Justia Iowa Supreme Court Opinion Summaries

Regena Strable, a marketing director at Altoona Nursing and Rehabilitation Center, injured her left ankle at work, leading to permanent partial disability. This injury caused further physical injuries to her hip and lower back, as well as mental injuries such as post-traumatic stress disorder and anxiety. Strable had previously suffered carpal tunnel injuries to both wrists a decade earlier. After settling with her employer for the ankle injury and the sequela injuries, Strable sought benefits from the Second Injury Fund of Iowa based on her prior carpal tunnel injuries.The deputy commissioner denied Strable’s request for benefits from the Fund, concluding that Iowa Code section 85.64 imposes liability on the Fund only when the second injury is limited to a scheduled injury. The Iowa Workers’ Compensation Commissioner disagreed and granted benefits. On judicial review, the Iowa District Court for Polk County reversed the Commissioner’s decision, agreeing with the deputy commissioner that awarding benefits from the Fund would result in double recovery for Strable.The Iowa Supreme Court reviewed the case and reversed the district court’s order. The court held that the Fund is liable under Iowa Code section 85.64 if the first and second qualifying injuries caused a compensable injury to an enumerated member, regardless of whether the injuries caused other non-enumerated or unscheduled injuries. The court found that the Commissioner erred in calculating the Fund’s liability by not including the employer’s liability for the sequela injuries. The case was remanded to the Commissioner for a determination of the amount and timing of the Fund’s liability, consistent with the court’s opinion. View "Second Injury Fund of Iowa v. Strable" on Justia Law

Silvia Cianzio, a retired professor from Iowa State University, filed a lawsuit against the university, the Iowa Board of Regents, and the State of Iowa, alleging wage discrimination in violation of Iowa Code section 216.6A. She claimed that male professors in her department were paid significantly more than female professors, including herself. After conducting a survey on departmental salaries, she discovered that her annual pay was substantially less than that of her male counterparts. She reported these findings to university officials, who dismissed her concerns. Cianzio retired in December 2020 and subsequently filed a complaint with the Iowa Civil Rights Commission (ICRC) in August 2021, followed by a lawsuit in January 2022.The Iowa District Court for Polk County partially granted the university's motion to dismiss, ruling that Cianzio could only seek damages for wage discrimination occurring within the two-year statute of limitations for wage claims, as set forth in Iowa Code section 614.1(8). The court rejected the university's argument that damages should be limited to the 300-day period preceding the filing of her ICRC complaint.The Iowa Supreme Court reviewed the case and reversed the district court's decision. The court held that Iowa Code section 216.15(9)(a)(9) allows a claimant to recover damages for the entire period of wage discrimination, not limited to the two-year statute of limitations or the 300-day period before filing the ICRC complaint. The court emphasized that the statute's language permits recovery for the entire period of discrimination, as long as the complaint is filed within the statutory time frame. The case was remanded for further proceedings consistent with this interpretation. View "Cianzio v. Iowa State University" on Justia Law

An employee, Ashley Koester, worked as a mobile crisis counselor for Eyerly-Ball Community Health Services. She believed she was entitled to overtime compensation for her on-call hours and filled out timesheets accordingly, which were approved by her supervisor. Later, her employer objected to the overtime payments and terminated her employment. Koester sued her employer under Iowa Code chapter 91A and for wrongful discharge in violation of public policy, claiming she was terminated for asserting her right to overtime pay.The Iowa District Court for Polk County dismissed Koester's claims, ruling that she did not have a claim under chapter 91A because she had been paid in full, including for the overtime hours she claimed. The court also found her statutory claim time-barred. Koester appealed, and the Iowa Court of Appeals reversed the dismissal of her public policy claim but affirmed the dismissal of her statutory claim.The Iowa Supreme Court reviewed the case and concluded that Koester did not state a claim for relief under chapter 91A or the common law tort of wrongful discharge in violation of public policy. The court held that chapter 91A is a wage collection law, not a generalized fair practices law, and since Koester did not have a claim for unpaid wages, she was not entitled to relief. The court also determined that Koester's public policy claim failed because she was not engaged in protected activity under the statute, as she did not file a complaint or claim unpaid wages before her termination. The Iowa Supreme Court vacated the decision of the Court of Appeals and affirmed the District Court's judgment dismissing Koester's claims. View "Koester v. Eyerly-Ball Community Mental Health Services" on Justia Law

