Justia Iowa Supreme Court Opinion Summaries

The Supreme Court reversed the ruling of the district court certifying a class action of employees with pending workers' compensation claims, holding that the district court abused its discretion by certifying this case as a class action.Employee filed this civil action on behalf of himself and other "similarly situated" employees who signed a memorandum of understanding (MOU) as a condition of employment providing for short-term light duty and treatment in Des Moines after sustaining a work-related injury. Before the instant case was filed, an Iowa court determined the MOU as applied to Employee violated Iowa Code 85.18 and 85.27(4). The district court certified the case as a class action. The Supreme Court reversed, holding that because the commonality requirement was lacking, individual issues predominated over common ones, and because workers' compensation claims must be resolved by the workers' compensation commission before judicial review, the district court erred in certifying this case as a class action. View "Roland v. Annett Holdings, Inc." on Justia Law

The Supreme Court dismissed Appellant's appeal from an order of the district court directing Appellant to pay room and board reimbursement for the seventy-eight days Appellant spent in the Mills County jail, holding that this Court lacked jurisdiction to consider matters raised in the restitution order or any other subsequent order of the court.On September 24, 2018 Appellant entered guilty pleas in two sex abuse cases. On October 5, after Appellant was sentenced, the sheriff a room and board reimbursement claim seeking a total of $4680 for the time Appellant spent in jail. The district court approved the claim and ordered Appellant to pay the amount. Appellant appealed, seeking relief from the district court's September 24 order. However, Appellant's entire argument was a challenge to the October 5 order. The Supreme Court dismissed the appeal, holding that it lacked jurisdiction to consider matters raised in the October 5 restitution order. View "State v. Boyer" on Justia Law

The Supreme Court annulled the writ of certiorari sought by Defendant after the district court denied his motion to correct an illegal sentence, holding that Iowa Code 124.413 and 901.12 serve to reduce the minimum period of confinement for specific criminal drug offenses and that Defendant's minimum period of confinement was not eligible for the one-half reduction.Defendant pled guilty to possession of methamphetamine with intent to deliver and to possession or control of a firearm. Defendant's guilty plea to the firearm charge enhanced the drug charge by doubling his maximum sentence to fifty years. The legislature later amended section 124.413 and created section 901.12, which amended Iowa law by retroactively reducing particular mandatory sentences by one-half. Defendant filed a motion to correct an illegal sentence arguing that section 901.12 reduced his minimum period of confinement by one-half. The district court denied the motion. The Supreme Court granted certiorari review but then annulled the writ, holding that Defendant's firearm-enhanced sentence was not eligible for the one-half reduction. View "Campuzano v. Iowa District Court for Polk County" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment for Defendants on Plaintiffs' medical malpractice claims, holding that Plaintiffs failed to set forth specific facts showing a prima facie case of causation and lost chance of survival.Sharon Susie lost her right arm and eight of her toes due to a disorder known as necrotizing fasciitis. Sharon and her husband (together, Plaintiffs) filed a negligence claim against Defendants seeking damages for the amputation of Sharon's arm and other injuries. Plaintiffs alleged that Defendants were negligent because Sharon's condition was not properly diagnosed and treatment was not timely commenced and that Defendants' actions resulted in the lost chance to save Sharon's arm and toes from amputation. The district court granted summary judgment for Defendants. The Supreme Court affirmed, holding that summary judgment was properly granted because Plaintiffs failed to set forth specific facts showing a prima facie case of causation and lost chance of survival. View "Susie v. Family Health Care of Siouxland, P.L.C." on Justia Law

