Justia Iowa Supreme Court Opinion Summaries

A vacancy on the Scott County Board of Supervisors occurred when Tony Knobbe resigned to become the Scott County Treasurer. A committee of county officials decided to fill the vacancy by appointment and kept certain applications confidential during the process. The committee referred to applicants by numbers and only revealed the name of the appointed individual. After the appointment, two individuals submitted open records requests for the confidential names and applications, which Scott County denied, citing Iowa Code section 22.7(18).The individuals filed a petition in the Iowa District Court for Scott County, which granted summary judgment in favor of Scott County, determining that the applications were exempt from disclosure under Iowa Code section 22.7(18). The district court relied on the precedent set in City of Sioux City v. Greater Sioux City Press Club, which held that employment applications could be kept confidential.The Iowa Supreme Court reviewed the case and reversed the district court's decision. The court held that the applications for the vacant county board of supervisors position were not confidential under section 22.7(18). The court reasoned that the applicants were not promised confidentiality beforehand, and the public nature of the appointment process meant it was not reasonable to believe that people would be deterred from applying if their applications were disclosed. The court ordered that the names and applications be disclosed and awarded costs and reasonable attorney fees to the plaintiffs. The case was remanded for further proceedings. View "Diercks v. Scott County, Iowa" on Justia Law

Gerry Greenland was convicted of attempted murder, assault on a peace officer with intent to cause serious injury while using a dangerous weapon, and simple assault. The incident occurred on May 23, 2019, when Greenland, after a series of confrontations with family members on a farm, used a tractor equipped with bale spears to attack Sheriff Ben Boswell's vehicle. Greenland's actions included ramming the sheriff's car, causing significant damage and endangering the sheriff's life.The Iowa District Court for Decatur County found Greenland guilty of all charges and sentenced him to concurrent terms of incarceration, totaling a maximum of twenty-five years. Greenland appealed, arguing insufficient evidence for his convictions and that the assault conviction should merge with the attempted murder conviction. The Iowa Court of Appeals affirmed the convictions, holding that there was sufficient evidence to support the convictions and that the convictions did not merge because they were based on separate and distinct actions.The Iowa Supreme Court reviewed the case, focusing on whether the convictions for assault on a peace officer and attempted murder should merge under Iowa Code section 701.9. The court held that the convictions did not merge because the assault involved alternative theories, including the use or display of a dangerous weapon, which was not an element of attempted murder. The court disavowed a previous statement in State v. Braggs that suggested it is impossible to commit attempted murder without also committing an assault, clarifying that assault is not always a lesser included offense of attempted murder. The court affirmed the decisions of the Court of Appeals and the District Court. View "State of Iowa v. Greenland" on Justia Law

Benjamin Trane established a private therapeutic boarding school for troubled youth, which was shut down after a police raid. Trane was charged with sexual abuse of a minor, sexual exploitation by a counselor or therapist, and child endangerment. The first two charges involved an underage female victim, while the third charge involved two boys placed in isolation rooms. A jury found Trane guilty on all counts. On direct appeal, the Iowa Supreme Court conditionally affirmed his convictions but remanded for a hearing on a rape shield issue, preserving his ineffective-assistance-of-counsel claims for postconviction relief (PCR) proceedings.In the Iowa District Court for Lee (South) County, Trane alleged ineffective assistance of trial counsel for failing to move to sever the child endangerment count and for not objecting to the marshaling instruction on that count. The district court rejected the severance claim, finding Trane made an informed decision to forego a motion for severance to avoid delay. However, the court ordered a new trial on the child endangerment charge, finding that the marshaling instruction allowed a nonunanimous verdict, thereby prejudicing Trane.The Iowa Supreme Court reviewed the case de novo. The court affirmed the district court's finding that Trane chose to forego a motion to sever the child endangerment count. However, the court reversed the district court's order for a new trial on the child endangerment charge. The court agreed that the marshaling instruction was erroneous but found no prejudice because both child victims were similarly situated, and there was no reasonable probability that jurors did not find Trane guilty of endangering both children. Thus, the court affirmed the denial of relief on the severance claim and reversed the order for a new trial on the child endangerment charge. View "Trane v. State of Iowa" on Justia Law

