Justia Iowa Supreme Court Opinion Summaries

The Supreme Court held that judgment creditors cannot levy on their judgment debtor, obtain the judgment debtor's chose in action for legal malpractice against the attorney representing the judgment debtor in the litigation giving rise to the judgment, and prosecute the claim for legal malpractice against the attorney as successors in interest to their judgment debtor.Janice and Jeff Gray were awarded $127 million in a civil suit against James Lee Hohenshell. The court of appeals affirmed. While the appeal was pending, the Grays caused to be issued a writ of execution on the judgment against Hohenshell. Amongst the property levied on was any claims against Michael Oliver, Hohenshell's lawyer in the underlying suit. The Grays purchased this right for $5000 at the sheriff's sale. The Grays then filed this malpractice claim against Oliver as successors in interest to Hohenshell. The district court granted Oliver's motion for summary judgment, holding that public policy prohibits the assignment of a legal malpractice claim to an adversarial party in the underlying lawsuit. The Supreme Court affirmed, holding that judgment creditors cannot prosecute a claim for legal malpractice as successors in interest to their former litigation adversary where the claim for legal malpractice arose out of the suit in which the parties were adverse. View "Gray v. Oliver" on Justia Law

The Supreme Court vacated the judgment of the district court ordering restitution in the amount of $2740.95 based upon testimony and exhibits submitted by the Crime Victim Compensation Program (CVCP), holding that the restitution order was not supported by substantial evidence.Defendant was convicted of sexual abuse in the third degree and supplying alcohol to a minor. The State filed a motion for restitution. The district court approved of the restitution claim in its entirety, largely relying on testimony about the general process conducted by the CVCP in evaluating potential restitution. The Supreme Court vacated the restitution order, holding (1) the CVCP fell short of establishing restitution in the amount of $2740.95; and (2) based on the Court's review of the record, the record supported only $285.50 in restitution. View "State v. Delong" on Justia Law

The Supreme Court reversed the order of the district court denying Defendant's motion to dismiss four additional arson charges as breach of his plea agreement with the State as to second-degree arson, holding that the State remained bound by its plea agreement under the circumstances of this case.The plea agreement provided that Defendant would plead guilty to second-degree arson, that Defendant would cooperate in an interview regarding other suspicious fires, and that the State would not bring charges regarding the other fires. Defendant pled guilty. Thereafter, the State decided not to hold the interview and advised Defendant that he would be charged with other arsons. The State gave Defendant an opportunity to withdraw from the plea agreement, but Defendant declined to withdraw. The State brought four additional arson charges, and Defendant moved to dismiss them as breach of the plea agreement. The district court denied the motion. The Supreme Court reversed, holding (1) the State could not unilaterally withdraw from the plea agreement by declining to conduct the interview; and (2) Defendant did not ratify the State's modification of the plea agreement by refusing the State's offer of rescission. View "State v. Beres" on Justia Law

The Supreme Court upheld the district court's order directing Plaintiff and/or his attorney to pay reasonable expenses associated with one of the defendant's attendance at a court-ordered pretrial settlement conference due to Plaintiff's failure to appear, holding that the district court did not abuse its discretion.Plaintiff failed personally to attend the settlement conference conference, despite pretrial orders and a local rule requiring his attendance. Defendants attended the conference, but Plaintiff did not. The district court refused to hold the conference without Plaintiff present and granted one of the defendant's motions for sanctions. The Supreme Court upheld the district court's order, holding that the district court did not exceed its jurisdiction or otherwise act illegally in finding Plaintiff in violation of the court's trial-setting order when he failed personally to appear for the scheduled settlement conference and in directing the specific sanction in this case. View "Davis v. Iowa District Court for Scott County" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing Appellant's petition for judicial review, holding that timely faxing a petition for judicial review to the opposing party's counsel, where the petition is actually received and no prejudice results, constitutes substantial compliance under Iowa Code 17A.19(2).Appellant filed four petitions with the Iowa Workers' Compensation Commission against Respondents, her employer and its workers' compensation insurance carrier, alleging that she received several workplace injuries. The commissioner largely denied the petitions. Appellant then filed a pro se petition with the district court seeking judicial review. The petition was electronically filed, and Appellant faxed copies the same day to Respondents and the workers' compensation commission. The district court granted Respondents' motion to dismiss, concluding that Appellant's sending of a fax of her petition was not substantial compliance with the requirements of section 17A.19(2). The Supreme Court reversed, holding that Appellant substantially complied with the service requirements in section 17A.19(2). View "Logan v. Bon Ton Stores, Inc." on Justia Law

