Justia Iowa Supreme Court Opinion Summaries

A mother and daughter drowned while floating on innertubes on the Turkey River after going over a low-head dam. Their estates sued the State of Iowa, Fayette County, the Fayette County Conservation Board, and the City of Clermont, alleging negligence and premises liability for failing to maintain warnings about the dam. The defendants moved to dismiss the claims.The Iowa District Court for Fayette County dismissed all claims. The court concluded that the claims were barred by the public-duty doctrine and that the petition failed to meet the heightened pleading requirements in Iowa Code § 670.4A. The court also dismissed the claims against the State, referring generally to the reasons set forth in the State’s motion, which included qualified immunity, sovereign immunity, discretionary function immunity, and the public-duty doctrine.The Iowa Supreme Court reviewed the case and reversed the district court’s dismissal. The court held that the heightened pleading requirements did not apply to the estates’ common law tort claims of negligence and premises liability. The court also determined that the public-duty doctrine did not bar the claims, as the allegations involved affirmative acts of negligence by the defendants. Additionally, the court found that the State’s sovereign immunity and discretionary function immunity did not apply at this stage, as the petition alleged inattention rather than considered choices by the State. The court also rejected the recreational immunity defense, concluding that the estates sufficiently pleaded an exception to the statute.The Iowa Supreme Court reversed the district court’s dismissal of the claims and remanded the case for further proceedings. View "Estate of Kahn v. City of Clermont, Iowa" on Justia Law

Siblings Martin, Paula, and Tom Robinson, along with Tom’s wife Laura, own adjoining farm properties and claim a drainage easement across properties owned by Central Iowa Power Cooperative (CIPCO) and Kenneth and Deanice Ludolph, which the Ludolphs leased to Coggon Solar, LLC. The Robinsons allege that CIPCO violated their drainage easement by rerouting a drainage tile line and that Coggon Solar’s solar farm development would further violate their easement. They sought declaratory and injunctive relief, damages, and claimed a right to access and repair the drainage tile on the servient properties.The Iowa District Court for Linn County dismissed the Robinsons’ lawsuit, quieted title in favor of the defendants, and awarded attorney fees to the defendants. The court held that the Robinsons had the right to drain surface water onto the servient estates but not along a fixed route, and they did not have a right to access or repair the drainage tile on the servient estates. The court also granted summary judgment in favor of CIPCO and Coggon Solar on the quiet-title action and dismissed the Robinsons’ nuisance claim.The Iowa Supreme Court affirmed the district court’s decision. The court held that the Robinsons have a legal and natural easement to drain surface water onto the servient estates but do not have a drainage easement along a fixed route or a right to access and repair the drainage tile on the servient properties. The court found no evidence that CIPCO’s rerouting of the tile line caused any detriment or injury to the Robinsons. The court also upheld the award of attorney fees, finding no abuse of discretion by the district court. View "Robinson v. Central Iowa Power Cooperative" on Justia Law

A custodian for a city police department sued the city and some of its employees, claiming she experienced sexual harassment and retaliation in violation of the Iowa Civil Rights Act (ICRA). The custodian alleged that a deputy chief made her uncomfortable with his behavior and comments, and that after she reported this, she faced retaliation from her administrative manager, who threatened her and her coworkers.The Iowa District Court for Linn County denied the defendants' motions for summary judgment on the custodian's claims of sexual harassment and retaliation, except for the claim of constructive discharge. The defendants then sought interlocutory review.The Iowa Supreme Court reviewed the case and found that the alleged harassment by the deputy chief was not sufficiently severe or pervasive to support an ICRA claim. The court also determined that the alleged acts of retaliation by the administrative manager did not amount to a materially adverse action as required for an ICRA claim. Consequently, the court reversed the district court's decision and remanded the case for dismissal of the custodian's claims. View "Rheeder v. Gray" on Justia Law

A qualified nonresident transmission company challenged an Iowa statute that granted incumbent utilities a right of first refusal (ROFR) for electric transmission projects, arguing it was unconstitutionally enacted. The statute prevented the company from competing for projects. The Iowa District Court for Polk County declared the statute unconstitutional under the Iowa Constitution's title and single-subject requirements and issued a permanent injunction against the statute's enforcement.The district court's decision was appealed by the State of Iowa, the Iowa Utilities Board (IUB), and two incumbent utilities, MidAmerican Energy Company and ITC Midwest, LLC. They argued that the district court could not retroactively enjoin their participation in projects awarded under the ROFR while the case was pending. They also contended that the district court lacked jurisdiction and that the nonresident company should have challenged the IUB's rule under Iowa Code chapter 17A.The Iowa Supreme Court reviewed the case and affirmed the district court's judgment and permanent injunction. The court held that the ROFR statute was void ab initio due to its unconstitutional enactment. The court determined that the district court had the authority to enjoin the parties from participating in projects awarded under the ROFR, as the incumbents were on notice of the constitutional challenge and no physical construction had begun on the projects. The court also rejected the argument that the IUB's rule could only be challenged under chapter 17A, as the constitutional challenge to the statute inherently invalidated the rule. The court deferred any remaining federal law issues to the Federal Energy Regulatory Commission (FERC). View "LS Power Midcontinent, LLC v. State" on Justia Law

