Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed the ruling of the district court that the contractual default interest rate applied in this dispute over the redemption of farmland and affirmed the court of appeals' decision requiring timely full payment of the amount necessary, holding that remand was required in this case.An attorney representing an investor underpaid the amount necessary to redeem farmland by at least $1,798 below the minimum owed. After concluding that the redemption was timely the district court resolved the parties' dispute over the interest rate by ruling that the contract default rate of twenty-one percent controlled, not the 4.25 percent nondefault rate. The court of appeals affirmed the twenty-one percent interest rate but concluded that the attempted redemption was untimely. The Supreme Court affirmed the judgment of the court of appeals and declined to grant equitable relief, holding that the court of appeals correctly held that the attempted redemption failed as untimely. View "Great Western Bank v. Clement" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Petitioners' applications for postconviction relief, holding that Petitioners' challenges to the State's allocation of its resources in the prison system were without merit.Petitioners were several male inmates serving time for sex-related offenses. Due to limits on resources, inmates were eligible for the sex offender treatment program, the completion of which was a requirement to be considered meaningfully for parole, only as the inmate neared his tentative discharge date. Petitioners brought applications for postconviction relief, arguing that this circumstance violated their constitutional due process rights. The district court denied relief. The Supreme Court affirmed, holding that the existing waiting list prioritizing admission to treatment based on tenantive discharge date, was a reasonable way to decide when an offender gets admitted to treatment and that the district court did not err in denying Petitioners' applications for postconviction relief. View "Bomgaars v. State" on Justia Law

The Supreme Court reversed Defendant's conviction of sexual abuse of a child, his granddaughter, holding that the district court erred by excluding evidence that another person, a teenager who testified for the State, sexually abused the victim.On appeal, Defendant argued (1) the Supreme Court should overrule State v. Pearson, 514 N.W.2d 452 (Iowa 1994), which would result in the reversal of his conviction; and (2) the district court erred in applying the "constitutional rights" exception to the rape shield law, Iowa R. Evid. 5.412(b)(1)(C). The Supreme Court reversed, holding (1) this Court declines to overrule Pearson; and (2) excluding Defendant's cross-examination of his granddaughter and the teenager about their relationship violated Defendant's rights under the Confrontation and Due Process Clauses and the constitutional rights exception to the rape shield law. View "State v. Montgomery" on Justia Law

The Supreme Court vacated in part the decision of the court of appeals affirming the district court's ruling that Iowa Code chapter 411 ordinary disability benefits are marital property, holding that chapter 411 ordinary disability benefits replace income that an individual would have earned if not for an injury causing the disability and should be treated as income rather than as property.The district court entered a dissolution decree dissolving the marriage of Matt and Karri Miller. The district court determined that Matt's chapter 411 ordinary disability benefit was marital property subject to division. The court of appeals affirmed. At issue before the Supreme Court was whether Matt's future disability benefit was income or property. The Supreme Court vacated in part the court of appeals' decision and let the rest of the court of appeals' opinion stand on the remaining issues, holding that Matt's future disability benefit is a replacement for income and not part of the marital pot to be divided upon dissolution. View "In re Marriage of Miller" on Justia Law

The Supreme Court affirmed in part and vacated in part the decision of the court of appeals affirming Defendant's conviction and sentence, holding that the district court erred in allowing the State to amend the trial information one week prior to the day of trial.The State charged Defendant with, among other offenses, assault causing bodily injury. One week prior to trial, the State moved to amend the trial information to charge Defendant with willful injury causing bodily injury. The district court allowed the amendment, concluding that the elements were substantially similar and the underlying facts remained the same. Defendant was subsequently found guilty. The court of appeals affirmed. The Supreme Court reversed in part and remanded the case for further proceedings, holding the court of appeals erred in relying on State v. Brisco, 816 N.W.2d 415 (Iowa Ct. App. 2012), to conclude that the charge of willful injury causing bodily injury was not wholly new and different from assault causing bodily injury. View "State v. Vandermark" on Justia Law

