Justia Iowa Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the district court denying Hamilton County Public Hospital's motion for summary judgment concerning Plaintiff's defamation claim and Iowa Wage Payment Collection Law (IWPCL) claim, holding that Plaintiff's defamation and statutory wage claims failed.Plaintiff, a general surgeon, was employed by the hospital. After an investigation, Plaintiff's employment through a for-cause provision in his contract was terminated. The hospital subsequently made two reports to the Iowa Board of Medicine and the National Practitioner Data Bank. Plaintiff then brought this action. The hospital moved for summary judgment on the defamation and IWPCL claims, but the district court denied the motion. The Supreme Court reversed on interlocutory appeal, holding (1) Plaintiff's defamation claim failed because the challenged portions of the reports were nonactionable opinions; and (2) Plaintiff's statutory wage claim failed because he did not perform work for which he was not paid. View "Andrew v. Hamilton County Public Hospital" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court concluding that Plaintiffs were not entitled to relief on their contract claim and that Defendant was entitled to a verdict on its counterclaim for breach of contract, holding that judgment was improperly granted on Defendant's counterclaim.Plaintiffs, the owners of a 1931 Chevy, brought this lawsuit against Defendant, a company in the business of restoration of antique vehicles, arguing that Defendant violated certain provisions of the Motor Vehicle Service Trade Practices Act (MVSTPA), Iowa Code chapter 537B and breached its contract with Plaintiffs. Defendant filed a counterclaim alleging breach of contract. The district court concluded that there were no violations of the MVSTPA, that Plaintiffs were not entitled to relief on their contract claim, and that Defendant was entitled to damages on its counterclaim. The Supreme Court reversed the judgment in favor of Defendant on the counterclaim, holding that Defendant violated several provisions of Iowa Code chapter 537B and therefore may not seek to enforce the terms of a contract that was unlawfully formed, but Plaintiffs did not establish actual damages arising from the alleged damages. View "Poller v. Okoboji Classic Cars, LLC" on Justia Law

The Supreme Court dismissed Defendant's appeal challenging the factual basis supporting his guilty plea to a drug offense, holding that Defendant failed to establish good cause to pursue a direct appeal as a matter of right.Defendant pled guilty to three drug-related offenses and was sentenced to an indeterminate term of incarceration. On appeal, Defendant argued (1) there was not a factual basis supporting one of his convictions; (2) his counsel provided constitutionally ineffective assistance; and (3) Iowa Code section 814.6 and 814.7 are unconstitutional. The Supreme Court dismissed the appeal, holding (1) section 814.6(1)(a)(3) is constitutional and governs this appeal; and (2) Defendant did not establish good cause to pursue this appeal as a matter of right. View "State v. Treptow" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing in part the ruling of the district court that Plaintiff was the prevailing party entitled to fees, holding that when a plaintiff recovers less at trial than the amount of a rejected offer to confess judgment, Iowa Code 677.10.bars recovery of the plaintiff's attorney fees incurred after the offer.The parties litigated claims over the breach of a farm lease entitling the "prevailing party" to recover reasonable attorney fees. Plaintiff's presuit demand was $190,564, and Defendant made a pretrial offer to confess judgment for $75,000. Plaintiff rejected the offer. The case proceeded to trial, and the jury awarded Plaintiff just over $41,000. Both sides sought attorney fees, and the district court granted them to Plaintiff. The court of appeals reversed in part, holding that a plaintiff recovering less than the amount of the offer to confess cannot recover postoffer attorney attorney fees that are taxed as costs under Iowa Code 625.25. The Supreme Court affirmed, holding (1) prevailing party contractual fees are considered "costs" when determining the effect of an offer to confess judgment; and (2) Iowa Code sections 677.10 and 625.22 operated together to preclude recover of Plaintiff's attorney fees incurred after it rejected the offer to confess judgment. View "NCJC, Inc. v. WMG, L.C." on Justia Law