A financial advisor, employed by Principal Securities, Inc., was terminated for failing to obtain a second client consent when rebalancing accounts using a new trading system. The advisor argued that the termination report filed by Principal with the Financial Industry Regulatory Authority (FINRA) was misleading and initiated arbitration to seek changes to the report. The arbitrator ruled in favor of the advisor, recommending changes to the termination report to reflect that the advisor's failure was due to a lack of training and that the advisor was encouraged not to resign during the investigation.The Iowa District Court for Polk County vacated the arbitration award, finding it unsupported by substantial evidence. The advisor appealed, and the case was transferred to the Iowa Court of Appeals. A divided panel of the Court of Appeals affirmed the district court's decision, with the majority agreeing that the information provided by Principal was not defamatory or misleading. The dissenting judge believed that substantial evidence supported the arbitration award.The Iowa Supreme Court reviewed the case and applied a highly deferential standard of review. The court concluded that substantial evidence supported the arbitrator's determination that the termination report was misleading and that the recommended changes were justified. The court vacated the decision of the Court of Appeals, reversed the district court's judgment, and remanded the case with instructions to confirm the arbitration award. View "Principal Securities, Inc. v. Gelbman" on Justia Law

A man passed away, and his wife made a claim on his estate for half of the money he had removed from their joint bank account before his death. The wife argued that the couple owned the account as joint tenants, and her husband had withdrawn funds exceeding his interest. The district court dismissed her claim, concluding that she was making a claim for conversion sounding in tort and had not met the legal standard.The wife appealed, arguing that the district court applied the wrong legal standard and that a standard from caselaw on joint tenancies should apply. The Iowa Court of Appeals agreed with her, reversed the district court's decision, and remanded the case. The estate sought further review from the Iowa Supreme Court.The Iowa Supreme Court affirmed the decision of the Court of Appeals, holding that the district court applied an incorrect legal standard. The correct standard, as established in Anderson v. Iowa Department of Human Services, involves determining the respective rights of joint tenants based on their agreement and the presumption that each joint tenant is entitled to half of the joint account, which can be rebutted. The court remanded the case for a new trial to allow for proper fact-finding regarding whether the husband removed funds in excess of his interest in the joint account. View "In re Estate of Johnston" on Justia Law

Lance and Tracy Degeneffe entered into a roofing contract with Home Pride Contractors, Inc. to repair their roof, gutters, and siding after wind and hail damage. Home Pride completed the repairs and billed the Degeneffes, who refused to pay, leading Home Pride to hire an attorney to collect the debt. The Degeneffes sued Home Pride, alleging that its prior counsel engaged in harassing and abusive collection efforts in violation of the Iowa Consumer Credit Code (ICCC).The Iowa District Court for Boone County reviewed cross motions for summary judgment. Home Pride argued it was not subject to the ICCC as it did not extend credit or lend money to its customers. The Degeneffes argued that the roofing contract was a consumer credit sale subject to the ICCC and that Home Pride’s conduct was harassing and abusive under the ICCC. The district court denied Home Pride’s motion and granted the Degeneffes’ motion in part, establishing that the roofing contract constituted a consumer credit sale subject to the ICCC, but left the question of whether Home Pride’s conduct was harassing and abusive for trial.The Iowa Supreme Court reviewed the case to determine whether the roofing contract was a consumer credit sale subject to the ICCC. The court concluded that Home Pride did not grant credit to the Degeneffes, as the contract required full payment upon completion of the work, and the 1.5% monthly interest charge for late payment did not constitute an extension of credit. The court reversed the district court’s entry of partial summary judgment in favor of the Degeneffes and remanded the case for entry of summary judgment in favor of Home Pride. View "Degeneffe, v. Home Pride Contractors, Inc." on Justia Law

A landlord, MIMG CLXXII Retreat on 6th, LLC, owns an apartment building in Cedar Rapids, Iowa. Mackenzie Miller, a tenant, entered a one-year lease in June 2022. The lease required rent to be paid by the first of each month, with a three-day notice period for nonpayment before the landlord could terminate the tenancy and pursue eviction. In December 2022, Miller failed to pay rent, and the landlord served a three-day notice. When the rent remained unpaid, the landlord filed a forcible entry and detainer (FED) action in the small claims division of the Linn County District Court.The small claims court dismissed the FED action, ruling that the Federal CARES Act required a thirty-day notice before eviction, which preempted Iowa's three-day notice law. The landlord appealed to the Iowa District Court for Linn County, arguing that the thirty-day notice requirement was time-limited to the 120-day moratorium period specified in the CARES Act. The district court upheld the small claims court's decision, stating that the plain language of the CARES Act did not include an expiration date for the thirty-day notice requirement.The Iowa Supreme Court reviewed the case and concluded that the thirty-day notice requirement in the CARES Act applies only to rent defaults that occurred during the 120-day moratorium period. The court reasoned that the statute must be read in context with the surrounding provisions, which were temporary measures related to the COVID-19 pandemic. The court also noted the presumption against preemption of state law, particularly in areas traditionally governed by state law, such as landlord-tenant relationships. The Iowa Supreme Court reversed the district court's decision and remanded the case for further proceedings consistent with its opinion. View "MIMG CLXXII Retreat on 6th, LLC v. Miller" on Justia Law