The Supreme Court affirmed the order of the district court reversing the Iowa Board of Medicine declaratory order interpreting Iowa Code 272C.6(4)(a) as allowing the Board to publish statements of charges and press releases containing investigative information, holding that the district court did not err.The Board filed a statement of charges against Dr. Domenico Calcaterra accusing him of a "pattern of disruptive behavior and/or unethical or unprofessional conduct" and published the statement of charges against Dr. Calcaterra, along with a press release, on the Board's website. Several years after the parties reached a settlement, information about the allegations against Dr. Calcaterra remained available on the Board's website. Dr. Calcaterra filed a petition for declaratory order with the Board challenging that Board's ongoing dissemination of investigative information. The Board denied the challenge. The district court set aside the Board's order, holding that section 272.6(4)(a) prohibited the disclosure of the investigative information. The Supreme Court affirmed, holding that the Board incorrectly interpreted section 272C.6(4)(a) and that investigative information cannot be released to the public in a statement of charges or a press release when there has been no underlying final decision in the disciplinary proceeding. View "Calcaterra v. Iowa Board of Medicine" on Justia Law

The Supreme Court vacated Defendant's conviction of assault while using or displaying a dangerous weapon, holding that the district court erred in allowing the State to amend the trial information on the day of trial.The State filed a trial information charging Defendant with assault causing bodily injury. On the first day of trial, the State moved to amend the charge of assault causing bodily injury to assault while using or displaying a dangerous weapon. The district court allowed the amendment, and a jury found Defendant guilty of the amended charge. The Supreme Court reversed, holding that the amended trial information charged a wholly new and different offense within the meaning of Iowa R. Crim. P. 2.4(8)(a), and the district court erred in allowing the amendment. View "State v. Allen" on Justia Law

The Supreme Court reversed Defendant's conviction of sexually abusing his seven-year-old daughter, K.W., holding that the trial court erred by admitting videos of two forensic interviews in which K.W. described the abuse and the admission was not harmless error.Defendant was convicted of sexual abuse in the second degree, enticing a minor, and indecent exposure. On appeal, Defendant argued that the forensic interview videos involving K.W. and played for the jury were inadmissible hearsay and did not fall within any exception to the hearsay rule. The Supreme Court agreed and remanded the case for a new trial, holding that neither interview was admissible under the Court's hearsay rules and that the error was not harmless. View "State v. Skahill" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the juvenile court's permanency order transferring sole legal custody of the child in this case to Father, holding that there was convincing evidence to show that the child could safely be transitioned to Mother's care at the time of the permanency hearing.The State initiated a child-in-need-of-assistance proceeding due to the parents' inability to coparent. At the time, Mother was the primary custodial parent. Mother participated in services to reunify with the child and showed progress, but the juvenile court determined it was not safe to return the child to Mother's home and entered a permanency order transferring sole legal custody of the child to Father. The court of appeals reversed. The Supreme Court affirmed, holding that there was convincing evidence to show the child could safely be transitioned to Mother's care at the time of the permanency hearing. View "In re D.M." on Justia Law

The Supreme Court conditionally affirmed Defendant's convictions of three misdemeanor drug offenses and remanded this case for further proceedings, holding that remand was required for the district court to apply the standard set forth in State v. Wright, 961 N.W.2d 396 (Iowa 2021).Last term, in Wright, the Supreme Court held that law enforcement officers conducted an unconstitutional seizure and search when they seized and searched garbage bags left out for collection without first obtaining a warrant. In the instant case, Defendant argued that a sheriff's deputy violated his constitutional rights by seizing and searching his trash without first obtaining a warrant. The Supreme Court conditionally affirmed Defendant's convictions and remanded the case for the district court to hold a hearing on Defendant's motion to suppress evidence without consideration of the evidence obtained during the trash pull. View "State v. Kuuttila" on Justia Law