Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court in favor of Defendants in this personal injury case, holding that the Federal Railroad Safety Act preempted Plaintiff's excessive speed claims and that summary judgment was properly granted on his lookout and braking claims.The driver of a road grader was seriously injured when a train struck the grader while it crossed the railroad tracks. The driver sued the railroad and the train crew alleging failure to break, excessive speed, failure to keep a proper lookout, and failure to properly sound the horn. The district court granted summary judgment to Defendants on all but the horn claims. After a trial, a jury returned verdicts for Defendants on the horn claims. The Supreme Court affirmed, holding (1) the driver's excessive speed claims were preempted by federal law; and (2) summary judgment was properly granted on the lookout and braking claims based on lack of causation. View "Wermerskirchen v. Canadian National Railroad" on Justia Law

The Supreme Court vacated the decision of the court of appeals affirming the decision of the district court concluding that the county board of adjustment legally granted an area variance to certain property owners, holding that the board of adjustment acted illegally in granting the variance from the county zoning ordinance.The Board of Adjustment of Cerro Gordo County granted the application for a variance filed by Gregory and Lea Ann Saul that allowed them to construct a pergola twenty-one inches from the property line. The local ordinance required a six-foot setback. The district court concluded that the board acted legally in granting the variance. The court of appeals affirmed. The Supreme Court vacated the judgment of the court of appeals and reversed the district court, holding that the Sauls did not meet their burden to establish unnecessary hardship. View "Earley v. Board of Adjustment of Cerro Gordo County" on Justia Law

The Supreme Court reversed the order of the district court granting partial summary judgment on Donald Clark's legal malpractice claim, holding that Clark may not use his prior successful ineffective assistance of counsel claims to establish preclusively the breach elements of his malpractice claims.Clark, who was represented at his criminal trial by a state public defender, was convicted of second-degree sexual abuse. Clark filed a postconviction relief (PCR) action seeking a new trial based on ineffective assistance of counsel. The PCR court concluded that Clark was entitled to a new trial, and the charges against Clark were eventually dismissed. Clark then brought this malpractice action against the State. In his motion for partial summary judgment, Clark asserted that the breach-of-duty element of his malpractice claim was conclusively established by the ruling of the PCR court under the doctrine of issue preclusion. The district court agreed and granted partial summary judgment. The Supreme Court reversed, holding (1) the State as a defendant in the malpractice action was not the same party or in privity with a party in the PCR action; and (2) therefore, the elements of issue preclusion were not met. View "Clark v. State" on Justia Law

The Supreme Court reversed the judgment of the juvenile court dismissing this child-in-need-of-assistance proceeding in which the child victim of sexual abuse had been returned to the home with the perpetrator and in which the child's mother refused to believe any sexual abuse occurred, holding that dismissal was improper.When a seven-year-old girl was sexually abused by her stepfather, the State initiated a child-in-need-of-assistance proceeding, and the juvenile court removed the girl from the home. After the stepfather had been prohibited from living there, the child was allowed to return to the home. The girl's mother, however, refused to accept the sexual abuse finding against her husband. The juvenile court eventually permitted the stepfather to run to the home and dismissed the child-in-need-of-assistance proceeding. The Supreme Court reversed, holding that the purposes of the child-in-need-of-assistance order were not accomplished, and the continuation of the child's supervision, care, or treatment through continued proceedings was warranted. View "In re D.D." on Justia Law