An officer on patrol stopped a vehicle for a traffic infraction after receiving information that the vehicle’s occupants might have been involved in a drug sale. After initially interacting with the driver, the officer waited for backup before removing the occupants and conducting a search with a drug-sniffing dog, which led to the discovery of a gun. The passenger, Tyre Brown, admitted ownership of the gun and was charged with unlawful possession of a firearm. Brown argued that the officer unlawfully prolonged the stop beyond the time necessary to address the traffic infraction, violating his constitutional rights.The Iowa District Court for Polk County denied Brown’s motion to suppress the evidence obtained from the search. Brown was found guilty after stipulating to a trial on the minutes of testimony. Brown appealed the denial of his motion to suppress, and the Iowa Court of Appeals affirmed the district court’s ruling. The court of appeals concluded that the extension of the stop was permissible under the shared-knowledge doctrine and that the officer had smelled marijuana, justifying further investigation.The Iowa Supreme Court reviewed the case and affirmed the lower courts' decisions. The court held that the shared-knowledge doctrine allowed the officer to act on information provided by another officer who had observed a potential drug transaction, thus justifying the extension of the stop. The court found that the extension of the stop to investigate for drugs did not violate Brown’s constitutional rights. Consequently, the district court’s ruling denying Brown’s motion to suppress was affirmed. View "State of Iowa v. Brown" on Justia Law

In 2017, the Franklin County Board of Supervisors undertook a project to deepen and widen the drainage ditch known as Drainage District No. 48 (DD48). The project affected several landowners, who sought damages for the reconstruction. The district court ruled that the Board had not abandoned the original right-of-way easement from 1906, limiting right-of-way damages to the expanded areas beyond the original boundaries. The court also awarded severance damages for the diminution in value of the remaining property due to the inability to traverse the ditch with farming equipment. Additionally, the court ordered the conveyance of a 4.01-acre landlocked parcel to the Board, with compensation for its full value.The Iowa District Court for Franklin County ruled in favor of the landowners, awarding both right-of-way and severance damages. The court of appeals affirmed the damages awards but reversed the order to convey the 4.01-acre parcel, remanding for further proceedings. The Board sought further review to determine the entitlement to severance damages.The Iowa Supreme Court reviewed the case and concluded that the Board held a permanent right-of-way easement for the drainage ditch, which had not been abandoned. Therefore, the landowners were only entitled to right-of-way damages for the expanded areas beyond the original boundaries. The court held that the plaintiffs were not entitled to severance damages for the diminution in value of their remaining property, except for the 4.01-acre parcel that became landlocked in 2017. The court affirmed the district court’s award for the landlocked parcel but reversed the severance damages for the other properties. The case was remanded for entry of a damages award consistent with the appraisal committee’s initial calculation. The Board was not entitled to a deed for the 4.01-acre parcel. View "Abbas v. Franklin County Board of Supervisors" on Justia Law

Isaiah Duffield was required to register as a sex offender due to a juvenile adjudication for sexual abuse. In April 2022, he was charged with sexual abuse in the third degree, second or subsequent offense, and failure to comply with the sex offender registry. After the charges were severed and amended, Duffield entered a guilty plea to the lesser offense of failure to register, an aggravated misdemeanor. The district court sentenced him to a term of incarceration not to exceed two years and a fine of $1,025, which was suspended. The court ordered the sentence to be served consecutively to a sentence in a separate sexual abuse case.Duffield appealed to the Iowa Court of Appeals, arguing that the district court abused its discretion in imposing the $1,025 fine and failed to state its reasons for imposing consecutive sentences. The court of appeals upheld the fine, reasoning it was within the statutory range and Duffield did not establish any irregularity. However, the court agreed that the district court erred in failing to state reasons for consecutive sentences and remanded the case to a different judge to decide whether the sentences should be served concurrently or consecutively.The Iowa Supreme Court reviewed the case and focused on the consecutive sentencing issue. The court held that the district court erred in failing to state its reasons for imposing consecutive sentences. The court vacated Duffield’s sentence and remanded the case for a plenary resentencing hearing, emphasizing that the resentencing should not be limited to the consecutive sentencing issue alone. The court also concluded that resentencing before a different judge was not required, as there was no taint in the sentencing process. The decision of the court of appeals was vacated, the conviction was affirmed, the sentence was vacated, and the case was remanded for resentencing. View "State of Iowa v. Duffield" on Justia Law