Justia Iowa Supreme Court Opinion Summaries

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

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