Justia Iowa Supreme Court Opinion Summaries

The Supreme Court reversed the order of the district court striking down sections 99 and 100 of House File 766, which added funding conditions prohibiting abortion providers from participating in two federally funded educational grant programs directed at reducing teenage pregnancy and promoting abstinence, holding that any conditions premised on providing abortions cannot be considered unconstitutional.Planned Parenthood of the Heartland (PPH) was a former grantee of both grants and, upon the passage of sections 99 and 100, became ineligible to receive funding. PPH brought a declaratory judgment action arguing that the Act violated its rights to equal protection, due process, free speech, and free association under the Iowa Constitution. The district court granted summary judgment for PPH and enjoined enforcement of the legislative enactments. The Supreme Court affirmed, holding (1) the conditions were rationally related to the classification selected by the general assembly; and (2) where abortion providers have no constitutional right to perform abortions, the unconstitutional conditions doctrine did not prohibit the State form barring abortion providers from receiving the funding at issue. View "Planned Parenthood of the Heartland, Inc. v. Reynolds" on Justia Law

The Supreme Court reversed the ruling of the district court granting summary judgment in favor of the owner of a zip line in this personal injury action, holding that exculpatory clauses purporting to negate liability for acts that are wantonly or recklessly committed generally violate public policy.Mt. Crescent Ski Area contracted with Challenge Quest, LLC to build and install a zip line. When Plaintiff took the zip line an employee had failed to reset the zip line's braking system after the previous rider existed. Consequently, Plaintiff slammed into a wood pole at the base of the zip line and fractured his neck. Plaintiff sued Challenge Quest and Mt. Crescent. The district court granted summary judgment in favor of Challenge Quest, concluding that it owed no duty to Plaintiff because it didn't install the allegedly defective braking system in place when Plaintiff was injured. The district court also granted summary judgment for Mt. Crescent based on a liability waiver that Plaintiff signed before riding. The Supreme Court reversed the summary judgment ruling as to Mt. Crescent, holding that the contractual waiver limiting Mt. Crescent's liability was unenforceable to the extent it purported to eliminate liability for the willful, wanton, or reckless conduct that Plaintiff alleged. View "Lukken v. Century, Inc." on Justia Law

The Supreme Court reversed the judgment of the district court in favor of Plaintiff on his claims of sexual orientation discrimination and retaliation under the Iowa Civil Rights Act (ICRA), Iowa Code 216.1-.21, holding that Defendants were entitled to judgment as a matter of law with respect to all claims, notwithstanding any errors.After Republican Terry Branstad defeated incumbent Democratic Governor Chet Culver Brandstad requested that thirty executive branch officers appointed by prior Democratic administrations each submit a letter of resignation. After Plaintiff refused to resign the Governor reduced his compensation. Plaintiff then brought this suit, alleging sexual orientation discrimination and retaliation and violations of his constitutional right to be paid a particular salary. A jury rendered a verdict in favor of Plaintiff. The Supreme Court reversed, holding (1) the district court erred in denying Defendants' motions for directed verdict and for judgment notwithstanding the verdict with respect to Plaintiff's claims arising under the ICRA; and (2) Plaintiff's constitutional claim failed as a matter of law. View "Godfrey v. State" on Justia Law

The Supreme Court reversed the judgment of the district court concluding that Employer discriminated against Employee by firing him when he sought a reasonable accommodation for a disability, holding that Defendants were entitled to judgment as a matter of law on each of Employee's disability discrimination claims except his claims for failure to accommodate and retaliation based on his request for a sign language interpreter.Employee, who had a preexisting hearing impairment, continued to work while rehabilitating from a workplace injury, and Employer assisted the rehabilitation by providing light-duty work. When a disagreement arose as to whether Employee was entitled to a specific work restriction, Employee was fired. A jury awarded Employee damages after finding that Employer discriminated against him when Employee sought a reasonable accommodation for a disability. The Supreme Court reversed, holding (1) to the extent Plaintiff's disability claims were based on the workplace injury, Plaintiff's failure to identify a job he could perform apart from the temporary light-duty work defeated his claims; and (2) Employer was entitled to a new trial on Employee's disability claims stemming from his request for a sign language interpreter. View "Rumsey v. Woodgrain Millwork, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court and the decision of the court of appeals rejecting a sex offender's challenge to two aspects of his lifetime special parole sentence, holding that there was no error.Defendant pled guilty to one count each of sexual abuse in the third degree, lascivious acts with a child, and indecent contact with a child. Following the revocation of his parole, Defendant returned to prison and filed this application for post conviction relief claiming that his plea counsel his ineffectively for failing adequately to inform him of the rules and requirements of his special sentence. The district court denied the application. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Defendant's plea counsel was not constitutionally ineffective; and (2) Defendant's claim that the parole and ex-offender-treatment-program rules were unconstitutional as applied to him was unavailing. View "Doss v. State" on Justia Law

