Justia Iowa Supreme Court Opinion Summaries

Marshall Sandlin, a laborer at Mid American Construction LLC, suffered an injury to his left foot during work. After an initial medical examination conducted by a physician chosen by Mid American's insurance carrier, Grinnell Mutual, Sandlin underwent another independent medical examination (IME) by a physician of his choosing. Sandlin sought reimbursement for the full cost of this second examination, as he believed the first examination's evaluation was too low.The Supreme Court of Iowa had to decide whether an amendment to Iowa Code section 85.39(2) in 2017 limited an employee's reimbursement for an IME to only the cost of the impairment rating or included the full cost of the examination. The court held that the employee is eligible for reimbursement of the reasonable cost of the full examination to determine the impairment rating, not merely the cost of the impairment rating itself. The court interpreted the term "examination" as used in the statute to include review of medical records, physical examination, testing, and written report.However, the court found that the commissioner's analysis of the physician's fee as reasonable was incomplete. While the commissioner considered the physician's written opinion about the reasonableness of his fee, the commissioner failed to analyze the typical fee charged for such an examination in the local area where the examination was conducted, as required by the 2017 amendment to the statute. Consequently, the court remanded the case for further fact-finding on the issue of the reasonableness of the fee based on the typical fee charged in the local area.Thus, the Supreme Court of Iowa affirmed in part and vacated in part the decision of the Court of Appeals and affirmed in part, reversed in part, and remanded the judgment of the District Court. View "Mid American Construction LLC v. Sandlin" on Justia Law

In the Supreme Court of Iowa, the State of Iowa appealed against the district court's dismissal of an extortion charge against Jerome Bailey Sr. Bailey had demanded $10,000 from his former property manager, threatening to expose her for allegedly sending a registered sex offender to his house, which he claimed was a childcare facility. The district court dismissed the charge, concluding that Bailey's threats were made with the reasonable belief that he had a right to make them under Iowa's extortion statute. However, the Supreme Court of Iowa reversed the district court's decision and remanded the case for further proceedings. The court reasoned that the statutory defense in the extortion statute, which allows threats made with a reasonable belief of a right to make them, does not apply automatically at the motion to dismiss stage if there are disputed facts. The court found that whether Bailey had a reasonable belief that he could demand $10,000 for the alleged misconduct was a question for a jury to decide, not a matter for dismissal. View "Iowa v. Bailey" on Justia Law

In the early morning of January 26, 2019, Simranjit Singh was driving a truck on Interstate 80 in Cass County, Iowa, when he hit a cow that had wandered onto the road. Singh was injured and his truck was damaged. The cow, owned by defendant Michael McDermott, was killed. Singh sued McDermott for negligence, claiming that McDermott was negligent in letting his cow wander onto the highway.McDermott moved for summary judgment, arguing that there was insufficient evidence to show that he was negligent. The district court granted McDermott's motion and Singh appealed. The Iowa Court of Appeals affirmed the district court's decision, and Singh sought further review from the Supreme Court of Iowa.The Supreme Court of Iowa affirmed the decisions of the lower courts, noting that the record did not contain sufficient evidence to support a finding of negligence by McDermott. The court clarified that the mere presence of a cow on the highway, without more, does not establish negligence on the part of the cow's owner. The court explained that the common-law duty of cattle owners is a "duty of ordinary care," such as the care an "ordinarily prudent and careful farmer exercises under like circumstances" to keep cows out of the highway.In this case, the court found no direct or circumstantial evidence of negligence on the part of McDermott, noting that there was no evidence of any unmended defects in his fence or that he failed to secure a gate. Singh's contention that the mere presence of the cow on the highway constituted "prima facie evidence" of negligence was rejected as this regime was a product of a now-repealed statute. The court also rejected Singh's reliance on the doctrine of res ipsa loquitur, finding that there was no evidence that a cow would not have escaped "in the ordinary course of things" if McDermott had used reasonable care. View "Singh v. McDermott" on Justia Law

