Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court convicting and sentencing Defendant but remanded for entry of a nun pro tune order to correct the fine suspended in the written sentencing order to the amount orally pronounced at the sentencing hearing.Pursuant to a plea agreement, Defendant pleaded guilty to several drug offenses. The district court imposed a thirty-year prison sentence with the mandatory minimum reduced by Defendant's guilty plea. On appeal, Defendant argued that the district court failed to consider its discretion for a lower mandatory minimum sentence under Iowa Code 124.413(3) and that there was a discrepancy between the fine stated orally at sentencing and in the written order. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion by imposing the agreed-upon prison sentence; and (2) the fine should be reset through a nunc pro tunc order on remand. View "State v. Wilbourn" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court granting Defendant a new trial at which a key witness associated with missing records would be barred from testifying, holding that the unavailability of the records did not entitle Defendant to a retrial.Defendant was convicted of solicitation to commit murder. At issue on appeal was whether the district court erred in denying Defendant's requests to obtain the privileged counseling records of two of the State's key witnesses on the grounds that the records might contain critical exculpatory information. The court of appeals reversed and remanded with instructions for the district court to review the counseling records. On remand, the two federal agencies believed to have the records refused to turn them over. The district court presumed the records contained exculpatory information and granted Defendant a new trial. The court of appeals reversed and remanded the case. The Supreme Court affirmed, holding that the trial court erred in allocating the discovery burden and ordering a new trial without requiring Defendant to show that he’d exhausted every available avenue to lawfully obtain the medical records for the court to review. View "State v. Retterath" on Justia Law

In this dispute over the just compensation award for commercial property the Supreme Court held that the district court did not abuse its discretion by limiting the testimony of the property owner regarding his opinion testimony that sales of other commercial property were comparable where that opinion required technical or specialized knowledge.An Iowa municipality condemned part of the owner's undeveloped land for a road. The district court allowed the owner to opine as to the site's reduction in value resulting from the taking but barred the owner's evidence of comparable sales on the grounds that the owner relied on hearsay and was unqualified as an expert. The Supreme Court affirmed, holding that the owner, a former restaurant manager, was not qualified as an expert under Iowa R. Evid. 5.702 to offer the opinion testimony given his lack of expertise and the complexity of these commercial real estate valuations. View "Rausch v. City of Marion" on Justia Law

The Supreme Court reversed the district court's grant of summary judgment in favor of Plaintiff in this real estate dispute, holding that Plaintiff offered sufficient evidence to survive Defendants' motion for summary judgment.A few months after purchasing a home Plaintiff discovered water in the basement. Plaintiff later sued the sellers, her real estate agent, the seller's real estate agent, and a home inspector, alleging that they had misrepresented the condition of the house. The district court granted summary judgment for Defendants based on Plaintiff's failure to designate an expert on causation and damages. The court of appeals affirmed. The Supreme Court vacated the opinion of the court of appeals and reversed the summary judgment, holding that expert testimony was not required for Plaintiff to survive Defendants' motion for summary judgment on either causation or damages. View "Putman v. Walther" on Justia Law

