Justia Iowa Supreme Court Opinion Summaries

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

The Supreme Court vacated the order of restitution in this criminal case for the reasons explained today in State v. Davis, __ N.W.2d __ (Iowa 2020), concluding that interim orders on components of restitution requiring a reasonable ability to pay are neither appealable nor enforceable, but because the district court did not have the benefit of State v. Albright, 925 N.W.2d 144 (Iowa 2019) in issuing the restitution order, the order is vacated and the case remanded for further proceedings.Defendant entered a guilty plea to sexual abuse in the third degree. The court placed Defendant on probation, ordered him to register as a sex offender, and ordered that Defendant pay $204 in court costs, stating that additional amounts could be assessed at a later date. Defendant filed this direct appeal from his judgment of sentence, arguing that the district court erred in ordering him to pay restitution when it did not know the total amount of those costs and had not conducted a reasonable-ability-to-pay determination. The State argued in response that Defendant's appeal was unripe because no final restitution order had been entered. The Supreme Court vacated the restitution order and remanded the matter for further proceedings because the district court did not have the benefit of Albright. View "State v. Staake" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court holding that a commercial general liability (CGL) policy and a related excess liability declaration do not cover claims brought by the estate and spouse of an employee who was fatally injured while working for Adventureland Amusement Park, holding that the district court erred in granting summary judgment.The decedent was serving as a loading assistant on a river ride when he was fatally injured. The decedent's estate and his widow filed a district court action, later removed to federal court, alleging that the decedent's injuries were a result of grossly negligent acts by the ride's operator, the decedent's coemployee. The insurer filed a declaratory action in state court seeking a declaration that it had no duty to defend or indemnify the coemployee in the federal action. The district court granted summary judgment for the insurer. The Supreme Court reversed in part, holding that there remained a question of fact as to whether the estate has a claim that amounts to gross negligence but is within the scope of the coverage of the CGL policy. View "T.H.E. Insurance Co. v. Estate of Booher" on Justia Law

In this criminal case arising from Appellant's act of writing checks without authorization from a bank account that was not hers the Supreme Court reversed the judgment of the district court denying Appellant's motion for acquittal, holding that the State failed to present sufficient evidence supporting a conviction under Iowa Code 714.1(6).Appellant was convicted under section 714.1(6), which forbids knowingly presenting a check that will not be paid when presented. The checks the State charged Appellant with writing were paid when presented. On appeal, Appellant argued that presenting a check without authorization was different than providing a check one knows will not be paid when presented. The Supreme Court agreed and reversed, holding that the State failed to present sufficient evidence that Appellant knew the checks would not be paid when presented, and therefore, there was insufficient evidence to support Appellant's conviction under section 714.1(6). View "State v. Schiebout" on Justia Law