John Feller was charged in 2011 with lascivious acts with a child and third-degree sexual abuse after his stepdaughter reported abuse. He pleaded guilty to two counts of lascivious acts with a child and was sentenced to concurrent five-year prison terms, a ten-year special sentence, and required to register as a sex offender. Initially, he was informed he needed to register for ten years, but later was told he had to register for life due to a procedural error resulting in two separate case numbers.The Iowa District Court for Dubuque County denied Feller's application to modify his sex offender registration requirements, citing his decision to testify by affidavit, his courtroom demeanor, and letters he sent to his daughter. The Iowa Court of Appeals affirmed this decision.The Iowa Supreme Court reviewed the case and found that the district court abused its discretion by considering improper factors, such as Feller's choice to testify by affidavit and his demeanor. The court noted that Feller had completed sex offender treatment, had no criminal charges since his release, and was evaluated as a low risk to reoffend. The court also found that the letters Feller sent to his daughter, which were sent with permission, did not indicate a risk of reoffense.The Iowa Supreme Court vacated the decision of the Court of Appeals, reversed the district court's judgment, and remanded the case for an order granting Feller's application to end his lifetime registration. The court emphasized that Feller's successful adjustment to the community and low risk of reoffense did not justify the continuation of his registration requirements. View "Feller v. State" on Justia Law

A police officer initiated a traffic stop of Ashlee Mumford because the vehicle's license plate was obscured by dirt and grime. During the stop, a drug detection dog conducted a sniff around the vehicle, briefly touching the passenger door and momentarily breaking the plane of the passenger window. The dog alerted to the presence of controlled substances, leading to a search that uncovered methamphetamine in the glove compartment and marijuana and a methamphetamine pipe in Mumford's purse. Mumford was arrested and charged with possession of methamphetamine, marijuana, and drug paraphernalia. She was acquitted of methamphetamine possession but convicted of marijuana and drug paraphernalia possession.In the Iowa District Court for Madison County, Mumford moved to suppress the evidence obtained from the traffic stop, arguing it violated her constitutional rights against unreasonable searches and seizures. The district court denied her motion, concluding the traffic stop was supported by probable cause and the use of the drug detection dog did not violate the Federal or State Constitution. Mumford was convicted of possession of marijuana and drug paraphernalia following a bench trial.The Iowa Supreme Court reviewed the case and affirmed the district court's decision. The court held that the traffic stop was supported by probable cause due to the obscured license plate, and the use of the drug detection dog did not constitute an unlawful search. The court also found sufficient evidence to support Mumford's conviction for possession of marijuana, rejecting her argument that lab testing was required to prove the substance was marijuana. The court concluded that the district court did not err in denying Mumford's motion to suppress evidence or her motion in arrest of judgment. View "State v. Mumford" on Justia Law

Todd Halbur was terminated from his position as comptroller of the Iowa Alcoholic Beverages Division (ABD). Halbur claimed he was fired in retaliation for reporting to his supervisor, Stephen Larson, that ABD was violating Iowa law by exceeding the 50% markup on liquor sales and for refusing to engage in illegal acts related to a service contract with Beverage Merchandising, Inc. (BMI). Halbur filed a lawsuit against Larson, asserting a statutory claim for wrongful discharge under Iowa Code section 70A.28 and a common law claim for wrongful discharge in violation of public policy. The district court submitted the statutory claim to a jury but dismissed the common law claim, ruling that the statutory claim was the exclusive remedy. The jury awarded Halbur $1 million, which was reduced due to a statutory cap on damages.The Iowa District Court for Polk County dismissed Halbur’s common law wrongful discharge claim, reasoning that the statutory claim under section 70A.28 provided a comprehensive remedy. The court also dismissed the statutory claims against the State of Iowa and ABD, allowing the claim to proceed only against Larson in his official capacity. Larson’s motion for summary judgment was initially granted in part but later reconsidered, allowing the case to proceed to trial. The jury found in favor of Halbur, awarding him damages.The Iowa Supreme Court reviewed the case. Larson argued that Halbur’s internal complaints did not constitute protected disclosures under section 70A.28. However, the court found that Larson failed to preserve this issue for appeal by not raising it during trial through a motion for directed verdict or judgment notwithstanding the verdict. On cross-appeal, Halbur argued that his common law claim should not have been dismissed. The court affirmed the district court’s decision, holding that the statutory remedy under section 70A.28 was exclusive and comprehensive, precluding the need for a common law claim. The court affirmed the judgment of the district court. View "Halbur v. Larson" on Justia Law

Several landowners owned a tract of land near the intersection of a highway and Interstate 35. The Iowa Department of Transportation (DOT) planned to modernize the interchange and condemned a strip of the landowners' property. The landowners anticipated being able to install a commercial entrance to the highway based on prior discussions with the DOT. However, the DOT's formal notice of condemnation indicated that all rights of direct access to the highway would be taken. The landowners filed actions challenging the condemnation after being informed that commercial access would not be allowed.The Iowa District Court for Story County dismissed the landowners' actions as untimely, citing the thirty-day deadline for challenging the exercise of eminent domain authority under Iowa Code section 6A.24(1). The landowners also delayed filing their notice of appeal in the district court, which was filed fifty-seven days after the dismissal order, although it was served on the DOT within twenty-two days.The Iowa Supreme Court reviewed the case and concluded that the delay in filing the notice of appeal was not fatal, as the thirty-five days from service to actual filing was deemed a reasonable time under Iowa Rule of Appellate Procedure 6.101(4). However, the court found that the landowners' challenge to the condemnation was untimely under Iowa Code section 6A.24(1), which requires actions to be commenced within thirty days after service of notice of assessment. The court held that this statute is the exclusive method for challenging the exercise of eminent domain authority and does not allow for exceptions or the application of a discovery rule. Consequently, the Iowa Supreme Court affirmed the district court's dismissal of the landowners' case. View "Brendeland v. Iowa Department of Transportation" on Justia Law

