Justia Iowa Supreme Court Opinion Summaries

The case involves $14,100.00 in cash seized by the Linn County Sheriff’s Office from a Bitcoin ATM kiosk in Cedar Rapids during a fraud investigation. Bitcoin Depot, the owner of the ATM, sought the return of the seized funds, while Carrie Carlson, the customer who deposited the money, also filed a competing claim for the return of the funds. Carlson had deposited the money into the ATM and received Bitcoins in return, which were transferred to a wallet as directed by a scammer.The Iowa District Court for Linn County held a hearing on the competing claims and ordered the return of the seized funds to Carlson. The court reasoned that Carlson was a victim of fraud and likened the situation to recovering stolen property from a pawnbroker. The court also considered the transaction a "smart contract" and concluded that Bitcoin Depot had reason to know of potential duress due to the warning provided on the ATM.The Iowa Supreme Court reviewed the case de novo and concluded that Bitcoin Depot had the greater right to possession of the seized funds. The court found that Bitcoin Depot acted in good faith and without reason to know of Carlson’s duress. The court rejected the district court’s analogy to pawnbrokers and the characterization of the transaction as a smart contract that inherently involved knowledge of duress. The court held that Carlson did not meet her burden to show that Bitcoin Depot had reason to know of her duress, and thus, the contract was not voidable.The Iowa Supreme Court reversed the district court’s order and remanded the case with instructions to return the seized funds to Bitcoin Depot. View "In the Matter of Property Seized for Forfeiture from Bitcoin Depot Operating, LLC v. Carlson" on Justia Law

Vanessa Gale was at a convenience store in Davenport when she encountered Romaro Houston. They walked outside together and got into Gale’s car. Shortly after, police officers arrived to arrest Houston, leading to a search of Gale’s body and purse. The search uncovered cash, methamphetamine, and marijuana. Gale was arrested and charged with possession of a controlled substance and possession of marijuana, both alleged as second offenses.In the Iowa District Court for Scott County, Gale filed a motion to suppress the evidence from the search, arguing that the stop and subsequent search were unlawful. The district court denied her motion. Gale consented to a trial on the minutes of testimony, and the court found her guilty on both counts, sentencing her based on the belief that she had prior convictions for possession of a controlled substance.Gale appealed, and the case was transferred to the Iowa Court of Appeals. She argued that the district court erred in denying her motion to suppress and that her sentence was illegal because her prior conviction did not qualify as a predicate offense under Iowa Code § 124.401(5). The State agreed that the minutes of testimony were inaccurate regarding her prior conviction. The court of appeals affirmed the district court’s denial of the motion to suppress and upheld the sentence, stating it could not take judicial notice of the Cedar County case filings.The Iowa Supreme Court reviewed the case and agreed with the parties that Gale’s prior conviction was for possession of prescription drugs without a prescription, which does not qualify as a predicate offense under § 124.401(5). The court concluded that Gale’s sentence for second-offense possession counts was illegal and remanded the case for resentencing. The decision of the court of appeals was affirmed in part and vacated in part, and the district court judgment was affirmed in part and reversed in part. View "State of Iowa v. Gale" on Justia Law

Ronald Eugene Cooley was charged with failing to fulfill his sex offender registration requirements after moving to a new address. Iowa law mandates that sex offenders must appear in person to notify the sheriff of any change in residence within five business days. Cooley claimed he attempted to register his new address in person, but the sheriff's office was closed due to the COVID-19 pandemic. The State argued that Cooley could have registered by calling a phone number posted on the sheriff's office door. The district court did not include the "appear in person" requirement in the jury instructions, and Cooley was convicted.The Iowa District Court for Linn County denied Cooley's motions for acquittal and a new trial, concluding that the closure of the sheriff's office did not absolve Cooley of his duty to register. The court of appeals affirmed the conviction, agreeing that the district court did not err in omitting the in-person requirement from the jury instructions.The Iowa Supreme Court reviewed the case and determined that appearing in person is an essential element of the crime of failing to register a change of address. The court found that the district court erred by not including this requirement in the jury instructions. The court concluded that the error was not harmless, as it could not be determined whether the jury would have found Cooley guilty beyond a reasonable doubt if properly instructed. The Iowa Supreme Court vacated the decision of the court of appeals, reversed the district court judgment, and remanded the case for a new trial. View "State of Iowa v. Cooley" on Justia Law

