Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court dismissing Plaintiff's claims for violations of a municipal civil rights ordinance and the Iowa Civil Rights Act (ICRA) and breach of contract, holding that the ICRA does not contain authorization for a municipality to enact law that would be binding between two private parties in state court.Plaintiff claimed that he was discriminated against in his education on the basis of age and disability. The district court dismissed all of Plaintiff's claims, concluding that it had no jurisdiction over the local ordinance claims, that the ICRA claims were barred because they were based on the same conduct, and that Plaintiff did not have a viable breach of contract claim. The Supreme Court affirmed, holding (1) the general assembly did not confer jurisdiction on Iowa state courts to hear claims by private parties arising under municipal civil rights ordinances; and (2) the district court did not err in its resolution of Plaintiff's ICRA and breach of contract claims. View "Petro v. Palmer College of Chiropractic" on Justia Law

In this case brought by a tenant against her landlord and a neighboring tenant alleging breach of the lease's no-pets provision the Supreme Court reversed the judgment of the district court dismissing the case, holding that the landlord's accommodation of an emotional support dog was not reasonable.Plaintiff moved into an apartment building because of its no-pets policy. Afterwards, another tenant requested a reasonable accommodation to have his emotion support animal (ESA), a dog, with him on the apartment premises. The landlord allowed the ESA and tried to accommodate the two tenants, but Plaintiff still suffered from allergic attacks. Plaintiff sued, alleging breach of the lease and interference with the quiet enjoyment of her apartment. The landlord asserted in its defense that its waiver of the no-pets policy was a reasonable accommodation that it was required to grant under the Iowa Civil Rights Act (ICRA). The small claims court concluded that the landlord's accommodations were reasonable. The district court dismissed the case. The Supreme Court reversed and remanded the case, holding (1) the landlord's accommodation of the ESA was not reasonable because Plaintiff had priority in time and the dog's presence posed a direct threat to her health; and (2) Plaintiff was entitled to recover on her claims. View "Cohen v. Clark" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the determination of the Iowa Department of Revenue that capital gains Taxpayer earned from the sale of farmland she inherited from her father and leased on a cash-rent basis did not qualify for the exclusion from Iowa income tax allowed under Iowa Code 422.7(21)(a), holding that the assessment of additional taxes and related penalties and interest was not irrational, illogical, or wholly unjustifiable.At issue was whether the Department's interpretation of section 422.7(21)(a), as delineated in Iowa Administrative Code rule 701-40.38(1)(c), or the director's application of that rule to the facts was irrational, illogical, or wholly unjustified. The Supreme Court affirmed, holding (1) the Department acted within its discretion when it promulgated distinct rules for farm leases and other types of real property leases in rule 701-40.38(1)(c); and (2) Taxpayers' attempt to avoid the farm-specific rules is rejected. View "Christensen v. Iowa Department of Revenue" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the judgment of the district court ordering Defendant to register as a sex offender after he entered an Alford plea to child endangerment, holding that the evidence was insufficient to prove sexual motivation beyond a reasonable doubt under Iowa Code 692A.126 and that the proper remedy was to remand and give the State an opportunity to prove sexual motivation.The district court relied on Defendant's Alford plea and a victim impact statement from the child victim's mother to find that Defendant's underlying conduct was sexually motivated. The court ordered Defendant to register as a sex offender. The court of appeals remanded the cause, finding that victim statements do not provide sufficient evidence that the offense of conviction was sexually motivated beyond a reasonable doubt but that the minutes of testimony identified evidence to establish that the offense could have been sexually motivated. The Supreme Court affirmed the court of appeals, vacated the order requiring Defendant to register as a sexual offender, and remanded, holding that, under the circumstances, the State is allowed to introduce the facts from the minutes in an effort to support its request that Defendant be required to register as a sex offender. View "State v. Chapman" on Justia Law

The Supreme Court reversed the judgment of the district court granting summary judgment to the City of Burlington and dismissing Plaintiffs' claim that the City was negligent by giving a sewer box the appearance that it was part of the City's trail system, holding that the public-duty doctrine did not shield the City from its affirmative acts under the circumstances and that a genuine issue of material fact existed precluding summary judgment.Plaintiff was injured when she struck a tree branch while riding on a sewer box that was connected to a public pathway and fell ten feet to the ground. Plaintiffs alleged that the City was negligent in connecting the sewer box to the pathway without providing guardrails and warning signs. The district court granted summary judgment in favor of the City based on the public-duty doctrine and the state-of-the-art defense. The Supreme Court reversed, holding (1) the public-duty doctrine did not apply to the facts of this case; and (2) because a material fact existed as to whether the City's pathway connected to the sewer box met the recognized safety standards at the time of construction the district court erred in granting the City's motion for summary judgment based on the state-of-the-art defense. View "Breese v. City of Burlington" on Justia Law