A criminal defendant was charged with operating while intoxicated after being pulled over for speeding. The arresting officer used radar to determine the defendant's speed. The assistant county attorney, Theron Christensen, prosecuted the case. After the defense exposed weaknesses in the State's case during depositions, Christensen filed a motion in limine to exclude certain evidence. The defendant resisted and moved for sanctions against Christensen, arguing the motion was frivolous and in bad faith. Christensen later withdrew the motion and dismissed the case, allegedly to avoid the officer testifying about radar calibration issues.The Iowa District Court for Story County dismissed the charges and later imposed a $2,072 monetary sanction on Christensen under Iowa Rule of Civil Procedure 1.413 and Iowa Code § 619.19, finding his actions sanctionable. Christensen filed a petition for writ of certiorari, challenging the sanctions.The Iowa Supreme Court reviewed the case and determined that neither Iowa Rule of Civil Procedure 1.413 nor Iowa Code § 619.19 applies to criminal cases. The court emphasized that these rules and statutes are intended for civil cases only and that the rules of civil procedure do not apply to criminal proceedings unless explicitly stated. The court held that the district court erred in imposing monetary sanctions on Christensen based on these civil rules and statutes. Consequently, the Iowa Supreme Court sustained the writ and reversed the sanctions order and the monetary sanction imposed on Christensen. View "Christensen v. Iowa District Court For Story County" on Justia Law

Fatima Belhak experienced complications during childbirth, leading Dr. Denice Smith to perform an episiotomy. Post-delivery, Belhak suffered from pain and infection due to a misdiagnosed fourth-degree laceration, which required delayed reconstructive surgery. Belhak and her husband sued Smith and her employer, Women’s Care Specialists, P.C., for negligence.The Iowa District Court for Scott County held a jury trial, which resulted in a verdict favoring Belhak, awarding her $3.25 million in damages. Smith moved for a new trial, citing insufficient evidence and misconduct by Belhak’s lawyer during closing arguments. The district court denied the motion. Smith appealed, and the Iowa Court of Appeals reversed the jury verdict, finding insufficient evidence to support one of the negligence claims.The Iowa Supreme Court reviewed the case and vacated the Court of Appeals decision, affirming the district court’s judgment. The Supreme Court found that the district court did not abuse its discretion in denying a new trial based on alleged misconduct by Belhak’s lawyer. The court also held that sufficient evidence supported the jury’s finding that Smith’s use of 4-0 sutures, which were too weak, caused the wound to break down, leading to infection and delayed surgery. The court concluded that the jury could reasonably infer causation from the expert testimony provided. View "Belhak v. Smith" on Justia Law

Five employees of the Glenwood Resource Center (GRC), a residence for individuals with severe intellectual and developmental disabilities, left their jobs during a period when the superintendent conducted unauthorized experiments on residents. These experiments included excessive hydration to reduce pneumonia and behavioral health experiments without consent. The plaintiffs, who had different roles and left under various circumstances, sued the Iowa Department of Human Services (DHS) and other officials, alleging wrongful discharge in violation of public policy, among other claims.The Iowa District Court for Mills County dismissed all claims except for the wrongful discharge claim, which was later dismissed on summary judgment. The court found that the plaintiffs failed to identify a clearly defined public policy that was violated by their discharge. The plaintiffs appealed the summary judgment on the wrongful discharge claim.The Iowa Supreme Court affirmed the district court's decision. The court held that the plaintiffs did not demonstrate that their discharge violated a clearly defined public policy. The statutes cited by the plaintiffs, Iowa Code sections 225C.1(2) and 230A.101(1), were deemed too general to support a wrongful discharge claim. Additionally, the court concluded that Iowa Code section 70A.28, which provides remedies for state employees who face retaliation for whistleblowing, is the exclusive remedy for such claims. The court found that the plaintiffs' claims were essentially whistleblower claims and that they had not appealed the summary judgment on their section 70A.28 claims. Therefore, the court affirmed the district court's grant of summary judgment in favor of the defendants. View "Brodie v. Foxhoven" on Justia Law