The case concerns Sandra Selden, an employee at the Des Moines Area Community College (DMACC), who alleged that she was a victim of illegal wage discrimination based on sex and wrongful retaliation. Selden discovered that a male colleague was receiving a higher salary for the same job. When her employer did not act on her complaint, attributing the pay gap to the male employee's greater seniority and initial higher salary because of his relevant experience, Selden filed a civil rights complaint. She also applied for a supervisory position, but her application was screened out due to her lack of required educational qualifications. The case went to trial and the jury awarded damages to Selden on both claims. DMACC appealed the decision.The Supreme Court of Iowa reversed the lower court's decision, holding that the record did not contain substantial evidence of an illegal pay practice. The court found that the pay gap was due to gender-neutral factors, specifically a neutral seniority system, and the decision to hire the male employee at a higher rate due to market conditions and his significant experience. The court also found that the retaliation claim was not supported by substantial evidence, as the employer consistently screened out all applicants who lacked the required qualifications. The court concluded that the lower court should have directed a verdict in favor of the defendants and remanded the case for that purpose. View "Selden v. Des Moines Area Community College" on Justia Law

In this case, three chiropractors and their respective business entities sued Wellmark, Iowa’s largest health insurer and claims administrator, alleging that the company violated Iowa antitrust laws through its Administrative Service Agreements with over 400 Iowa employers who self-fund healthcare benefits for their employees. The chiropractors argued that without these agreements, the self-funded employers would compete independently for chiropractic services, resulting in higher profits for chiropractors. The chiropractors filed a motion to certify a class of approximately 1,300 Iowa chiropractors. However, the Supreme Court of Iowa affirmed the district court's decision to deny class certification, concluding that the chiropractors failed to meet the predominance requirement for class certification as they could not prove the threshold issue of antitrust injury on a classwide basis. The court found that proving whether individual chiropractors would be better or worse off without Wellmark’s agreements would require numerous mini-trials, and thus, individual questions predominated over common questions. Additionally, the court applied the doctrine of judicial estoppel to prevent the chiropractors from belatedly reviving a different liability theory that they had previously abandoned to avoid a motion to dismiss. View "Chicoine v. Wellmark, Inc." on Justia Law

This case was heard by the Supreme Court of Iowa and involved an appeal by a defendant, Demetrias Martin, who was challenging the mandatory minimum term imposed with his sentence for first-degree robbery. The main issue in the case was the use of a risk assessment tool that categorized Martin as a "high" risk for violent recidivism and a "moderate/high" risk for continuous victimization. Martin argued that the district court abused its discretion by relying on these conclusions without any information about how the tool actually arrived at them.In March 2019, Martin was sentenced to twenty-five years in prison with a requirement to serve at least 70% of his sentence under a statutory mandatory minimum. After a retroactive amendment to the robbery sentencing statute in June 2019, Martin was eligible for resentencing with a potential mandatory minimum as low as 50%. The amendment required the district court to consider certain factors when determining the mandatory minimum to impose, including a validated risk assessment.The Supreme Court of Iowa affirmed the decision of the lower courts, holding that the district court did not abuse its discretion in considering the results of the risk assessment tool. The court found that Martin had notice of the risk assessment and had the opportunity to challenge it but failed to do so. The court held that a district court does not abuse its discretion by considering risk assessment information in a presentence investigation report where a defendant has notice of the risk assessment and fails to present evidence exposing some actual unsoundness in it. Therefore, the court rejected Martin's argument and affirmed the sentence imposed by the lower court. View "State of Iowa v. Martin" on Justia Law