In this action brought by a law firm seeking to enforce its payment due under a contingency fee contract the Supreme Court affirmed the judgment of the district court ordering judgment against the family that retained the law firm for one-third of their recovery plus interest, holding that the one-third contingency fee contract was reasonable at the time of its inception.After a car accident left a motorist in critical condition, the motorist's family (Appellants) retained a law firm to represent the motorist's interests. A contingency fee contract required Appellants to pay one-third of the recovery to the law firm for attorney fees. Appellants accepted a $7.5 million offer to settle the case. When Appellants failed to pay the contingency fee the law firm brought this action to enforce its payment. Appellants argued that the one-third contingency fee contract violated Iowa Rule of Professional Conduct 32:1.5(a) because it was an unreasonable fee. Judgment was ordered against Appellants for one-third of the recovery plus interest. The Supreme Court affirmed, holding (1) the one-third contingency fee agreement was reasonable at the time of its inception; and (2) this Court will not use the noncontingency fee factors under Rule 32:1.5(a) to reevaluate the contingency fee contract from a position of hindsight. View "Munger, Reinschmidt & Denne, LLP v. Plante" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing Appellant's petition for postconviction relief, holding that the limitations period for challenging Appellant's convictions had expired and that his resentencing did not bring about a new limitations period for attacking his conviction.In 2011, Appellant pled guilty to second-degree robbery and forgery. In 2015, the district court granted Appellant's motion to correct an illegal sentence. Appellant was resentenced. That same, year, Appellant filed the instant petition for postconviction relief. The State moved for summary judgment, arguing that Appellant's petition was time barred under the three-year statute of limitations in Iowa Code 822.3. The district court dismissed the petition. The court of appeals affirmed. The Supreme Court affirmed, holding that the resentencing of Defendant, which did not affect his underlying convictions, did not restart section 822.3's time clock. View "Sahinovic v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court imposing a seventeen and one-half year mandatory minimum prison term before parole eligibility on Defendant's second resentencing for attempted murder during a home invasion after considering the youth sentencing factors under State v. Roby, 897 N.W.2d 127 (Iowa 2017), holding that there was no error in the sentence and that counsel was not constitutionally ineffective.Defendant was seventeen years old at the time of the crime and was since resentenced twice, once in 2014 and once in 2018, as caselaw on juvenile sentencing evolved. In this appeal from his latest resentencing, Defendant argued that the district court failed to follow the Supreme Court's 2017 mandate to apply Roby and that his counsel was constitutionally ineffective for failing to retain a defense expert on the youth sentencing factors. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in applying the Miller/Lyle/Roby factors and deciding to impose the mandatory minimum sentence; and (2) Defendant's defense counsel had no duty to present a defense expert to testify regarding the Roby factors where Defendant decided to forgo retaining a defense expert. View "State v. Majors" on Justia Law

The Supreme Court vacated in part and affirmed in part the decision of the court of appeals affirming Defendant's conviction of voluntary manslaughter, holding that the court of appeals correctly found that the district court correctly determined that Defendant was not justified in his use of deadly force because he continued the incident which resulted in the victim's death.On appeal from his conviction of voluntary manslaughter Defendant argued that he was justified in his use of deadly force. The district court rejected the argument, finding that Defendant continued the incident with the victim and could have pursued an alternative course of action by retreating. The court of appeals affirmed, concluding that, while Defendant did not continue the incident with the victim, Defendant was not justified in his use of self-defense because he had an alternative course of action available. The Supreme Court held (1) Defendant continued the incident that resulted in the victim's death, and therefore, substantial evidence supported the district court's finding that Defendant was not justified in his use of deadly force; and (2) Defendant was not entitled to relief on his due process and equal protection claims. View "State v. Fordyce" on Justia Law

The Supreme Court reversed the judgment of the district court awarding Plaintiff compensatory and punitive damages in his action for first-party bad faith in connection with a workers' compensation claim, holding that the compensatory award must be reduced and that, under the federal Due Process Clause, the maximum amount of punitive damages that may be awarded under the facts of this case was $500,000.Plaintiff, who was severely injured at work, brought this lawsuit alleging that a workers' compensation insurance carrier acted in bad faith to delay the receipt of benefits to which Plaintiff was entitled. On retrial, the jury returned a verdict in favor of Plaintiff for $382,000 in compensatory damages and $6,750,000 in punitive damages. The Supreme Court reversed, holding (1) Plaintiff failed to offer substantial evidence to support his claim that the insurance carrier engaged in bad faith in connection with an alleged delay in acquisition of a replacement wheelchair; (2) with respect to the permanently and totally disabled bad-faith claim, the evidence supported actual damages of no more than $58,452,42; and (3) the maximum amount of punitive damages that may be awarded in this case is $500,000. View "Thornton v. American Interstate Insurance Co." on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court upholding the final agency action of the Employment Appeal Board (EAB) denying unemployment benefits, holding that substantial evidence supported the EAB's determination that Employee voluntarily quit.Employee was employed with a temporary employment agency. The agency informed Employee by phone that the workplace where she had been assigned was ending her assignment, after which Employee hung up the phone. Thereafter, Employee applied for unemployment benefits and did not attempt to resume contact with the agency for almost five weeks. In denying benefits, the EAB determined that Employee voluntarily quit her employment without good cause attributable to the employer. The district court and court of appeals affirmed. The Supreme Court affirmed, holding (1) the EAB's determination that Employee voluntarily quit was supported by substantial evidence; and (2) substantial evidence supported the EAB's finding that Employee did not meet the safe harbor in Iowa Code 96.5(1)(j)(1) relating specifically to temporary employees of temporary employment firms. View "Sladek v. Employment Appeal Board" on Justia Law