Justia Iowa Supreme Court Opinion Summaries

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

The Supreme Court affirmed the decision of the court of appeals affirming the determination of the district court that evidence of approximately twenty instances of Defendant's cell phone use while in a vehicle over an approximately three-year period was inadmissible as habit evidence.Plaintiff was riding his bicycle when he was struck with the vehicle driven by Defendant. Plaintiff filed a negligence petition against Defendant. Before trial, Defendant filed a motion in liming asking the district court to prevent Plaintiff from making any argument that she had a habit of driving while distracted. The district court refused to admit evidence of Defendant's cell phone use while driving to prove a habit. The jury returned a verdict for Defendant. The court of appeals affirmed. The Supreme Court affirmed, holding that proffered specific instances of Defendant's cell phone use while driving were not numerous enough to constitute habit evidence. View "Holmes v. Pomeroy" on Justia Law

The Supreme Court affirmed the district court's order sustaining a subpoena served on a state agency for various categories of information related to a potential transaction, holding that the subpoena was not invalid.The agency in this case (Agency) and a state institution (Institution) overseen by the Agency contacted Rob Sand, the Iowa Auditor of State (Auditor Sand), to discuss a transaction that was expected to create a multi-billion dollar obligation for the Agency. Auditor Sand requested information on the potential investors involved in the transaction, but the Agency refused to provide the information, asserting that it was confidential. Auditor Sand then served a subpoena on the Agency requesting thirteen categories of documents related to the transaction. The district court entered an order sustaining the subpoena. The Supreme Court affirmed, holding that, even though Auditor Sand was not actually engaged in an audit, the subpoena was valid. View "Sand v. Doe" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of a strip club and dismissing this common law wrongful-death-negligence action, holding that Defendants owed no continuing legal duty to the decedent in this case.Daulton Holly was ejected from the strip club by the club's security guard and offered a cab ride home. Holly refused the offer and left the establishment on foot. Thirty minutes later, Holly was struck and killed by a drunk driver about one-half mile away from the strip club. Holly's parents and estate brought this action against the strip club. The district court granted a "no-duty" summary judgment against the plaintiffs. The Supreme Court affirmed, holding that the strip club owed no continuing legal duty to Holly after he refused the offer of the cab ride and chose to walk away. View "Morris v. Legends Fieldhouse Bar & Grill, LLC" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court upholding the ruling of the Property Assessment Appeal Board (PAAB) concluding that bins that primarily hold raw material until it is needed in the manufacturing process do not themselves constitute "machinery," holding that some, but not all, of the ingredient bins qualify for a tax exemption.At issue was when bins for holding ingredients qualify for a tax exemption as machinery used in manufacturing establishments under Iowa Code 427A.1(1)(e). The court of appeals disagreed with the PAAB's interpretation of the statute, finding that bins that are integrated into the manufacturing process and used for temporary storage of ingredients fell within the statutory exemption. The Supreme Court vacated the court of appeals' decision and reversed in part the district court's judgment, holding (1) customized overhead bins within a building where feed is manufactured constitute part of a continuous piece of machinery within that building; and (2) two large stand-alone corn silos, while connected by an underground conveyor to the feed manufacturing facility, do not meet the definition of machinery. View "Stateline Cooperative v. Iowa Property Assessment Appeal Board" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming a probate court ruling that a restriction on the transfer of devise property was a restraint on alienation and void, holding that the provision was a prohibited restraint on alienation and void.The testamentary provision in this case restricted the beneficiaries from selling or transferring the devised property outside their immediate family for a period of twenty years following the testator's death. The district court ultimately held that the restriction on the property was an invalid restraint on alienation and void. The court of appeals affirmed. The Supreme Court affirmed, holding that the restriction was a restraint on alienation and that reasonable restraints on alienation are not allowed under Iowa law. View "Estate of Vera E. Cawiezell v. Coronelli" on Justia Law