A former high school tennis coach was accused of inappropriate touching and harassment by students. The school district investigated and found no inappropriate touching or bullying but recommended the coach avoid touching players. After the investigation, the coach posted on social media, which was perceived as targeting former players. At a public school board meeting, two students expressed dissatisfaction with the investigation. The school district posted an unaltered video of the meeting online, placed the coach on paid administrative leave, and did not renew her contract. The coach requested the video be altered or removed, but the district refused.The coach filed claims of defamation and wrongful termination in violation of public policy against the school district. The Iowa District Court for Johnson County granted summary judgment in favor of the school district, finding the republication of the statements was protected by the fair-report privilege and that the coach failed to demonstrate a well-established public policy. The Iowa Court of Appeals affirmed the district court's decision.The Iowa Supreme Court reviewed the case and affirmed the decisions of the lower courts. The court held that the fair-report privilege protected the school district's republication of the students' statements made at the public meeting, as the video was an accurate and complete report of an official proceeding. The court also found that the coach did not identify a clearly defined and well-recognized public policy that was violated by her termination. Thus, the defamation and wrongful termination claims were dismissed. View "Villarini v. Iowa City Community School District" on Justia Law

Minor Doe, Father Doe, and Mother Doe filed a lawsuit against the Western Dubuque Community School District and several school officials after Minor Doe was assaulted by another student during class. The plaintiffs claimed negligence, breach of fiduciary duty, and loss of consortium. The school did not contact medical personnel or the parents after the incident, and Minor Doe was later diagnosed with a concussion.The Iowa District Court for Dubuque County dismissed the case on four grounds: failure to meet the heightened pleading requirements of the Iowa Municipal Tort Claims Act (IMTCA), improper use of pseudonyms, failure of the breach of fiduciary duty claim as a matter of law, and the consortium claim failing without the underlying causes of action. The plaintiffs appealed the dismissal.The Iowa Supreme Court reviewed the case and concluded that the district court erred in dismissing the case based on the IMTCA’s qualified immunity provision and the use of pseudonyms. The court held that the IMTCA’s qualified immunity provision does not apply to common law claims and that pseudonymous petitions are generally disfavored but may be allowed in certain circumstances. The court found that the plaintiffs should have been given an opportunity to amend their petition to use their real names. However, the court affirmed the dismissal of the breach of fiduciary duty claim, stating that schools and their officials do not generally have fiduciary relationships with students.The Iowa Supreme Court reversed the district court’s dismissal of the negligence and consortium claims and remanded the case for further proceedings, while affirming the dismissal of the breach of fiduciary duty claim. View "Doe v. Western Dubuque Community School District" on Justia Law

In the fall of 2021, the League of United Latin American Citizens of Iowa (LULAC) filed a petition against the Iowa Secretary of State, the Iowa Voter Registration Commission, and several county auditors. LULAC challenged a 2008 permanent injunction from a different case, which prohibited the dissemination of voter registration forms in languages other than English under the Iowa English Language Reaffirmation Act. LULAC argued that the injunction was wrongly decided and sought its dissolution, along with a declaration that the Act allowed for non-English voting materials.The Iowa District Court for Polk County granted LULAC’s requests, dissolving the King injunction and issuing a declaratory judgment that the Act did not apply to voting materials. The court held that voting materials were necessary to secure the right to vote and thus fell within the rights exception of the Act.The Iowa Supreme Court reviewed the case and focused on the issue of standing. The court concluded that LULAC lacked standing to challenge the King injunction and the Secretary of State’s interpretation of the law. The court reasoned that LULAC’s general interest in the proper interpretation and enforcement of the law, as well as its resource diversion in response to the injunction, did not constitute a legally cognizable injury. The court emphasized that standing requires a specific personal or legal injury, which LULAC failed to demonstrate. Consequently, the Iowa Supreme Court reversed the district court’s decision and remanded the case for dismissal. View "League of United Latin American Citizens of Iowa v. Iowa Secretary of State" on Justia Law

In February 2014, Clint Shalla entered into a debt settlement agreement with Greg and Heather Koch to prevent a foreclosure on his farm. The Kochs agreed to purchase the farm and give Clint an exclusive option to repurchase it by August 15, 2015, with written notice and financing commitment. Clint's wife, Michelle, was not a party to the agreement but conveyed her marital interest in the property. Clint sought financing from Christopher Goerdt, then president of Peoples Trust and Savings Bank, who allegedly agreed to secure financing. Clint missed the option deadline, and the Kochs later agreed to sell the farm for a higher price. Goerdt, who had moved to County Bank, secured financing for the Shallas, but was later found to be involved in fraudulent activities.The Iowa District Court for Washington County granted partial summary judgment in favor of Peoples Bank, dismissing Michelle's fraudulent misrepresentation claim. The court later reconsidered and dismissed the Shallas' negligence and fraudulent misrepresentation claims, citing Iowa Code section 535.17. The court ruled in favor of County Bank in the foreclosure action and found Goerdt liable for conversion. The Shallas appealed, and the Iowa Court of Appeals affirmed the district court's judgment, with a dissent on the application of the statute of frauds.The Iowa Supreme Court reviewed the case and affirmed the lower courts' decisions. The court held that Iowa Code section 535.17, the credit agreement statute of frauds, barred the Shallas' claims for negligence and fraudulent misrepresentation. The court concluded that the statute applies to all actions related to unwritten credit agreements, regardless of whether the claims are framed in contract or tort. The case was remanded to the district court for a determination of County Bank's attorney fees, including appellate attorney fees. View "County Bank v. Shalla" on Justia Law