The Supreme Court reversed the judgment of the district court granting a tax deed holder possession of disputed property and remanded the case for dismissal, holding that Iowa R. Civ. P. 1.943 barred the tax deed holder's third forcible entry and detainer (FED) action, and the district court erred in concluding otherwise.At issue was Rule 1.943, under which a second voluntary dismissal of a tax deed holder's FED action operates as an adjudication on the merits unless the court orders otherwise. The tax deed holder in this case twice purported to dismiss without prejudice its FED petition against the property owner who was delinquent in paying taxes. The district court allowed the tax deed holder's third FED action to go forward. The Supreme Court reversed, holding that the district court erred by allowing the third FED action to go forward because it involved the same claim as the two prior actions. View "ACC Holdings, LLC v. Rooney" on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment in favor of Insurer in this insurance dispute, holding that summary judgment was properly granted.Insured, which operated a bar and restaurant, made a claim under its commercial property insurance policy for business interruption coverage for the period it closed its business in response to the order of the West Virginia Governor that bars and restaurants shut down in response to the COVID-19 pandemic. Insurer denied the claim. The Supreme Court affirmed, holding (1) the language "direct physical loss of or damage to Covered Property" requires a physical aspect to the property loss before coverage is triggered; and (2) Insured's claim failed under the provision that required actual damage to nearby property. View "Jesse’s Embers, LLC v. Western Agricultural Insurance Co." on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment in favor of an Insurer in this insurance dispute, holding that the mere loss of use of business property did not constitute "direct physical loss of or damage to property" to trigger coverage in this case.Insured, which operated a private golf and country club, made a claim under its all-risk commercial property insurance policy for income it lost during the time it temporarily closed its facilities in compliance with the Governor's 2020 proclamation restricting in-person services at bars and restaurants in response to the COVID-19 pandemic. Insurer denied the claim, and Insured sued. The district court granted Insurer's motion for summary judgment. The Supreme Court affirmed, holding that the mere loss of use of business property does not constitute “direct physical loss of or damage to property” to trigger coverage under the business interruption endorsement to an all-risk commercial property insurance policy like the one at issue in this case. View "Wakonda Club v. Selective Insurance Co. of America" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress and convicting him of possession of methamphetamine, second offense, holding that law enforcement acted reasonably under the Fourth Amendment and Iowa Const. art. I, 8 by ordering Defendant out of the vehicle.Defendant was the passenger in a vehicle that was stopped for speeding. Officers asked Defendant to exit the vehicle in order to facilitate the lawful arrest of the back-seat passenger. Officers then asked if they could check Defendant for weapons. The officer's pat-down revealed a methamphetamine pipe and a baggie containing methamphetamine. Defendant moved to suppress the evidence obtained after the exit order, which the district court denied. The Supreme Court affirmed, holding (1) Defendant's consent was voluntary based on the totality of the circumstances; and (2) the Iowa Constitution does no require that subjects of a search must be informed of their right to decline the search in order for their consent to be voluntary. View "State v. Hauge" on Justia Law

The Supreme Court affirmed the decision of the district court dismissing Plaintiff's professional negligence action against several healthcare providers, holding that the district court properly dismissed the complaint on the ground that Plaintiff failed to file the certificate of merit required by Iowa Code 147.140.Plaintiff filed this action alleging professional negligence, negligent hiring, retention, or supervision of professional staff and other claims. The district court dismissed the petition under section 147.140. The Supreme Court affirmed, holding that Plaintiff exclusively alleged professional negligence claims that fell within the scope of section 147.140, and therefore, the district court correctly dismissed the complaint. View "Struck v. Mercy Health Services-Iowa Corp." on Justia Law

The Supreme Court affirmed the district court's grant of summary judgment for Defendants in this medical malpractice action, holding that Defendants were not estopped from asserting the statute of repose defense, which applied to the facts of this case.In 2004, a benign cyst was detected on Linda Berry's right kidney. In 2009, Dr. Paul Grossman treated Berry for colitis, and a radiologist noted that the mass had grown in size, but no one mentioned this to Berry. In 2016, Berry was treated for renal cancer. Berry died from cancer in 2019. In 2018, Berry filed a medical malpractice action against Defendants for failing to disclose the kidney mass in 2009. Defendants moved for summary judgment based on the six-year statute of repose found in Iowa Code 614.1(9). The district court granted summary judgment for Defendants, rejecting Plaintiffs' reliance on the doctrine of fraudulent concealment to avoid the six-year bar. The court of appeals reversed. The Supreme Court reversed, holding that Berry could not rely on fraudulent concealment to estop Defendants from asserting the six-year statute of repose as a defense to Berry's claims. View "Downing v. Grossman" on Justia Law