Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed in part and vacated in part the ruling of the court of appeals affirming the jury's verdict on libel-per-se damages and punitive damages, holding that remittitur was appropriate in this case.After a jury trial, Hoffmann Innovations, Inc. and Jerry Hoffmann were awarded $11 million in compensatory and punitive damages against Scott Clark based on defamatory statements that Clark made on social media and in podcasts. During the proceedings, the trial court repeatedly sanctioned Clark for violating a consent order preventing both parties from making disparaging statements about each other. Ultimately, the court struck Clark's answer and affirmative defenses in an attempt to secure compliance with sanctions. Without any defense pleaded to the claims, the trial proceeded on only the amount of damages. The Supreme Court reversed in part, holding that the jury used the wrong measure of damages on the damages awarded and that remittitur was also appropriate for punitive damages. View "Hoffman v. Clark" on Justia Law

The Supreme Court reversed the decision of the district court granting summary judgment in favor of Defendants on Plaintiffs' premises liability claims against Alcoa Inc. and on their products liability claims against Iowa-Illinois Taylor Insulation, Inc. (IITI) for supplying asbestos-containing insulation in the Alcoa plant, holding that the district court erred.At issue was the provision in Iowa Code 686B.7(5) that a "defendant in an asbestos action or silica action shall not be liable for exposures from a product or component part made or sole by a third party." In the instant asbestos case, the district court read the statute to limit liability to manufacturers of the asbestos-containing product at issue. The district court held that section 686B.7(5) granted immunity to Alcoa and IITI because the asbestos-containing insulation was manufactured by third parties. The Supreme Court reversed, holding that the district court failed to appreciate the legal significance of the legislature's use of the phrase "produce or component part made or sold by a third party" to reference a products liability defense known as the component parts defense as described in the specific context of asbestos litigation. View "Beverage v. Alcoa, Inc." on Justia Law

Vangen was convicted of criminal mischief in the fourth degree after the prosecution presented alternative theories to the jury—she either used a baseball bat to smash the windows of a car or she drove others to the scene and one of them smashed the windows. She argued that neither was supported by sufficient evidence, but even if one was supported, a 2019 statute requiring the jury’s general verdict to be affirmed as long as one theory was supported violates her constitutional rights (Iowa Code 814.28–prohibiting an appellate court from reversing “a verdict on the basis of a defective or insufficient theory if one or more of the theories presented . . . is sufficient to sustain the verdict on at least one count”). The Iowa Supreme Court affirmed. Both theories presented to the jury were supported by sufficient evidence, so the court declined to address the challenge to Iowa Code section 814.28. View "State of Iowa v. Vangen" on Justia Law

A father going through a contentious divorce was accused by his young daughter of sexual abuse. A Department of Human Services social worker observed the forensic interview, believed it was credible, obtained additional information primarily from the mother, and obtained an ex parte court order requiring the father to leave the family home. An ensuing adversary proceeding determined that the allegation was unfounded and that the mother had “wanted [the father] out of the house.” The DHS finding was set aside and, eventually, the father obtained physical care of the children. In the father's subsequent suit, the district court granted the defendants summary judgment.The Iowa Supreme Court affirmed. The claim of intentional interference with the parent-child relationship fails because that claim applies to extralegal actions— such as absconding with a child—not to judicially-approved acts. The claim for intentional infliction of emotional distress fails because the conduct here did not reach the level of an “outrage” necessary to sustain such a claim. The unreasonable search and seizure claim cannot succeed because there was no showing that the DHS social worker falsified the affidavit she submitted to the court or that the removal order would not have been granted without her questioned statements. The substantive due process claim fails because DHS’s conduct does not “shock the conscience.” A procedural due process claim cannot prevail because the father was provided with adequate process, which ultimately cleared his name. View "Lennette v. State of Iowa" on Justia Law

Pursuant to an arbitration award, American Home paid workers’ compensation benefits to an employee injured in 2008. American did not file a notice before the arbitration that, pursuant to Iowa Code 85.21, it was paying the claim subject to a potential coverage issue. By 2013, American paid all the benefits owed under the arbitration award. In 2016, the employee sought to reopen the case. American then filed a section 85.21 notice seeking reimbursement of benefits paid to the employee, claiming that on the date of injury Liberty Mutual was providing the employer with workers’ compensation coverage.The workers’ compensation commissioner concluded that in order to be entitled to reimbursement, American was required to file section 85.21 notice before the arbitration proceeding and could not, years later, seek to be reimbursed. The district court reversed, reasoning that section 85.21 gave the commissioner broad power to order reimbursement, not time-limited in the statute. The court of appeals, agreeing with the commissioner, reversed. The Iowa Supreme Court agreed. The commissioner may require that insurance carriers obtain a section 85.21 reimbursement order before an evidentiary hearing in order to seek indemnity or contribution from another carrier. The procedural question is not controlled by the substantive provisions of section 85.21. The commissioner has simply established a rule of procedure for handling section 85.21 claims. View "American Home Assurance v. Liberty Mutual Fire Insurance Co." on Justia Law

