merging Defendant's conviction for willful injury causing serious injury with first-degree robbery.The court of appeals primarily affirmed the judgment of the district court but agreed with Defendant that his conviction for willful injury causing serious injury merged with his conviction for first-degree robbery. The Supreme Court affirmed, holding (1) the district court's rulings were all correct except as to Defendant's merger claim; and (2) a defendant's prior conviction for vehicular homicide by reckless driving under Iowa Code 707.6A(2) is a "crime of similar gravity" to a forcible felony for purposes of applying the sentencing enhancement set forth in Iowa Code 902.11. View "State v. Bloom" on Justia Law

The Supreme Court held that a spouse’s permanent disability suffered during the parties’ marriage may be considered when determining a traditional spousal support award, even if the length of the parties’ marriage does not quite meet the typical durational threshold.Jason and Erinn Mills married in 2006. Later that year, Erinn was injured while giving birth to the parties' only child, leading to her becoming permanently disabled. Jason filed for divorce in 2019. At issue on appeal was whether the fact that one spouse acquires a permanent disability during the marriage can support an award of spousal support when the length of the marriage would not otherwise support a traditional support award. The Supreme Court held (1) a court may appropriately consider a spouse's permanent disability acquired during the parties' marriage as a factor when determining a child support award; and (2) Erinn should be awarded traditional spousal support of $400 per month, but the amount should not increase upon the termination of Jason's child support obligation. View "In re the Marriage of Mills" on Justia Law

The Supreme Court vacated the decision of the court of appeals reversing the decision of the district court affirming the Polk County assessor's original tax valuation of two large corporate office buildings in downtown Des Moines at $87,050,000 and $44,910,000, holding that the district court did not err by relying on the Board's expert appraisers when it affirmed the assessor's valuation.Nationwide Mutual Insurance Co., the owner of the buildings at issue, protested the valuation, and the Polk County Board of Review upheld the valuation. The district court affirmed the assessment after hearing appraisers appointed by both the Board and Nationwide as expert witnesses and finding the Board's experts more reliable. The court of appeals reversed and reduced the assessments. The Supreme Court vacated the appellate court's decision and affirmed the judgment of the district court holding (1) there was no basis to reject the district court's determination about the relative reliability of the expert witness testimony; and (2) the Board met its burden to prove that the valuation was not excessive. View "Nationwide Mutual Insurance Co. v. Polk County Board of Review" on Justia Law

The Supreme Court affirmed the judgment of the district court in favor of the State, the Iowa Department of Corrections, and the director of the Iowa Department of Corrections (collectively, Defendants) and against Plaintiff on his claims of employment discrimination, holding that Plaintiff's constitutional claims failed.Plaintiff sued Defendants under the Iowa Civil Rights Act. On the morning of trial, Plaintiff objected to the composition of the jury venire, arguing that the jury venire did not represent a fair cross section of the community. The district court denied the challenge, ruling that the fair-cross-section requirement does not apply to civil jury trials. Thereafter, the jury found that Plaintiff failed to prove any of his claims. On appeal, Plaintiff argued that the Fifth and Seventh Amendments of the United States Constitution require that civil juries be drawn from a fair cross section of the community. The Supreme Court affirmed, holding that Plaintiff's federal claims failed. View "Savala v. State" on Justia Law