The Supreme Court sustained Liquor Bike LLC's petition for writ of certiorari and vacated the district court's order disqualifying Liquor Bike's counsel on the ground that counsel's representation of Liquor Bike in this matter was directly adverse to a current client of counsel's law firm in another matter, holding that the district court abused its discretion.The district court disqualified Liquor Bike's counsel, Billy Mallory and Brick Gentry, P.C., in a boundary-dispute litigation, concluding that Mallory's representation of Liquor Bike violated Iowa Rule of Professional Conduct 32:1.7. Liquor Bike filed a petition for a writ of certiorari challenging the district court's disqualification of its counsel. The Supreme Court sustained the petition, holding that the district court did not subject the motion for attorney disqualification to strict scrutiny and, instead, found a concurrent conflict of interest where none existed. View "Liquor Bike, LLC v. Iowa District Court for Polk County" on Justia Law

The Supreme Court reversed the adjudication of the juvenile court adjudicating Mother's fourth child, A.W., a child in need of assistance (CINA), holding that the State failed to offer clear and convincing evidence that A.W. was at imminent risk of harm from Mother's failure to "exercise a reasonable degree of care in supervising" A.W., as required to support adjudication under Iowa Code 232.2(6)(c)(2).A.W. was born in April 2020. On April 2, 2021, the Supreme Court reversed the termination of Mother's parental rights to her three older children. The juvenile court adjudicated A.W. as a CINA based on two grounds - Iowa Code 232.2(6)(n) and section 232.2(6)(c)(2). The court of appeals reversed the adjudication based on section 232.2(6)(n) but affirmed on section 232.2(6)(c)(2) grounds. The Supreme Court reversed, holding that A.W. should not have been adjudicated CINA, and therefore, the juvenile court erred. View "In re A.W." on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment to Defendants and dismissing Plaintiff's breach of fiduciary and defamation claims, holding that summary judgment was proper.Ryan Koster, a former member of Harvest Bible Chapel (HBC), a nondenominational Christian church, filed suit against HBC and three of its pastors, alleging breach of fiduciary duty, invasion of privacy, defamation, vicarious liability, and conspiracy. The district court granted summary judgment to Defendants as to all counts. Koster appealed, challenging the dismissal of the breach of fiduciary duty and defamation claims. The Supreme Court affirmed, holding that defamation was warranted on these claims. View "Koster v. Harvest Bible Chapel–Quad Cities" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the order of the district court insofar as it modified the rent rates, duration, and for-profit subleasing rights in certain farm leases entered into by a ward's conservator, holding that the court of appeals did not err.After entering into written leases with members of Marvin Jorgensen's family members, Marvin's court-appointed conservator filed a motion seeking direction on whether the farm leases were appropriate. The district court concluded that the leases were inconsistent with Marvin's past practices and reformed them to provide a discount. The court of appeals reversed the ruling as to the reformation of the conservator's farm leases with Marvin's daughter. The Supreme Court affirmed, holding that the court correctly modified the rent rates, duration and for-profits subleasing rights in the daughter's leases. View "In re Guardianship & Conservatorship of Marvin M. Jorgensen" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Appellant's cause of action for unjust enrichment against the State, holding that the district court correctly dismissed the matter as an unlawful collateral attack on Appellant's criminal conviction.Appellant pleaded guilty to speeding in a construction zone. Appellant later filed a lawsuit challenging the authority of Iowa Department of Transportation (IDOT) officers to issue traffic citations and contesting the payments the State collected from fines resulting from convictions on unauthorized IDOT-issued citations. The district court held (1) the IDOT officers, at the time, lacked authority to stop Defendant's vehicle; and (2) Appellant's unjust enrichment claim was an improper collateral attack on his conviction, warranting dismissal. The Supreme Court affirmed, holding that the district court correctly concluded that Appellant's unjust enrichment claim was an improper collateral attack on his speeding ticket conviction. View "Rilea v. State" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court decreeing dissolution of a limited liability company (LLC), holding that, for the most part, the district court properly adjudicated the parties' rights but erred in ordering dissolution of the LLC.Plaintiffs filed suit seeking an order expelling three individuals as members of the LLC, an order dissolving the LLC, an order appointing a receiver for the LLC, and damages for breach of contract, breach of fiduciary duty, economic duress, and civil conspiracy. After a nonjury trial, the district court adjudicated the parties' rights and granted the request to dissolve the LLC based on the impracticability of continuing business. The Supreme Court reversed in part, holding that judicial dissolution should not have been ordered under Iowa Code 489.701(d)(2). View "Barkalow v. Clark" on Justia Law