Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the district court affirming the conclusion of the workers' compensation commissioner that Claimant's rotator cuff injury was a scheduled shoulder injury rather than an unscheduled whole body injury under Iowa Code 85.34(2), holding that there was no error.Claimant sustained a work-related injury that was diagnosed as a "full thickness rotator cuff tear that has retracted to the level of the glenoid, severe AC arthrosis, tendonitis and tearing of the biceps tendon." In seeking permanent partial disability benefits, Claimant argued that her injury qualified as an unscheduled injury to the body as a whole, entitling her to industrial disability benefits. The commissioner concluded that Claimant's rotator cuff injury was a scheduled injury to the shoulder, and the district court affirmed. The Supreme Court affirmed, holding that the district court properly determined (1) Claimant's rotator cuff injury was a scheduled shoulder injury under Iowa Code 85.34(2)(n); and (2) substantial evidence supported the commissioner's finding that Claimant failed to prove her biceps tear resulted in a permanent disability to her arm under section 85.34(2)(m). View "Chavez v. MS Technology LLC" on Justia Law

In this criminal action, the Supreme Court affirmed the ruling of the district court on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury, holding that Defendant's conviction of second-degree murder stands.On appeal, Defendant, an African-American, argued that his right to an impartial jury under the United States Constitution had been violated because his jury pool contained only two African-Americans, one of whom was later excused. The Supreme Court made refinements to how a defendant must prove a fair-cross-section constitutional violation and remanded the case to give Defendant an opportunity to develop his impartial-jury arguments. On remand, the district court rejected Defendant's further-developed claims. The Supreme Court affirmed, holding that the district court did not err in ruling on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury. View "State v. Williams" on Justia Law

In this criminal action, the Supreme Court affirmed the ruling of the district court on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury, holding that Defendant's conviction of two counts of murder in the first degree and one count of attempted murder stands.On appeal, Defendant, an African-American, argued that his right to an impartial jury under the United States Constitution had been violated because, although his jury pool contained five African-Americans, the jury that decided his case contained no African-Americans. The Supreme Court made refinements to how a defendant must prove a fair-cross-section constitutional violation and remanded the case to give Defendant an opportunity to develop his impartial-jury arguments. On remand, the district court rejected Defendant's further-developed claims. The Supreme Court affirmed, holding that the district court did not err in ruling on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury. View "State v. Veal" on Justia Law

The Supreme Court affirmed the judgment of the district court imposing a six-day jail sentence and ordering Defendant to pay restitution costs for operating a motor vehicle while her license was barred as a habitual offender, holding that there was no error.On appeal, Defendant challenged the district court's discretion to sentence her to jail and the constitutionality of the sentence, arguing that the court (1) improperly considered her financial situation in imposing the jail sentence over Defendant's requested sentence of a fine or probation, and (2) erred by ordering restitution for court costs and court-appointed attorney fees under recent legislation codified in Iowa Code chapter 910. The Supreme Court affirmed, holding (1) the district court properly evaluated all of the facts before imposing jail time instead of a fine or probation; and (2) Defendant waived any challenges to the court's finding that she had a reasonable ability to pay court costs and court-appointed attorney fees. View "State v. McCalley" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court denying Employer's motion for a new trial and motion for judgment notwithstanding the verdict following a jury trial on Employee's claims of sex and gender identity discrimination and dismissing Employee's claims against a third-party administrator on summary judgment, holding that the court erred in part.Specifically, the Supreme Court (1) reversed the district court's denial of Employer's motion for judgment notwithstanding the verdict and dismissed the jury's verdict as to Employee's sex discrimination claims, holding that the district court erred in submitting the sex discrimination claim to the jury; (2) affirmed the jury's verdicts as to employee's gender identity discrimination claims; (3) affirmed the jury's damages award in favor of Employee in the full amounts that the jury entered; and (4) affirmed the district court's grant of summary judgment in favor of Employer. View "Vroegh v. Iowa Department of Corrections" on Justia Law

