Justia Iowa Supreme Court Opinion Summaries

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

The Supreme Court affirmed Defendant's conviction of possession of a controlled substance under Iowa Code 124.401(5), holding that there was no error in the proceedings below.When Defendant was pulled over by an Iowa trooper for speeding she provided the trooper with a current Patient Medical Marijuana Registry Identification Card issued by the Arizona Department of Health Services, which allowed her to legally purchase and possess a limited amount of marijuana for medical use in Arizona. The registry card required a written certification completed by a licensed Arizona physician, but the certification was not provided to the trooper. On appeal from her convictions, Defendant challenged the district court's determination that the registry card and written certification were not a valid prescription or order and barring their admissions during trial. The Supreme Court affirmed, holding (1) the district court properly excluded from evidence the registry card and written certification because they were not a valid prescription or order; and (2) Defendant was not entitled to relief on her remaining allegations of error. View "State v. Middlekauff" on Justia Law

The Supreme Court reversed the ruling of the Iowa Business Specialty Court denying Appellants' motion to dismiss this action involving a shareholder's challenge to a corporate merger involving the purchase of a publicly traded company's shares in a "going private transaction," holding that Appellee's claims must be dismissed.Appellee, a shareholder, brought this action alleging that Appellants, the corporation's directors, breached their fiduciary duties by agreeing to a flawed merger process that resulted in an unsatisfactory price for the minority shareholders' stock. Appellants filed a motion to dismiss, arguing that Appellee failed to plead around the statutory defenses available to the directors. The business court denied the motions to dismiss filed by Appellants. The Supreme Court reversed, holding that Appellant's allegations were insufficient to establish "intentional infliction of harm on the corporation or the shareholders" by the directors. View "Meade v. Christie" on Justia Law

The Supreme Court affirmed the decision of the court of appeals and the district court judgment convicting Defendant of murder in the first degree, holding that a verdict-urging instruction did not improperly coerce the jury verdict.Specifically, the Supreme Court held (1) a jury instruction that explains reasonable doubt in terms of "hesitate to act" is legally adequate, but because the inclusion of "hesitate to act" language was not legally required in this case the district court did not abuse its discretion by refusing to add the discretionary instruction; and (2) the verdict-urging instruction given in this case lacked content that this Court had previously disapproved of, but the jury was not improperly coerced by the court's verdict-urging instruction. View "State v. Davis" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the order of the district court granting Defendant's motion to suppress evidence of drugs seized following a pat-down, holding that law enforcement's conclusion that Defendant possessed drugs met the bar to establish probable cause.The district court concluded that the officer's inability to discern the type of the drugs in the packaging before removing them from Defendant's pocket required suppression of the evidence. The court of appeals reversed, determining that the evidence was sufficient under the plain-feel exception to the warrant requirement that Defendant believed the package contained heroin, powder cocaine, or crack cocaine, despite not knowing which one. The Supreme Court affirmed, holding that the evidence established probable cause for the officer to have arrested Defendant for drug possession. View "State v. Hunt" on Justia Law