The Supreme Court affirmed the order of the district court concluding that Husband, who had a recent income history less than that of Wife, was not entitled to alimony under the facts and circumstances developed at trial, holding that Husband was not entitled to alimony.In determining that the record did not support alimony for Husband, the district court held that traditional alimony would not be appropriate based upon the length of the marriage and the earning capacity of both parties. The district court further declared that there was no basis for reimbursement or rehabilitative alimony. The court of appeals awarded Husband three years of alimony. The Supreme Court reversed, holding that, based on a totality of all the relevant factors, the district court properly declined to award Husband alimony in this case. View "In re the Marriage of Mann" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing for lack of standing Attorney's petition for judicial review of the decision of the Iowa Ethics and Campaign Disclosure Board dismissing Attorney's complaint that the Governor had underreported the fair market value of a trip to Tennessee, holding that the district court properly concluded that Attorney lacked standing in this case.To comply with campaign disclosure requirements, the Governor's campaign committee reported the trip as a $2800 campaign contribution from an individual donor. Attorney complained to the Board that the Governor had underreported the fair market value of the trip, but the Board dismissed the complaint. Attorney petitioned for judicial review. The district court dismissed the petition, concluding that Attorney had not been injured by the Board's action, nor had he been deprived of any information. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Attorney was not an "aggrieved or adversely affected" party within the meaning of Iowa Code 17A.19; and (2) because Attorney did not allege he was lacking any relevant information but merely voiced a a disagreement over the reporting method used by the candidate committee, Attorney lacked standing. View "Dickey v. Iowa Ethics & Campaign Disclosure Board" on Justia Law

The Supreme Court affirmed Defendant's conviction for assault on a peace officer with a dangerous weapon, a felony, and several misdemeanors, holding that Defendant did not receive ineffective assistance of counsel.After Defendant pleaded guilty, he absconded. He was later returned to custody. On appeal, Defendant argued that he received ineffective assistance of counsel because the plea bargain contained an unlawful term. Specifically, Defendant argued that the plea bargain's provision that he would be released from jail for a forty-eight-hour furlough after pleading guilty was illegal and that his trial counsel committed ineffective assistance in obtaining the illegal benefit for him. The Supreme Court affirmed, holding that where Defendant entered into the plea agreement with the illegally lenient sentence, he could not benefit from that sentence and then attack the plea bargain. View "State v. Gordon" on Justia Law

The Supreme Court affirmed the order of the district court denying Claimant's petition for judicial review challenging the decision of the workers' compensation commissioner concluding that Claimant, who was receiving disability benefits for a traumatic injury, could not later recover disability benefits on a separate cumulative injury claim where the cumulative injury was based solely on aggravation of the earlier traumatic injury.Because the three-year statute of limitations for review-reopening had passed Claimant instead brought a separate cumulative injury claim. The commissioner declined to award benefits for the asserted cumulative injury. The district court upheld the commissioner's ruling. The court of appeals reversed, concluding that because Claimant was precluded by the statute of limitations from bringing an original proceeding or review-reopening she could recover by way of a cumulative-injury claim. The Supreme Court reversed, holding that sufficient record evidence sustained the commissioner's finding that Claimant's difficulties were merely the aggravation over time of her original injury and that Claimant did not suffer a distinct and discrete cumulative injury to support additional benefits. View "Gumm v. Easter Seal Society of Iowa, Inc." on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder after declining Defendant's invitation to change constitutional precedent to further limit the admissibility of eyewitness identifications following police photo arrays, holding that the double-blind procedures used in this case were not unduly suggestive and that Defendant received effective assistance of counsel.On appeal, Defendant argued (1) because the police used unduly suggestive photographic identification procedures the district court erred by failing to grant his motion to suppress the resulting identification; and (2) trial counsel was ineffective for failing to request jury instructions on eyewitness identifications that reflect modern scientific research. The court of appeals affirmed the conviction while preserving for possible postconviction relief action Defendant's ineffective assistance of counsel claim. The Supreme Court affirmed in part and vacated in part the court of appeals' decision, holding (1) the eyewitness identification was not unduly suggestive; and (2) contrary to the decision of the court of appeals, the record was adequate to decide the ineffective assistance of counsel claim challenging the jury instruction on eyewitness identification, and this claim is rejected on the merits. View "State v. Booth-Harris" on Justia Law