The case involves the defendant, Amadeus Demetrius McClain, who was stopped by Iowa State Patrol troopers for speeding. During the stop, the trooper smelled marijuana and conducted a warrantless search of the vehicle, finding marijuana in a backpack in the trunk. McClain was charged with possession of marijuana with intent to deliver and failure to affix a drug tax stamp. He filed a motion to suppress the evidence, arguing the search was unconstitutional.The Iowa District Court for Buchanan County denied McClain's motion to suppress, finding that the trooper had probable cause to search the vehicle based on the smell of marijuana and that the automobile exception to the warrant requirement applied. McClain entered a conditional guilty plea, reserving the right to appeal the suppression ruling.The Iowa Supreme Court reviewed the case. The court first determined that it had jurisdiction to hear McClain's appeal in the interest of justice, despite the State's argument that McClain was raising new, unpreserved arguments on appeal. The court then addressed McClain's argument that the State failed to show the trooper's training to identify the odor of marijuana, concluding that McClain had not preserved this issue for appeal.Finally, the court considered McClain's argument to abandon the automobile exception to the warrant requirement. The court reaffirmed its previous decision in State v. Storm, which upheld the automobile exception, noting that the justifications for the exception, including the inherent mobility of vehicles and the lower expectation of privacy in vehicles, remain valid. The court concluded that the availability of electronic search warrants does not undermine the rationale for the automobile exception.The Iowa Supreme Court affirmed the district court's ruling denying McClain's motion to suppress and upheld his conviction. View "State of Iowa v. Mcclain" on Justia Law

Barry and Jacklynn Graham hired Bradshaw Renovations, LLC to renovate their home. They agreed on a contract with an initial estimate of $136,168.16, which was later revised to $139,168.16. The contract included provisions for revising estimates and required written approval for changes. Throughout the project, Bradshaw sent invoices that varied from the initial estimate, leading to the Grahams' concerns about billing practices. After paying $140,098.79, the Grahams disputed a final invoice of $18,779.15, leading to a legal dispute.The Iowa District Court for Polk County held a jury trial, which found in favor of the Grahams on their breach of contract and consumer fraud claims, awarding them $16,000 and $40,000 respectively. The court denied Bradshaw's claims for unjust enrichment and quantum meruit. Bradshaw's motions for directed verdict and judgment notwithstanding the verdict were also denied. The court awarded attorney fees to the Grahams for their consumer fraud claim.The Iowa Court of Appeals affirmed the jury verdict, the district court's denial of Bradshaw's posttrial motions, and the dismissal of Bradshaw's equitable claims. It also affirmed the attorney fee award but remanded for determination of appellate attorney fees.The Iowa Supreme Court reviewed the case and found that the Grahams did not present substantial evidence of consumer fraud as defined by Iowa Code section 714H.3(1). The court reversed the district court's ruling on the consumer fraud claim and remanded for entry of judgment consistent with this opinion. The court affirmed the district court's dismissal of Bradshaw's unjust enrichment and quantum meruit claims, as these were covered by the written contract. The court also upheld the $16,000 jury award for the breach of contract claim. View "Bradshaw Renovations, LLC v. Graham" on Justia Law

A railroad worker, Phillip Morgan, committed suicide after experiencing months of alleged harassment by his supervisor at Union Pacific Railroad Company. His wife, Kera Morgan, acting as the administrator of his estate, filed a lawsuit under the Federal Employers’ Liability Act (FELA), seeking wrongful death damages. She claimed that the harassment and stress from his job led to Phillip's emotional distress and eventual suicide.The Iowa District Court for Polk County granted summary judgment in favor of Union Pacific, concluding that Phillip's injuries were emotional and not tied to a physical impact or near physical harm, thus falling outside the scope of FELA. The court held that FELA did not cover emotional injuries unless there was a physical impact or the worker was in imminent danger of physical harm.The Iowa Supreme Court reviewed the case and affirmed the district court's decision. The court held that under the precedent set by the United States Supreme Court in Consolidated Rail v. Gottshall, FELA incorporates common law limits on compensable injuries. The court concluded that Phillip's emotional injuries, which led to his suicide, did not meet the "zone of danger" test established in Gottshall. This test requires that the worker must have been in immediate risk of physical impact or harm to recover for emotional injuries under FELA. Since Phillip's injuries were purely emotional and not tied to any physical impact or imminent threat of physical harm, the court ruled that FELA did not provide coverage for his case. View "Estate of Morgan v. Union Pacific Railroad Company" on Justia Law