In this case arising from finance agreements related to the purchase from a third-party vendor of multimedia systems for Defendants' waiting rooms, the Supreme Court affirmed the rulings and judgments of the district court in favor of an Iowa corporation, holding that the district court did not err.NCMIC Finance Corporation and Defendants - hundreds of optometrists, dentists, and their professional associations - entered into finance agreements related to multimedia systems for their waiting rooms. After Defendants stopped making payments under the finance agreements, Defendants brought putative class actions seeking a declaration that the finance agreements were unenforceable. NCMIC then assigned its interests in the finance agreements to PSFS 3 Corporation, who, in turn, filed cases against Defendants seeking to enforce the terms of the finance agreements. The cases were consolidated, and the district court entered judgment for PSFS 3 and awarded damages. The Supreme Court affirmed, holding that there was no error or abuse of discretion. View "PSFS 3 Corp. v. Seidman" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court dismissing Plaintiff's complaint alleging that Defendant, his employer, did not substantially comply with Iowa Code 730.5(15) when it drug tested him and then terminated him after he tested positive for methamphetamine, holding that equitable relief was appropriate based on the facts of this case.After Plaintiff was randomly selected for a drug test the lab technician rejected Plaintiff's first sample for being insufficient. The second sample tested positive for methamphetamine. Following Plaintiff's termination, Defendant sent Plaintiff a letter informing him of the drug test results and his right to get a confirmatory test. Plaintiff then brought this complaint alleging that the letter did not substantially comply with section 730.5. The district court dismissed the petition. The Supreme Court affirmed in part and reversed in part, holding that Defendant failed to substantially comply with section 730.5(7)(j)(1) when it failed to include the cost of a retest in its notice to Plaintiff. View "Woods v. Charles Gabus Ford, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that two of Employer's employees were improperly classified as engaged in safety-sensitive positions so that they should never have been drug tested and were entitled to relief and that two other employees were not aggrieved by Employer's actions in attempting to comply with the statutory requirements, holding that there was no error.Employer in this case amended its drug-testing policy to allow for unannounced random drug testing. Plaintiffs, three employees who tested positive and were terminated and a fourth who failed to provide an adequate sample, brought this action under the civil remedies provision of Iowa Code 730.5 arguing that Employer failed to follow statutory requirements involving workplace drug testing. The district court granted relief to two of the four plaintiffs. The Supreme Court affirmed, holding (1) two of the employees should not have been tested under Employer's testing program and were entitled to relief; and (2) the other two employees were not entitled to relief. View "Dix v. Casey's General Stores, Inc." on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court finding that a 2019 Waterloo "ban the box" ordinance was not preempted, holding that the ordinance was preempted to the extent that it purported to regulate a term and condition of employment.In 2017, the legislature adopted a statute, codified at Iowa Code 364.3(12)(a), that prohibits cities from adopting or administering an ordinance providing for any terms or conditions of employment exceeding or conflicting with state or federal law requirements relating to certain employment issues. In 2019, the City of Waterloo enacted the ordinance at issue, which regulated the time when an employer can inquire into a prospective employee's criminal history. The district court concluded that no part of the ordinance was preempted. The Supreme Court reversed in part, holding (1) the ordinance was preempted to the extent it purported to regulate whether an employer can consider an employee's criminal history at all; and (2) the ordinance was not preempted where it only regulated timing because that was not a term or condition of employment. View "Iowa Ass’n of Business & Industry v. City of Waterloo" on Justia Law

The Supreme Court affirmed in part and reversed in part the ruling of the district court making a "fair value" determination of Plaintiffs' shares in an election to purchase in lieu of dissolution proceeding, holding that the district court erred in determining the fair value of the shares without any discount for transaction costs or built-in gain taxes.This case concerned the three children of Lawrence and Georgia Kassel - Susan Guge, Peggy McDonald, and Craig Kassel. After their parents died, Susan and Peggy (together, Plaintiffs) filed a lawsuit against Craig, Craig's wife, two of Craig's corporations, and Kassel Enterprises, the family farming operation that the parents incorporated. Plaintiffs sought judicial dissolution of Kassel Enterprises under Iowa Code 490.1430(1)(b)(2) and 490.1430(1)(b)(4). Kassel Enterprises elected to purchase Plaintiffs' shares for fair value in lieu of a judicial dissolution of the corporation. Both sides appealed the district court's determination of fair value. The Supreme Court reversed in part, holding (1) remand was required for the court to determine and apply the appropriate deduction of transaction costs to the value of the corporation's assets in setting the fair value of Plaintiffs' shares; and (2) the district court's judgment was otherwise affirmed. View "Guge v. Kassel Enterprises, Inc." on Justia Law