Justia Iowa Supreme Court Opinion Summaries

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

The Supreme Court reversed the district court's judgment denying Insurer's motion for directed verdict on this action concerning Insurer's alleged delay in paying a claim, holding that the district court erred in denying the motion for directed verdict on Insured's breach of contract and bad faith causes of action.A fire broke out in Insured's kitchen that resulted in a total loss of the building and its contents. Insured invoked its right to the appraisal process. The appraisers signed an appraisal letter establishing the loss amount at $502,000. Insurer paid the amount in full. Eight months later, Insured sued Insurer for breach of contract and bad faith based on Insured's failure to pay the $550,000 building coverage limit and for its actions during the appraisal hearing. The jury returned a verdict in favor of Insured and awarded $48,000 in damages. The Supreme Court reversed, holding (1) Insured's invocation of the appraisal process and Insurer's timely payment of the appraisal award required dismissal of the claims as a matter of law; and (2) Insured failed to prove bad faith for any actions taken after the appraisal hearing. View "Luigi's Inc. v. United Fire & Casualty Co." on Justia Law

The Supreme Court affirmed Defendant's prison sentence, holding that Defendant forfeited any rights to enforce the plea agreement in this case when he breached it.The plea agreement provided that Defendant would plead guilty to third-degree burglary, be released with supervision until sentencing, and be free to argue for probation at sentencing. Defendant, however, absconded after the plea hearing and failed to appear for the sentencing hearing. Defendant was arrested approximately seven months later. Defendant's counsel sought a suspended sentence and probation, and the State advocated for a term of imprisonment. The district court sentenced Defendant to an indeterminate term of imprisonment not to exceed five years. The Supreme Court affirmed, holding that the State did not breach the plea agreement in this case. View "State v. Jordan" on Justia Law

The Supreme Court reversed Defendant's conviction of operating while intoxicated (OWI), holding that Mitchell v. Wisconsin, 588 U.S. __, __, 139 S. Ct. 2525 (2019) (plurality opinion), applies to cases of suspected driving while under the influence of controlled substances, in addition to alcohol-related cases.Defendant caused an accident while driving recklessly. Defendant, who was injured, was taken to the hospital strongly smelling of marijuana. A police officer dispatched to the hospital performed a blood test of Defendant, who was sedated, after a medical professional certified that Defendant was unable to consent or refuse blood testing. Defendant filed a motion to suppress the testing, but the motion was overruled. Defendant appealed, arguing that the warrantless blood draw violated Iowa Code 321J.7, the Fourth Amendment to the federal Constitution, and Iowa Const. art. I, 8. The Supreme Court reversed, holding (1) the State complied with section 321J.7; (2) because the parties did not have an opportunity to make a record under the Mitchell standard, the case must be remanded; and (3) article I, section 8 does not provide greater protection from warrantless blood draws than the Mitchell standard. View "State v. McGee" on Justia Law

The Supreme Court reversed the judgment of the district court granting summary judgment in favor of Mercy Medical Center and dismissing Plaintiffs' suit for the negligent credentialing of Dr. David Segal, holding that the district court erred in dismissing this suit.In its judgment dismissing this suit, the district court concluded that Plaintiffs' negligent credentialing claim was cognizable in Iowa. The Supreme Court reversed, holding that assuming, without deciding, the tort of negligent credentialing is cognizable in the state of Iowa, the district court (1) erred in concluding that Mercy had no duty to exercise reasonable care under the circumstances; and (2) erred in ruling that evidence of prior malpractice suits against Dr. Segal and that expert opinion regarding breach of the standard of care based, in part, on prior lawsuits was inadmissible under Iowa R. Evid. 5.403. View "Rieder v. Segal" on Justia Law

The Supreme Court held that Iowa Code 357A.2 grants cities the primary right to provide water services within two miles of of the city limits that were not already being served by a rural water district.The Supreme Court answered in the affirmative three questions certified by the federal court in this dispute between an Iowa municipality and a rural water district over the right to provide water service to disputed areas within two miles of the city limits. Specifically, the Court held (1) before amendments in 2014, a section 357A.2 rural district did not have a legal right to provide water service to portions of an area described in its county board of supervisors resolution when those portions were also within two miles of the limits of a municipality and when the municipality had not waived its rights to provide water service to the area; (2) section 357.2(4), as amended in 2014, does not exempt a rural water district from following notice-of-intent procedures when the area the district seeks to serve is within the district's boundaries; and (3) a section 504A nonprofit corporation created in 1977 did not have a legal right to provide water service anywhere within the state. View "Xenia Rural Water District v. City of Johnston" on Justia Law

The Supreme Court vacated the judgment of the district court sentencing Defendant to consecutive sentences of incarceration in connection with his plea of guilty to possession of a controlled substance, third or subsequent offense, and driving while barred, holding that the district court improperly speculated that Defendant was working under the influence.The district court accepted Defendant's guilty pleas and proceeded to a sentencing hearing. The district court sentenced Defendant to consecutive sentences of incarceration not to exceed two years for both charges after noting that it was not safe for Defendant to be working in a day care center if he was under the influence. The court of appeals affirmed. The Supreme Court vacated the sentence, holding that the district court's speculation about Defendant working under the influence was improper based on the information it had before it. View "State v. Fetner" on Justia Law

The Supreme Court dismissed Defendant's appeal challenging his guilty plea to theft in the second degree, holding that Defendant's challenge to the constitutionality of new legislation limiting his ability to appeal was unavailing.The legislation at issue limits the ability of a defendant to appeal as a matter of right from a conviction following a guilty plea and directs that ineffective assistance of counsel claims be presented and resolved in the first instance in postconviction relief proceedings. On appeal from his conviction of theft in the second degree Defendant argued that the new legislation violated his right to equal protection of then laws and the separation of powers doctrine. The Supreme Court affirmed, holding that Defendant's constitutional challenges failed. View "State v. Tucker" on Justia Law