A landowner in Hardin County, Iowa, refused to allow a surveyor for a pipeline developer to enter his private property. The developer, Summit Carbon Solutions, LLC, sought access under Iowa Code section 479B.15, which governs hazardous liquid pipelines. The district court ordered the landowner to allow the surveyor temporary access, rejecting the landowner’s claims that the statute was unconstitutional under the “takings” clauses of the U.S. and Iowa Constitutions and that carbon dioxide in a supercritical state is not a “hazardous liquid.”The Iowa District Court for Hardin County ruled that the statute was facially constitutional and that Summit was a “pipeline company” with access rights under section 479B.15. The court found that Summit had provided proper statutory notice to the landowner and that the landowner’s claim of having a tenant who did not receive notice was not credible. The court granted Summit’s request for injunctive relief to compel access for surveying.The Iowa Supreme Court reviewed the case and affirmed the district court’s judgment. The court held that section 479B.15 is a lawful pre-existing limitation on the landowner’s title, consistent with longstanding background restrictions on property rights, and does not constitute a taking under the Federal or Iowa Constitutions. The court also held that supercritical carbon dioxide is a “hazardous liquid” within the meaning of section 479B.2, making Summit a pipeline company with access rights under the statute. The court found that Summit had complied with the statutory notice requirements and that no additional showing of irreparable harm was required for the injunction. The judgment and injunctive relief granted by the district court were affirmed. View "Summit Carbon Solutions, LLC v. Kasischke" on Justia Law

Graphite Construction Group, Inc. (Graphite) was hired by Des Moines Area Community College (DMACC) in 2019 for a construction project. DMACC withheld 5% of each payment as retainage, amounting to about $510,000 by January 2022. Graphite requested the release of the retainage, but the project was not yet completed. A dispute arose between Graphite and a subcontractor, Metro Concrete, Inc. (Metro), over unpaid services. Metro filed a claim, and Graphite filed a bond for twice the amount of Metro’s claim, demanding the release of the retainage.The Iowa District Court for Polk County denied Graphite’s motion to compel the release of the retainage, stating that under Iowa Code chapter 573, retainage could not be released before the project’s completion and final acceptance. The court also denied Graphite’s request for attorney fees, as Graphite had not prevailed on its retainage claim.The Iowa Court of Appeals reversed the district court’s decision, ordering the release of the retainage to Graphite but denied Graphite’s request for attorney fees. DMACC sought further review from the Iowa Supreme Court.The Iowa Supreme Court vacated the Court of Appeals' decision and affirmed the district court’s judgment. The Supreme Court held that under Iowa Code chapter 573, retainage could not be released before the project’s completion and final acceptance, and the statutory exceptions did not apply in this case. The court also upheld the denial of attorney fees to Graphite, as they were not the prevailing party. View "Rochon Corporation of Iowa, Inc. v. Des Moines Area Community College" on Justia Law

Jeffrey Flynn was stopped by Dubuque County Deputy Sheriff Rob Freund for speeding. Freund suspected Flynn was intoxicated after smelling alcohol and hearing Flynn admit to drinking. Flynn performed poorly on field sobriety tests and a preliminary breath test indicated a blood alcohol concentration above the legal limit. Flynn was arrested for operating a motor vehicle while intoxicated (OWI) and transported to the law enforcement center. Freund requested Flynn submit to a chemical breath test without providing a written request or advising Flynn of the consequences of refusal or submission. The test showed a blood alcohol concentration of .110, and Flynn was charged with OWI first offense.The Iowa District Court for Dubuque County granted Flynn’s motion to suppress the chemical breath test evidence. The court reasoned that the statutory requirements for a written request and advisories were mandatory and not followed by Freund. The court concluded that the failure to comply with these requirements rendered the test results inadmissible.The Iowa Supreme Court reviewed the case and affirmed the district court’s decision. The court held that the implied consent statute requires a peace officer to make a written request and provide advisories when requesting a motorist to submit to a chemical test under certain conditions, which were present in this case. The court rejected the State’s argument that the statute was not invoked and that actual consent was sufficient. The court concluded that the failure to follow the statutory procedures rendered the chemical breath test results incompetent for prosecution purposes. The case was remanded for further proceedings consistent with this opinion. View "State of Iowa v. Flynn" on Justia Law