In 2005, Sandoval was convicted of two counts of first-degree murder and two counts of attempted murder. He was sentenced to serve concurrent terms of life imprisonment without the possibility of parole for the murder convictions and 25 years’ imprisonment for the attempted murder convictions. Sandoval unsuccessfully challenged his convictions on direct appeal and in three different applications for postconviction relief.The Iowa Supreme Court affirmed the dismissal of Sandoval’s fourth application for postconviction relief, which the district court held was barred by the three-year statute of limitations of Iowa Code section 822.3. Sandoval argued that because he was only 19 at the time he murdered two people, his mandatory life sentences without the possibility of parole violated the federal and state constitutional prohibitions against “cruel and unusual punishment.” U.S. Const. amend. VIII; Iowa Const. art. I. The court disagreed. Sandoval’s mandatory sentences of lifetime incarceration without the possibility of parole for committing these offenses are not categorically prohibited by either the Federal Constitution or the state constitution. View "Sandoval v. State of Iowa" on Justia Law

In 1994, Dorsey shot and killed a woman when he was 18 years and five days old. He was found guilty of murder in the first degree and was sentenced to a mandatory term of life in prison without the possibility of parole.In Dorsey’s fifth attempt to obtain post-conviction relief, the Iowa Supreme Court affirmed his sentence, rejecting Dorsey’s argument that the sentence violates his state constitutional right to be free from “cruel and unusual punishment.” He argued the state constitution prohibits imposing a mandatory punishment on a young adult offender and instead requires the district court to hold an individualized sentencing hearing before imposing any sentence and that his life sentence without the possibility of parole is grossly disproportionate to the crime. Considerations of efficiency and certainty require a bright line separating adults from juveniles. There is nothing unique about the facts of this case that raise an inference of gross disproportionality. Dorsey’s willful, deliberate, and premeditated murder of an unarmed woman in her own home justifies the most severe sentence allowed under our law. View "Dorsey v. State of Iowa" on Justia Law

The Supreme Court reversed the order of the juvenile court declining to remove the Iowa Department of Human Services (DHS) as the guardian of certain children, holding that DHS acted unreasonably in failing to send relative notices as to the removal of the children and in failing to serve the children's best interests.The children at issue lived in their stepgrandmother's care for approximately eighteen months after they were adjudicated as children in need of assistance. The parental rights of the children's parents was subsequently terminated by the juvenile court. Later, acting as the children's guardian, DHS entered the children's home on the pretext of a visit and abruptly removed the children from their stepgrandmother's care to place them in foster care with strangers. The children's guardian ad litem filed motions for the immediate return of the children to their step grandmother, for a hearing on modification of placement, and to remove DHS as guardian. The juvenile court declined to remove DHS as the guardian. The Supreme Court reversed, holding that the DHS acted unreasonably by making the sudden change to the children's placement. View "In re K.D." on Justia Law

The Supreme Court reversed the judgment of the district court affirming the decision of the workers' compensation commissioner denying Petitioner's petition for benefits for trauma-induced mental injuries she suffered on the job while working as emergency dispatcher, holding that because Petitioner established that her PTSD resulted from a manifest happening of a sudden traumatic nature from an unexpected cause or unusual strain, Petitioner was entitled workers' compensation benefits.Petitioner, a sixteen-year veteran of the county emergency dispatch system, sought benefits for the PTSD she suffered after taking a 911 call from a woman screaming over and over at a high pitch, "Help me, my baby is dead." The workers' compensation commissioner and district court denied benefits, concluding that the mother's call wasn't an "unexpected cause or unusual strain." The Supreme Court reversed, holding that Petitioner was entitled to benefits because she established that her PTSD resulted from a manifest happening of a sudden traumatic nature from an unexpected cause or unusual strain. View "Tripp v. Scott Emergency Communication Center" on Justia Law

The Supreme Court vacated the decision of the court of appeals reversing the judgment of the district court affirming the decisions of the administrative law judge (ALJ) and the Iowa Department of Transportation (DOT) that good cause existed to permit a franchiser to create dueling franchises in a geographic area under Iowa Code 322A.4, holding that the district court did not err in its judgment.At issue was whether, in considering if the establishment of an additional franchisee in a geographic area is in the public interest, the DOT must consider the investment and impacts across the entire geographic area of the existing franchisee. The ALJ and DOT concluded that the twenty-three county area where the additional franchisee would compete with the existing franchisee was the relevant geographic area to consider when determining the presence of good cause under section 322A.4. The court of appeals reversed, arguing that the relevant geographic area to consider was the entire seventy-one county area in which the existing franchise conducted business. The Supreme Court vacated the decision below and affirmed the trial court, holding that the proper focus was the area in which the existing franchisee and the proposed new franchise would be in direct competition. View "Sioux City Truck Sales, Inc. v. Iowa Department of Transportation" on Justia Law