Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's sentence for theft after Defendant pleaded guilty, holding that "good cause" under the newly amended Iowa Code 814.6 means a "legally sufficient reason," and the good cause requirement is satisfied when the defendant appeals a sentence that was neither mandatory nor agreed to in the plea bargain.Defendant pleaded guilty to two separate charges of theft in the third degree. The court sentenced Defendant to an indeterminate term of two years of incarceration for each case to run concurrently. Defendant appealed, arguing that the sentencing court abused its discretion by considering improper factors when imposing her sentence. The State responded that the Supreme Court lacked jurisdiction over Defendant's appeal without a showing of good cause under the newly amended Iowa Code 814.6. The Supreme Court affirmed, holding (1) Defendant satisfied the good-cause requirement to proceed with her appellate challenge to the sentence; and (2) on the merits, Defendant's challenge to her sentence failed. View "State v. Damme" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court reversing the decision of the Iowa Department of Human Services (DHS) that a child-care provider must pay back benefits the provider received during agency review of her cancelled provider agreement, holding that DHS erred in refusing to consider the provider's unjust enrichment defense to the recoupment proceeding.At issue was whether the provider was given constitutionally sufficient notice of DHS's intent to recoup payments. DHS sent the provider a notice cancelling the provider agreement and noted that any benefits the provider got while her appeal was being decided "may have to be paid back if the Department's action is correct." DHS affirmed its decision to cancel the provider's agreement but did not find, until years later, that the provider had to pay back the $16,000. The district court reversed DHS's decision on recoupment and denied attorney fees under Iowa Code 625.29(1)(b). The Supreme Court reversed in part, holding (1) DHS's notice met procedural due process requirements, but the DHS should have been allowed an opportunity to raise unjust enrichment as an offset to DHS's effort to recoup overpayments; and (2) where DHS's role was primarily adjudicative, DHS was not liable for attorney fees. View "Endress v. Iowa Department of Human Services" on Justia Law

The Supreme Court affirmed in part and vacated in part the court of appeals' decision and affirmed in part and reversed in part the judgment of the district court, holding that a child-care provider whose provider agreement and registration was cancelled should be allowed to raise unjust enrichment as an offset to the Iowa Department of Human Services' (DHS) effort to recoup $31,815 for child-care services the provider rendered during agency review.This appeal was a companion case to Endress v. Iowa Department of Human Services, __ N.W.2d __ (Iowa 2020), also decided today. DHS attempted to recoup child-care service payments during agency review of the provider's cancelled provider agreement and registration. On appeal, the court of appeals held that DHS's notice concerning recoupment of overpayments was constitutionally deficient. The Supreme Court (1) vacated the court of appeals' decision on the constitutional issue, holding that DHS's notice of recoupment met procedural due process requirements; and (2) remanded the case to the district court to remand to DHS for consideration of the provider's equitable relief, holding that the provider should have been allowed to pursue her claim for unjust enrichment. View "Pfaltzgraff v. Iowa Department of Human Services" on Justia Law

The Supreme Court granted Jane Doe's petition for writ of certiorari, sustained the writ, and vacated the order of the district court denying Doe's application to expunge her criminal record as to three separate cases pursuant to Iowa Code 901C.2, holding that the court erred in denying the application on the ground that Doe had court-ordered financial obligations in other cases.In the three separate cases at issue the charges were all dismissed. Doe later filed an application for expungement of the record in each of the cases. The district court denied the application on the ground that Doe had "[m]onies owed in other matters." The Supreme Court vacated the district court's order denying expungement, holding (1) pursuant to State v. Doe, __ N.W.2d __ (Iowa 2020), filed today, the requisite condition for expungement requires that the defendant establish only that he satisfied all of the court-ordered financial obligations in the criminal case for which expungement was sought; and (2) in the instant case, the district court erred in concluding that Iowa Code 901C.2(1)(a)(2) required Defendant to establish that she also satisfied all court-ordered financial obligations in other cases. View "Doe v. State" on Justia Law

The Supreme Court granted Jane Doe's petition for writ of certiorari, sustained the writ, and vacated the order of the district court denying Doe's application to expunge her criminal record as to a particular case pursuant to Iowa Code 901C.2, holding that the court erred in denying the application on the ground that Doe had court-ordered financial obligations in other cases.In 2011, Doe was charged with one count of unauthorized use of a credit card. The charge was dismissed, and Doe subsequently satisfied all of her financial obligations in the dismissed case. In 2019, Doe filed her application to expunge the criminal record. The district court denied the application because Doe had court-ordered financial obligations remaining in other cases and thus did not meet the requisite condition set forth in section 901C.2(1)(a)(2). The Supreme Court vacated the district court's order, holding that the district court (1) erred in concluding that section 901C.2(1)(a)(2) required Defendant to establish that she satisfied all financial obligations in both this case and in any other case; and (2) erred in denying Doe's application on that ground. View "Doe v. State" on Justia Law

The Supreme Court granted John Doe's petition for writ of certiorari, sustained the writ, and vacated the order of the district court denying Doe's application to expunge his criminal record as to a particular case pursuant to Iowa Code 901C.2, holding that the court erred in denying the application on the ground that Doe had court-ordered financial obligations in other cases.In 2000, Doe was charged with escape. The charge was later dismissed. In 2019, Doe filed an application for expungement of the record. The district court denied the application on the ground that Doe had court-ordered financial obligations in other cases. The Supreme Court vacated the district court's order denying expungement, holding (1) pursuant to State v. Doe, __ N.W.2d __ (Iowa 2020), filed today, the requisite condition for expungement requires that the defendant establish only that he satisfied all of the court-ordered financial obligations in the criminal case for which expungement was sought; and (2) in the instant case, the district court erred in concluding that section 901C.2(1)(a)(2) required Defendant to establish that he also satisfied all court-ordered financial obligations in other cases. View "Doe v. State" on Justia Law

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