Justia Iowa Supreme Court Opinion Summaries

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

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of an insurer on the grounds that the plaintiff's contractual assignment was unenforceable, holding that a residential contractor acting as an unlicensed public adjuster cannot enforce its post-loss contractual assignment of insurance benefits against the homeowner's insurer.The contractor in this case represented homeowners as an assignee of their insurance claim for storm damage to their home. The district court concluded that the contractor's contractual assignment was invalid because the contractor acted as an unlicensed public adjuster. The Supreme Court affirmed, holding that the district court did not err in ruling that the contractor acted as an unlicensed public adjuster and that the assignment contract was void and unenforceable under Iowa Code 103A.71(5). View "33 Carpenters Construction, Inc. v. IMT Insurance Co." on Justia Law

In this appeal challenging several district court rulings in a grand jury proceeding the Supreme Court affirmed in part and reversed in part the judgment of the district court, holding that the State cannot subpoena a criminal defense expert but that the prosecution's contact with the expert does not merit recusal and that there was no basis to quash the grand jury proceeding.Before the grand jury proceedings, the prosecutor contacted an expert witness retained by John Doe, who faced possible criminal charges, and asked the expert her opinions about the matter. When the expert declined to substantively respond, the prosecutor served the expert with a subpoena to appear before the grand jury. Doe moved to quash the subpoena and to disqualify the prosecutor from the proceeding. Doe also sought to quash the grand jury proceedings. The district court denied the motion. The Supreme Court affirmed in part and reversed in part, holding (1) the district court erred in not quashing the grand jury subpoena of Defendant's retained expert; (2) the issuance of the subpoena did not amount to the kind of misconduct that requires the disqualification of the prosecutor; and (3) the district court did not err in declining to quash the grand jury. View "In re 2018 Grand Jury of Dallas County v. Doe" on Justia Law

The Supreme Court affirmed the district court's grant of summary judgment for an insurer on the grounds that the plaintiff's contractual assignment was unenforceable, holding that a residential contractor acting as an unlicensed public adjuster cannot enforce its postloss contractual assignment of insurance benefits against the homeowner's insurer.Iowa Code 103A.71(5) declares void contracts entered into by residential contractors who perform public adjuster services without the license required under Iowa Code 522C.4. The contractor in this case represented homeowners as an assignee of their insurance claim for hail damage to their home. The district court concluded that the contractor's contractual assignment was invalid under section 103A.71(5) because the contractor acted as an unlicensed public adjuster. The Supreme Court affirmed, holding that the district court did not err in ruling that the contractor acted as an unlicensed public adjuster and that the assignment contract was unenforceable and void under Iowa law. View "33 Carpenters Construction, Inc. v. State Farm Fire & Casualty Co." on Justia Law

The Supreme Court vacated the court of appeals' decision affirming the district court's dismissal of a physician's petition for judicial review of the Iowa Board of Medicine's decision to use a "confidential letter of warning" to impose conditions on the physician's return to the practice of medicine over his objection, without a finding of probable cause, and without judicial review, holding that the district court erred by ruling that the Board's letter was not judicially reviewable.Before the physician voluntarily ceased practicing medicine the Board had opened an investigation into the physician. The Board closed the investigation without a finding of probable cause that the physician had violated any rule or standard of practice. In its letter, the Board told the physician that if he returned to practicing medicine he must complete a comprehensive clinical competency evaluation. The physician sought judicial review, contending that the Board's letter constituted illegal agency action. The district court dismissed the action, concluding that the letter was not a disciplinary sanction subject to judicial review. The Supreme Court vacated the decision, holding that the Board's letter was subject to judicial review because the physician was aggrieved by the Board's action where he was unable to resume practicing his profession without triggering the competency evaluation. View "Irland v. Iowa Board of Medicine" on Justia Law