The Supreme Court reversed the judgment of the district court convicting Defendant of violating Iowa Code 724.4C, which criminalizes carrying a dangerous weapon while intoxicated, holding that the jury instructions were erroneous because section 724.4C prohibits only carrying, which requires more than mere possession.On appeal, Defendant argued that the jury instructions improperly allowed the jury to convict him based on conduct not covered under the statute. Specifically, Defendant argued that the jury could have convicted him on a finding of possession alone, rather than carrying a dangerous weapon. The Supreme Court reversed and remanded the case for a new trial, holding (1) the jury instructions that allowed the jury to convict Defendant if he either carried or possessed a dangerous weapon misstated the law; and (2) the instructional error prejudiced Defendant and required reversal. View "State v. Shorter" on Justia Law

The Supreme Court reversed the judgment in favor of Plaintiff in this will contest, holding that a claim alleging that the decedent's will resulted from tortious interference by a beneficiary must be joined with a timely will contest and otherwise is barred.Mother and Father died within one day of each other, and their 2014 mirror wills were probated. Plaintiff decided to forgo a timely contest to Mother's will but then later brought a suit for tortious interference against a Beneficiary of the will, arguing that the Beneficiary exercised improper and undue influence over Mother. The jury returned a verdict in favor of Plaintiff. The Supreme Court reversed, holding (1) the common law and principles of claim preclusion do not permit a tortious interference with inheritance claim alleging an improperly obtained will to go forward outside normal probate deadlines and proceedings; and (2) Plaintiff's tortious interference claim was a de facto substitute for a will contest based on undue influence and was thus barred because it was not brought in conjunction with a timely will contest. View "Youngblut v. Youngblut" on Justia Law

The Supreme Court reversed the judgment of the district court ruling that Plaintiffs' claim seeking contract damages was barred by the limitations period set forth in Iowa Code 614.17A, holding that the district court erred in granting summary judgment.John and Dessie Rottinghaus filed a claim in the Estate of Sandra Franken, alleging that the Estate sold certain real estate in violation of their right of first refusal to purchase the real estate. The executor disallowed the claim and moved for summary judgment, claiming that section 614.17A barred the Rottinghauses' claim. The district court granted the motion for summary judgment, concluding that the statute of limitations precluded the Rottinghauses' claim for damages. The Supreme Court reversed, holding (1) section 614.17A applies only to actions seeking to recover or establish an interest in or claim to real estate filed against the holder of the record title; and (2) neither the merger doctrine, the statute of frauds, the indirect effect of section 614.17A, nor the statute of limitations in section 614.1(5) barred the Rottinghauses' damages action. View "In re Estate of Franken" on Justia Law

The Supreme Court reversed the judgment of the district court granting Defendant's motion for summary judgment pursuant to the continuing storm doctrine in this negligence action, holding that because a factual dispute existed as to whether there was a continuing storm the proper course was to instruct the jury on the doctrine and leave the fact-finding to the jury.Plaintiff sued Defendant, her landlord, after she slipped and fell on an icy sidewalk outside her apartment building. The district court held that the district court erred in holding that, as a matter of law, Defendant had no duty at the time Plaintiff fell to remove or ameliorate the accumulation of snow or ice on the sidewalk pursuant to the continuing storm doctrine. The Supreme Court reversed, holding (1) this Court declines Plaintiff's request to abandon the continuing storm doctrine; and (2) Defendant failed to establish the continuing storm doctrine entitled Defendant to judgment as a matter of law. View "Gries v. Ames Ecumenical Housing, Inc." on Justia Law

In this criminal action, the Supreme Court vacated the restitution awarded and clarified State v. Albright, 925 N.W.2d 144 (Iowa 2019), holding that defendants may seek appellate review of interim restitution orders in a direct appeal of right from the judgment of conviction.Appellant filed a direct appeal from his judgment of conviction, challenging only the restitution award, which was awarded without a determination of his reasonable ability to pay and without a final order of restitution. The State argued that under Albright, which held that "any temporary, permanent, or supplemental order regarding restitution is not appealable or enforceable until the court files its final order of restitution," the appeal must be dismissed. The Supreme Court vacated the restitution orders, holding (1) interim restitution orders are not enforceable until the district court determines the defendant's reasonable ability to pay all items of restitution and enters the final order of restitution; (2) there is no right of direct appeal from interim restitution orders preceding the court's final order of restitution, but defendants may seek appellate review of interim restitution orders in a direct appeal of right from the judgment of conviction; and (3) because the district court did not have the benefit of Albright, this case is remanded for further proceedings. View "State v. Davis" on Justia Law