The Supreme Court affirmed Defendant's conviction, rendered after a second jury trial, of second-degree murder, holding that Defendant was not entitled to relief on her allegations of error.Over twenty-five years after the murder in this case, a woman told a cold-case investigator about a murder confession she witnessed as a girl from Defendant. Defendant was ultimately charged with and convicted of murder. The Supreme Court affirmed, holding (1) as to Defendant's argument that the prosecution failed to timely disclose that certain evidence had been determined unsuitable for standard DNA testing, Defendant could have sought DNA testing prior to trial but chose not to do so, and Defendant may still pursue specialized DNA testing in a postconviction proceeding; (2) the twenty-six year delay in prosecution did not prejudice Defendant's ability to make her case, and there was no bad faith on the part of the prosecution; (3) the district court did not err in allowing the jury to scrutinize the credibility of witnesses; and (4) there was sufficient evidence for the jury to find Defendant guilty of second-degree murder. View "State v. Cahill" on Justia Law

The Supreme Court vacated Defendant's convictions for three counts of sexual abuse in the second degree, holding that an erroneous jury instruction prejudiced Defendant's rights.At issue was the district court's instruction to the jury that "[t]here is no requirement that the testimony of an alleged victim of sexual offenses be corroborated." The Supreme Court vacated Defendant's convictions, holding (1) substantial evidence supported the jury's verdict that Defendant committed sexual abuse against B.T. and L.S., and Defendant's remaining attacks on the sufficiency of the evidence were unavailing; but (2) the district court committed reversible error when it gave the jury instruction at issue, and the remaining instructions did not cure the error. View "State v. Mathis" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the judgment of the district court concluding that Plaintiff's filed petition did not relate back to her previously rejected filing, holding that the district court did not err in granting Defendants' motion to dismiss.Plaintiff filed this personal injury suit against Defendants one day after the two-year statute of limitations set forth in Iowa Code 614.1(2). Defendants filed a motion to dismiss the petition on the grounds that Plaintiffs' claims were time-barred. In response, Plaintiff argued that her untimely petition related back to the date she attempted to file her petition but the clerk of court rejected it due to Plaintiff's failure to include personal identification information with the proposed filing. The district court dismissed the action, concluding that the filed petition did not relate back to the rejected filing. The court of appeals affirmed. The Supreme Court affirmed, holding that Plaintiff's filing did not relate back to her attempted filing. View "Carlson v. Second Succession, LLC" on Justia Law

The Supreme Court affirmed Defendant's convictions but vacated his sentence and remanded the case for resentencing by a different judge, holding that the prosecutor breached the parties' plea agreement by failing to recommend a suspended sentence in the manner required by precedent.Defendant pleaded guilty pursuant to an Alford plea to lascivious acts with a child and indecent contact with a child. The court, without mentioning the plea agreement or the State's recommendation, sentenced Defendant to a combined seven-year prison sentence that was not suspended. Defendant appealed, but the court of appeals dismissed the appeal. The Supreme Court affirmed Defendant's convictions and vacated his sentence, holding (1) the court of appeals erred by dismissing Defendant's appeal for lack of jurisdiction; and (2) the prosecutor breached the plea agreement by not actually recommending that the district court suspend the sentences. View "State v. Davis" on Justia Law

The Supreme Court further modified a hybrid traditional and rehabilitative alimony award that the court of appeals modified in this case, holding that this Court hereby adopts transitional alimony as another tool to do equity in calculating spousal support.In this divorce action, the district court entered a decree dissolving the parties' seventeen-year marriage, ordering shared custody and physical care of the children, and diving the marital property. On appeal, the court of appeals increased the spousal support award and recalculated Husband child support obligation. On appeal, Husband argued that the increase in the spousal support award and duration was excessive and unnecessary. The Supreme Court affirmed the decision as modified, holding that the alimony is modified as to the amount and duration and that this modification required a recalculation of child support. View "In re Marriage of Pazhoor" on Justia Law