In this case, the Supreme Court of Iowa addressed whether the district court erred in ordering the placement of a sexually violent predator in a transitional release program over the State’s objection. The State argued that the offender was ineligible for that program without a relapse prevention plan (RPP) accepted by his treatment provider at the Civil Commitment Unit for Sexual Offenders (CCUSO) as required by Iowa Code section 229A.8A(2)(d) (2022). The district court determined that the offender’s plan, approved by the offender’s expert, satisfied that statutory requirement. The State appealed, asserting that the court erred by substituting its judgment for that of CCUSO’s staff.The Supreme Court of Iowa held that a writ of certiorari is the proper form of appellate review, and granted the petition. On the merits, the court held that the district court erred by substituting its judgment for that of CCUSO’s staff. The court agreed with the State that the offender was ineligible for placement in the transitional release program because his treatment provider at CCUSO had not accepted his proposed RPP. The court also rejected the offender's substantive due process claims. Consequently, the court sustained the writ and vacated the district court’s ruling. View "In Re Detention of Schuman" on Justia Law

In the Supreme Court of Iowa, the case involved a dispute between divorced parents who held joint legal custody of their children. The parents disagreed on whether their children should receive the COVID-19 vaccine. The mother filed an application for vaccination determination after unsuccessful mediation, seeking the district court's authorization to vaccinate the children. The district court dismissed the case, concluding it lacked the authority to act. The court of appeals reversed the decision, instructing the district court to hear the mother's application on the merits.Upon review, the Supreme Court of Iowa vacated the decision of the court of appeals and affirmed the district court's dismissal of the case. The Supreme Court held that the language of Iowa Code section 598.1(3) provides parents with equal participation in decisions affecting their children's medical care. The court found that the mother's application for vaccination determination attempted to circumvent the dissolution decree that gave the parents joint legal custody. Without a request for a modification of the custody agreement, the district court did not have the authority to resolve the parents' dispute. Therefore, the court concluded that the district court did not have the authority to resolve the parties' conflict over vaccinating their children against COVID-19. View "In re Marriage of Frazier" on Justia Law

In a workers' compensation case, an employee was injured and sought compensation from her employer and its insurance carrier. The employee failed to provide her expert witness's evidence in a timely manner, serving them only two weeks before the arbitration hearing began. The employer and its insurance carrier objected, arguing that this late submission of evidence was unfairly prejudicial. The deputy workers’ compensation commissioner agreed with the employer and excluded the evidence. This decision was affirmed by the commissioner, but was later reversed on judicial review by the district court. The court of appeals affirmed the district court’s ruling. However, the Supreme Court of Iowa held that the commissioner’s decision to exclude untimely evidence was entitled to deference. The court found that the commissioner did not abuse his discretion by excluding the untimely evidence since the employee had disregarded multiple deadlines and submitted the reports only about two weeks before the hearing. Moreover, the reports were not from the employee’s treating physicians and the vocational report reached a conclusion that no other expert in the case shared. Therefore, the supreme court vacated the court of appeals decision, reversed the district court decision, and remanded the case back to the district court to enter a judgment affirming the commissioner's decision to exclude the untimely evidence. View "Hagen v. Serta/National Bedding Co., LLC" on Justia Law

The Supreme Court of Iowa ruled that the State University of Iowa, Iowa State University of Science and Technology, and the University of Northern Iowa were required to be members of the Iowa Individual Health Benefit Reinsurance Association (IIHBRA) and therefore had to pay assessments to the association. The universities had argued that they were not members of IIHBRA and that the statute requiring them to pay assessments violated the Iowa Constitution, which prohibits the state from acting as a surety for another. The court rejected these arguments, finding that the statutory scheme did not violate the constitution and that the universities, as providers of health benefit plans, were indeed members of IIHBRA. The court also ruled that IIHBRA was statutorily authorized to impose late payment fees against its members. However, the court denied IIHBRA's request for attorney fees and costs. The court affirmed in part, reversed in part, and remanded the case for further proceedings. View "Iowa Individual Health Benefit Reinsurance Ass’n v. State University of Iowa" on Justia Law