The Supreme Court affirmed the ruling of the district court on declaratory judgment declining to adjudicate the validity of two wills the ward, who was still alive, executed while he was in a voluntary conservatorship, holding that neither Iowa Code 633.637 nor other provisions of the Probate Code permit a challenge to the validity of a will executed by a testator who is still living.The ward's sister and her husband (together, Petitioners) brought this action to determine the validity of the ward's two wills. The conservator bank moved to dismiss the action, arguing that Petitioners lacked standing to challenge the wills while the testator was still alive. The district court denied the motion to dismiss but limited the scope of the action to a determination of the ward's present testamentary capacity. The Supreme Court affirmed, holding (1) will contests must await the testator's death, and the Probate Code does not allow this declaratory judgment action to proceed; and (2) the district court erred by ordering Petitioners to pay the conservator's attorney fees without an applicable fee-shifting statute. View "In re Guardianship & Conservatorship of Radda" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress, holding that observations of a driver holding a phone in front of his face and actively manipulating the screen for at least ten seconds justified stopping the driver to resolve any ambiguity about whether the driver was violating Iowa Code 321.276.Section 321.276 allows drivers to use cell phones for some limited purposes while prohibiting most others. Defendant was stopped when officers believed he might be violating the statute. In his motion to suppress, Defendant argued that the officers lacked reasonable suspicion that Defendant was committing a traffic violation. The district court denied the motion. The Supreme Court affirmed, holding that the officers had reasonable suspicion Defendant was violating section 321.276 to support an investigatory stop. View "State v. Struve" on Justia Law

The Supreme Court reversed Defendant's conviction for wanton neglect of a resident of a health care facility, holding that the admission of a certain exhibit, when coupled with a certain instruction, posed a serious risk of misleading or confusing the jury.Defendant's conviction arose out of his alleged failure to properly ensure that a facility resident as ordered by the patient's physician. On appeal, Defendant argued that the trial court's admission of the standard of care in the nursing profession and the subsequent instructions related to the use of the standard of care in this case were improper. The Supreme Court agreed and reversed the conviction, holding that the professional standards should have been excluded under Iowa R. Evid. 5.403 and that the court's jury instructions did not mitigate the problem. View "State v. Buman" on Justia Law

The Supreme Court affirmed the judgment of the district court denying a citizen's quo warranto action asserting that a district judge was holding his office unlawfully, holding that this case presented a nonjusticiable controversy.In 2018, two finalists were sent to the Governor for a district judge position. Iowa law provides that, if the Governor fails to make an appointment within thirty days after a list of nominees has been submitted, the appointment shall be made by the Chief Justice of the Supreme Court. On a Thursday, the thirtieth day, the Governor communicated to her chief of staff the her selected nominee's identity - Jason Besler. The following Monday the Governor told Besler that he had been selected. The Chief Justice accepted the Governor's view that the appointment was timely. Gary Dickey, a private citizen, filed an application for leave to file a petition for writ of quo warranto alleging that Besler was holding the office of district judge unlawfully because the Governor failed to appoint Besler by the deadline for making an appointment. The district court denied the application. The Supreme Court affirmed, holding that because both the Governor and the Chief Justice deferred to and accepted the view that the appointment was timely, this quo warranto action was nonjusticiable. View "State ex rel. Dickey v. Besler" on Justia Law

The Supreme Court affirmed Defendant's convictions for attempting to obtain a prescription drug by deceit, as a habitual offender, and conspiracy to commit a nonforcible felony, holding that Defendant's constitutional challenge to Iowa Code 814.6A was unavailing.Specifically, the Supreme Court held (1) the district court did not abuse its broad discretion in admitting, over Defendant's objections, evidence regarding Defendant's residential address, which was offered to prove Defendant's knowledge, motive, and intent; and (2) section 814.6A, a newly-enacted law that prohibits a represented defendant from filing pro se documents, does not violate the constitutional separation-of-powers doctrine. The Court then denied Defendant's motion to accept his pro se supplemental brief. View "State v. Thompson" on Justia Law

The Supreme Court affirmed Defendant's sentence imposed following his pleas of guilty to possession of a firearm by a felon, interference with official acts while armed with a firearm, and carrying weapons, holding that there was no error.On appeal, Defendant argued that the prosecutor breached the parties' plea agreement by failing to recommend the bargained-for sentence and that the district court improperly considered his juvenile offense history as an aggravating factor. The Supreme Court affirmed, holding (1) Defendant failed to establish a breach of the plea agreement; and (2) the district court did not consider an improper sentencing factor in considering Defendant's juvenile adjudications and dispositions. View "State v. Boldon" on Justia Law