Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the district court granting Employer's motion to dismiss a petition for judicial review as untimely, holding that the district court correctly dismissed Claimant's petition for judicial review.Claimant sustained a work injury and pursued workers' compensation benefits. The workers' compensation benefits ordered Employer to pay temporary total disability benefits related to Claimant's right extremity injury but rejected Claimant's claim that she had also sustained a right shoulder occupational injury. According to Iowa Code 17A.19(3), Claimant had thirty day to file a petition for judicial review. Claimant's attorney failed to file the petition by the deadline. When the attorney realized his oversight, Claimant filed a petition for judicial review. The district court dismissed the petition as untimely. The Supreme Court affirmed, holding that the district court did not err. View "Askvig v. Snap-On Logistics Co." on Justia Law

The Supreme Court reversed the ruling of the district court affirming the decision of the Public Information Board that the Polk County Assessor violated the Open Records Act by refusing to disclose a list of property owners who asked that their names be removed from the public name search function on the Assessor's website, holding that a statutory exemption applied.A reporter sought the list at issue, and the Assessor withheld it as exempt from disclosure under Iowa Code 22.7(18). Thereafter, the reporter filed a complaint with the Board, which ordered the Assessor to disclose the list. The district court affirmed. The Supreme Court reversed and remanded the case, holding (1) the Assessor had the burden to establish that the list was exempt under section 22.7(18); and (2) the Assessor met that burden, showing that the list is confidential, subject to resolution of an open issue. View "Ripperger v. Iowa Public Information Board" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court denying Defendant's application for postconviction relief, holding that there was no error.Defendant pleaded guilty to child endangerment resulting in death. The court imposed an indeterminate sentence of up to fifty years with immediate parole eligibility. Defendant later filed the instant application for postconviction relief, alleging that counsel provided ineffective assistance in giving parole advice and in failing to object to an in-chambers proceeding. The district court denied the application. The Supreme Court affirmed, holding that Defendant failed to show that her plea counsel breached an essential duty or that she was prejudiced by the in-chambers proceeding. View "Sothman v. State" on Justia Law

The Supreme Court affirmed the order of the juvenile court terminating Father's parental rights to his child, holding that the juvenile court did not err in terminating Father's parental rights.The juvenile court concluded that the State proved the grounds for termination and terminated Father's parental rights. Father's counsel filed a motion for belated appeal, which the Supreme Court granted. The Supreme Court then affirmed, holding that the State proved by clear and convincing evidence that the bases for termination under both Iowa Code 232.116(1)(3) and 232.116(1)(h) were satisfied and that no exceptions in Iowa Code 232.116(3) applied to preclude the termination. View "In re W.T." on Justia Law

The Supreme Court vacated the decision of the court of appeals reversing Defendant's convictions of possession of methamphetamine with intent to deliver and possession of marijuana, holding that the court of appeals made three legal errors in reviewing the jury's verdict.After the jury considered the evidence and arguments at trial it found Defendant guilty of all charges. The court of appeals reversed, concluding that the conviction was not supported by substantial evidence. The Supreme Court vacated the court of appeals' decision, holding that the court (1) misstated the law of possession; (2) relied upon a long-rejected distinction between direct-evidence and circumstantial-evidence cases in concluding that there was insufficient evidence to establish Defendant was in constructive possession of controlled substances; and (3) improperly reasoned that the convictions were the result of an impermissible stacking of inferences. View "State v. Jones" on Justia Law

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