The defendant was pulled over by deputies in Des Moines County after they responded to a reckless-driver complaint and observed her driving erratically. The deputies noted symptoms of intoxication and conducted field sobriety tests, which the defendant failed to complete. She requested an attorney when asked to submit to a preliminary breath test and was arrested. At the jail, she was given her phone and informed of her rights, including the right to contact an attorney, but she did not make any attempt to do so.The defendant was charged with operating a motor vehicle while intoxicated (OWI), first offense. She filed a motion to suppress evidence, claiming her rights were violated under Iowa Code section 804.20 when the deputies did not permit her to call an attorney. The Iowa District Court for Des Moines County denied her motion, and the case proceeded to a jury trial. The district court also denied her motion in limine to suppress alleged hearsay evidence. The jury found the defendant guilty, and she appealed the decision, challenging the sufficiency of the evidence and the denial of her motions.The Iowa Court of Appeals affirmed the district court's decisions. The Iowa Supreme Court granted further review but adopted the court of appeals' opinion for all claims except the motion to suppress issue concerning Iowa Code section 804.20. The Supreme Court determined that Iowa Code section 804.20 was not violated, as the defendant was given a reasonable opportunity to contact an attorney without unnecessary delay. The decision of the court of appeals and the district court judgment were affirmed. View "State of Iowa v. Clark" on Justia Law

Several estates filed a lawsuit against Tyson Foods Inc. and several of its corporate executives and plant supervisors, alleging gross negligence and fraud after four former workers at Tyson Foods’ pork processing plant in Waterloo died from COVID-19. The plaintiffs claimed that Tyson failed to implement adequate safety measures and misled workers about the risks of COVID-19, leading to the workers' deaths.The Iowa District Court for Black Hawk County dismissed the case, concluding that Iowa’s Workers’ Compensation Act (IWCA) provided the exclusive remedy for the estates’ claims, thus lacking subject matter jurisdiction. The court found that the plaintiffs did not sufficiently plead gross negligence to fall within an exception to the IWCA and that the claims were improperly "lumped" together without specifying each defendant's duty or claim.The Iowa Supreme Court reviewed the case and held that the plaintiffs had sufficiently pleaded gross negligence against the executive and supervisor defendants, thus falling within the IWCA’s exception. The court found that the petition provided fair notice of the claims and that the allegations met the elements of gross negligence: knowledge of the peril, knowledge that injury was probable, and a conscious failure to avoid the peril. The court also held that the fraudulent misrepresentation claims against the supervisor defendants were not preempted by the IWCA, as intentional torts fall outside its scope.However, the court affirmed the dismissal of the claims against the corporate defendants, Tyson Foods and Tyson Fresh Meats, as the IWCA’s exclusivity provisions barred any direct tort claims against employers. The court also affirmed the dismissal of the breach-of-duty claims against Adams and Jones due to waiver. The case was remanded for further proceedings consistent with the court’s opinion. View "Mehmedovic v. Tyson Foods Inc." on Justia Law

Douglas Wilson underwent hip replacement surgery at Shenandoah Medical Center (SMC) and was injured in a fall while recovering. He and his wife sued the hospital for professional negligence in his postoperative care. They identified a nursing expert but failed to certify this expert by the agreed deadline. The certification was only made three months later, after SMC moved for summary judgment. The plaintiffs argued that expert testimony was not required and blamed defense counsel’s silence for missing the deadline.The Iowa District Court for Page County found good cause for the delay, citing defense counsel’s silence and ongoing scheduling negotiations. The court did not decide whether expert testimony was necessary. SMC appealed, and the Iowa Court of Appeals affirmed the district court’s decision, with a dissenting opinion arguing that the plaintiffs had not shown good cause.The Iowa Supreme Court reviewed the case and concluded that the district court abused its discretion in finding good cause for the plaintiffs’ delay. The court held that defense counsel is not obligated to remind opposing counsel of expert certification deadlines and that an adversary’s silence cannot excuse missing the statutory deadline by three months. The court emphasized that the plaintiffs’ three-month delay was a serious deviation and that the lack of prejudice to the defendant alone was insufficient to establish good cause.The Iowa Supreme Court vacated the decision of the Court of Appeals, reversed the district court’s judgment, and remanded the case for the district court to determine whether the plaintiffs’ claims require expert testimony to avoid summary judgment. View "Wilson v. Shenandoah Medical Center" on Justia Law