Justia Iowa Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the district court dismissing the trial information in this case, holding that the State's delay in arresting and formally charging Defendant did not amount to a due process violation.By late 2017, law enforcement had focused on Defendant as the suspected perpetrator of a robbery. However, the police did not file a criminal complaint against Defendant until August 2018 and did not serve an arrest warrant until September 2019. In October 2019, after it was finally filed, the district court dismissed the trial information, concluding that Defendant's due process rights under the Fifth Amendment were violated. The Supreme Court reversed, holding that the State's delay in arresting and charging Defendant did not violate the speedy indictment rule or violate due process where Defendant failed to show actual prejudice. View "State v. Smith" on Justia Law

The Supreme Court vacated the order of the district court denying Defendant's application under Iowa Code 692A.128 to modify the requirement that he register as a sex offender, holding that because the district court did not have the benefit of the guidance provided in this opinion, the case must be remanded.Defendant was convicted of three counts of lascivious acts with a child. As a result of his convictions, Defendant was a tier III sex offender and subject to lifetime registration as a sex offender. Defendant filed an application for modification of his sex offender registration requirements, but the district court denied the application, concluding that Defendant did not present a compelling reason for release from the registry. The Supreme Court vacated the decision and remanded for further proceedings, holding that the district court improperly considered a number of factors in the modification proceeding. View "Fortune v. State" on Justia Law

The Supreme Court reversed the order of the district court denying Defendants' motion for summary judgment and holding that the City of Davenport's mayor was required to show cause to remove an appointee from the Davenport Civil Rights Commission, holding that the law imposed no obligation on the mayor to show cause for the appointee's removal from the commission.Mayor Frank Klipsch entered an order removing Commissioner Nicole Bribriesco-Ledger from the Davenport Civil Rights Commission before her term had expired. Bribriesco-Ledger brought this action claiming that Klipsch had no authority to remove her absent a showing of cause. Defendants - Klipsch and the City of Davenport - filed a motion for summary judgment, which the trial court denied. The Supreme Court reversed, holding that removal from office under Iowa Code 372.15 does not require that the removal be for cause. View "Bribriesco-Ledger v. Klipsch" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court terminating the parental rights of Father to his child and denying the State's petition to terminate Mother's parental rights and instead entering a permanency order appointing Grandmother of one of the boys as the guardian for both, holding that the juvenile court should have terminated Mother's parental rights.Father appealed the termination of his rights, but his notice of appeal was untimely filed. Mother appealed the permanency order, asking the Court to direct the State to continue reunification efforts. The State also appealed, challenging the juvenile court's disposition as to Mother. The Supreme Court reversed as to Mother and otherwise affirmed, holding (1) as to Mother, guardianship was not a proper permanency plan, and the juvenile court erred in denying termination; and (2) because Father's late filing of an appeal was beyond his control, this Court addresses his appeal, and the juvenile court did not err in terminating Father's parental rights. View "In re W.M." on Justia Law

The Supreme Court reversed the termination of parental rights as to Mother but not as to Father, holding that the juvenile court erred in finding each required element for a termination of Mother's custody under Iowa Code Ann. 232.116(1)(f) and (h).At issue was the termination of the parental rights of Mother to her three children and the termination of the parental rights of Father of one of the children. Both parties appealed, but Father filed his petition two days late. The Supreme Court affirmed in part and reversed in part, holding (1) this Court recognizes delayed appeals in termination of parental rights cases under certain limited circumstances; (2) the State did not meet its burden of proving that the children could not be returned to Mother's custody at the time of the adjudication; and (3) the juvenile court properly terminated Father's parental rights as to his child. View "In re A.B." on Justia Law

In this action seeking to set aside a sheriff's sale of the stock of Plaintiff's farm business the Supreme Court vacated the decision of the court of appeals reversing the decision of the district court concluding that Plaintiff's claims were untimely or barred by claim preclusion, holding that the court of appeals erred.In his motion to dismiss, Defendant argued that this action was repetitive of prior unsuccessful lawsuits and that Defendant was precluded under court order from filing any new actions regarding the sheriff's sale. The district court adopted Defendant's arguments in its dismissal order. The court of appeals reversed. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding that the district court correctly found that claim preclusion applies. View "Daniels v. Holtz" on Justia Law

The Supreme Court affirmed Defendant's conviction of sexual abuse in the third degree, holding that there was no trial error and that there was sufficient evidence to support the conviction.Specifically, the Supreme Court held (1) the district court did not abuse its discretion when it prohibited Defendant from cross-examining the victim about a prior sexual incident between Defendant and the victim; (2) the district court did not err when it submitted Instruction No. 20 to the jury; and (3) Defendant's claim that the evidence offered by the victim was too vague and insufficient to constitute substantial evidence to support the jury's verdict was without merit. View "State v. Donahue" on Justia Law

The Supreme Court affirmed the ruling of the district court granting summary judgment dismissing Kristina Lewis's negligence claims against Howard L. Allen Investments, Inc. (Allen Investments), holding that Allen Investments did not owe a duty to protect Lewis from the harm she suffered.Allen Investments sold a house under a contract of sale that required the buyers to make monthly payments for ten years. Five years into the payment period the buyers leased the house to Lewis and her fiancé. The house subsequently caught fire, causing Lewis to suffer serious injuries. Lewis brought this negligence action against the buyers and Allen Investments. The district court granted summary judgment for Allen Investments, concluding that the company, as a contract seller, owed no duty to Lewis. The Supreme Court affirmed, holding (1) Allen Investments was not the landlord of the property under Iowa's Uniform Residential Landlord and Tenant Act, Iowa Code chapter 562A; and (2) Allen Investments owed no duty of care to Lewis to maintain the property. View "Lewis v. Howard L. Allen Investments, Inc." on Justia Law

The Supreme Court dismissed this appeal from a jury verdict in favor of Defendants in this medical malpractice action, holding that Plaintiff failed to timely file her notice of appeal.Plaintiff, individually and on behalf of her minor son, brought this lawsuit alleging that her son developed severe, disabling injuries from bacterial meningitis and that Defendants were liable for medical negligence and parental loss of consortium. The jury returned a verdict in favor of Defendants. Plaintiff appealed, presenting several issues. The Supreme Court dismissed the appeal, holding that the appeal was untimely and should be dismissed under Iowa R. App. P. 6.101(1)(b). View "Valles v. Mueting" on Justia Law

The Supreme Court reversed the judgment of the district court granting Defendant's motion to suppress physical evidence and statements based on a police officer's alleged promise of leniency, holding that there was no improper promise of leniency.The officer at issue initiated a Terry stop on a public stop after observing Defendant make a possible drug buy. The officer told Defendant if he cooperated he would not be arrested that day but may be arrested later. Three months after Defendant handed over crack cocaine and marijuana the officer charged him with possession. The trial court granted Defendant's motion to suppress, concluding that the evidence obtained after the officer promised leniency was fruit of the poisonous tree. The Supreme Court reversed, holding that the officer did not improperly promise leniency. View "State v. Hillery" on Justia Law