Justia Iowa Supreme Court Opinion Summaries

The Supreme Court conditionally affirmed Defendant's convictions and remanded for the district court to hold a hearing on Defendant's motion to suppress evidence, holding that the peace officer in this case conducted an unreasonable search and seizure by taking a citizen's opaque trash bags left outside for collection, opening the trash bags, and rummaging through the papers and effects contained therein.Despite an ordinance making it unlawful for any person to take solid waste placed out for collection, Officer Brandon Heinz, without probable cause or warrant, took Defendant's garbage bags and searched through them during the dark of night. Heinz subsequently applied for and was granted a search warrant based on the evidence obtained from the warrantless seizure and search of Defendant's trash bags. Defendant was subsequently charged with several drug-related counts. The district court denied Defendant's motion to suppress, and Defendant was found guilty. The court of appeals affirmed. The Supreme Court held that Heinz conducted an unreasonable search and seizure in violation of Iowa Const. art. I, 8 and that remand was required for a suppression hearing without consideration of the evidence obtained during the trash pulls used to support the warrant application. View "State v. Wright" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment against an investor on grounds that he failed to exercise his appraisal rights in a merger, holding that the investor failed validly to exercise his appraisal rights that had been extinguished.The investor, the beneficial owner of 1.1 million shares, received $39.6 million when the merger transaction closed. The investor objected to the merger and sought to exercise his appraisal rights, but he never obtained the written consent of the record shareholder. The corporation brought this declaratory judgment action. The district court granted summary judgment for the corporation. The Supreme Court affirmed, holding (1) lacking the record shareholder's consent, the investor lost his right to an appraisal; and (2) the investor's waiver and estoppel arguments failed. View "EMC Insurance Group, Inc. v. Shepard" on Justia Law

The Supreme Court affirmed the ruling of the district court against Defendant and in favor of Plaintiff finding breach of contract and breach of implied covenant of good faith and fair dealing, holding that the district court erred.Defendant, a managed care organization, entered into a contract with Plaintiff, a dentist, to deliver dental services to Medicaid participants as a member of Defendant's network. Defendant later sent Plaintiff a "notice of non-renewal" of the provider contract. Plaintiff sued, and the district court ruled that the provider contract did not allow Defendant to terminate Plaintiff through non-renewal of the provider contract. At issue was whether Defendant properly ended a provider contract that automatically renewed for successive one-year terms by sending a notice of non-renewal. The Supreme Court affirmed, holding that the district court correctly determined that Defendant possessed no right to terminate by non-renewal. View "Colwell v. MCNA Insurance Co." on Justia Law

In this lawsuit to set aside a will the Supreme Court affirmed the judgment of the district court for Plaintiffs on their undue influence claim and dismissing their tortious interference with inheritance claim, holding that there was no error.Shortly after the decedent died, Plaintiffs brought this action seeking to set aside the decedent's will. Their petition alleged several causes of action against Defendants, including undue influence and tortious interference with inheritance. The district court dismissed the tortious interference with inheritance claim. Later, the jury returned a verdict in favor of Plaintiffs on the undue influence claim. Both sides appealed. The Supreme Court affirmed, holding (1) the district court correctly held that Plaintiffs needed to prove Defendants' knowledge of Plaintiffs' expectancy of an inheritance from the decedent; and (2) the district court did not admit improper hearsay evidence, and Plaintiffs' lawyer did not make prejudicial statements during closing argument. View "Buboltz v. Birusingh" on Justia Law

The Supreme Court affirmed the ruling of the district court ruling that Plaintiff's employer had complied with Iowa Code 35C.6 when it terminated the employment of Plaintiff, a military veteran, from his job as a police officer at the University of Iowa's (UI) Department of Public Safety (DPS), holding that the district court did not err.Plaintiff was charged with misconduct after he violated DPS policies. Following arbitration, Plaintiff was terminated and was later reinstated without back pay. Plaintiff filed a petition for writ of certiorari alleging that DPS violated section 35C.6 in his initial termination. The district court ruled that DPS had complied with section 35C.6 as interpreted in Kern v. Saydel Community School District, 637 N.W.2d 157 (Iowa 2001). The Supreme Court affirmed, holding (1) this Court declines to overrule Kern; and (2) the district court correctly determined that the State complied with Iowa Code 35C.6 in terminating Plaintiff. View "Williams v. Bullock" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for operating while intoxicated on two alternative theories, holding that neither Iowa law nor the Iowa Constitution guarantee a suspected drunk driver the right to a private phone consultation with counsel before deciding whether to take a blood alcohol test.On appeal, Defendant challenged the denial of his motion to suppress, arguing that the officials at the jail where he was detained impermissibly refused to allow him a private, unrecorded conversation with his attorney. The Supreme Court affirmed, holding (1) Iowa Code 804.20 does not provide the detainee a right to a private and confidential telephone consultation; and (2) the Iowa Constitution does not provide a detainee with a right to a confidential telephone conversation. View "State v. Sewell" on Justia Law

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