Justia Iowa Supreme Court Opinion Summaries

The Supreme Court vacated Defendant's guilty plea to possessing a tool with the intent to use it in the unlawful removal of a theft detection device under Iowa Code 714.7B(3), holding that there was no factual basis to support Defendant's guilty plea to this charge.Defendant's conviction arose from his act of using bolt cutters to cut the padlock off of a steel cable wrapped around a riding lawn mower on display outside of a Mills Fleet Farm. Defendant pled guilty violating section 714.7B(3). On appeal, Defendant argued that the padlock-steel cable combination device he cut with bolt cutters was not a "theft detective device" under section 714.7B, and therefore, his trial counsel was ineffective for allowing him to plead guilty to this charge.The Supreme Court agreed and vacated Defendant's guilty plea, holding (1) the padlock-steel cable combination did not constitute a "theft detective device" under the statute, and therefore, there was no factual basis to support Defendant's guilty plea; and (2) Defendant's counsel was ineffective for allowing Defendant to plead guilty. View "State v. Ross" on Justia Law

In this appeal from the district court's denial of a motion to dismiss and compel arbitration the Supreme Court held that the court-appointed liquidator of a now-insolvent health insurer pursuing common law tort claims against a third-party contractor is bound by an arbitration provision in a preinsolvency agreement between the health insurer and the third-party contractor.Prior to its insolvency, the health insurance provider entered into an agreement with a third-party contractor for consulting services. The provider was later declared insolvent and placed into liquidation. Plaintiff, the provider's court-appointed liquidator, brought an action against the contractor, asserting common law tort damages. The contractor filed a motion to dismiss and compel arbitration on the grounds that the parties' agreement contained an arbitration clause. The district court denied the motion, concluding that the arbitration provision did not apply. The Supreme Court reversed, holding (1) the liquidator was bound by the arbitration provision because the liquidator stood in the shoes of the provider; (2) the liquidator could not use Iowa Code 507C.21(k) to disavow a preinsolvency agreement that the contractor already performed; and (3) the McCarran-Ferguson Act does not permit reverse preemption of the Federal Arbitration Act when the liquidator asserts common law tort damages against a third-party contractor. View "Ommen v. MilliMan, Inc." on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of child endangerment, holding that the evidence was sufficient to support Defendant's conviction.During trial, the State was required to prove Defendant had custody of her child and that she knowingly acted in a manner that created a substantial risk to her child's health or safety. The district court concluded that the State met its burden of production and persuasion. The Supreme Court affirmed, holding that Defendant's failure to remove her child from a physical environment that caused a risk of fire was sufficient to establish that Defendant had knowledge she had created or allowed her child to remain in a physical environment that posed a substantial risk to her child's physical health and safety. View "State v. Folkers" on Justia Law

The Supreme Court affirmed the judgment of the district court finding that Plaintiffs had a "losing cause of action," concluding that Plaintiffs' claims against Defendants were frivolous, and granting Defendants' motion for costs and expenses, holding that the district court did not err or abuse its discretion.A group of property owners alleged that confined animal feeding operations (CAFOs) operated and supported by Defendants amounted to a nuisance. The plaintiffs later dismissed their lawsuit because they failed to exhaust farm mediation and then later refiled. Two of the plaintiffs (together, Plaintiffs), however, voluntarily dismissed their claims a second time, resulting in an adjudication against them on the merits. Defendants sued Plaintiffs seeking costs and expenses pursuant to Iowa Code 657.11(5). The district court granted the motions. The Supreme Court affirmed, holding (1) two voluntary dismissals meant Plaintiffs had "a losing cause of action"; (2) Plaintiffs' claims were frivolous; and (3) the district court's apportionment of costs and expenses was appropriate. View "Merrill v. Valley View Swine, LLC" on Justia Law

The Supreme Court reversed the foreclosure decree entered by the district court giving priority under a future-advances clause to the full amount of credit extended by the first lienholder rather than the maximum amount set forth in the notice provision of the first lienholder's mortgage, holding that the first lienholder's priority was capped at $148,000.A bank made a series of loans to a farmer and obtained a mortgage with a future-advances clause on a farm property. The bank's mortgage contained language stating that the mortgage secured credit in the amount of $148,000. The farmer later took out a loan from a second bank, also secured in part by the same farm property. When the first bank filed a foreclosure proceeding, the parties disputed whether the first bank's lien had priority for all amounts due to the first bank or only up to $148,000. The district court found that the first bank's priority was not limited to $148,000 but extended to all debt secured by the mortgage. The Supreme Court reversed, holding (1) the first bank's priority was capped at $148,000, plus interest; and (2) the first bank was not allowed to collect default interest at eighteen percent as part of its first-priority lien where there was no written agreement to pay that rate. View "Blue Grass Savings Bank v. Community Bank & Trust Co." on Justia Law

In this construction law case, the Supreme Court reversed the order of the circuit court granting summary judgment in favor of Appellee, holding that Appellee was not entitled to claim preclusion or issue preclusion even though the federal court found in Appellee favor in a parallel federal case.The dispute in this case arose out of a contract between two subcontractors in a construction project. In the federal case, subcontracting parties litigated questions related to the fabrication of the salt conveyor system. The federal district court ruled in favor of Appellee. Appellant filed a second lawsuit in state court against subcontractors involved in the federal case. Appellee filed a motion for summary judgment, arguing that the judgment in the federal litigation compelled judgment in its favor in the state court litigation. The district court granted summary judgment for Appellee on both claim preclusion and issue preclusion. The Supreme Court reversed, holding (1) under Noel v. Noel, 334 N.W.2d 146 (Iowa 1983), and Pagel v. Notbohm, 186 N.W.2d 638 (Iowa 1971), Appellee waived its claim preclusion argument; and (2) that the state district court ruling took too broad an approach to what the "issue" was in the federal lawsuit. View "Lemartec Engineering & Construction v. Advance Conveying Technologies, LLC" on Justia Law

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