Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court ruling in favor of the Iowa Parole Board (Board) as to Petitioner's action challenging the manner in which the Board considers whether persons convicted of offenses while a juvenile should be granted parole, holding that the district court did not err.Petitioner was sixteen years old when he committed the crime of kidnapping. In his petition for judicial review brought pursuant to the Iowa Code 17A.19, Petitioner sought a declaratory judgment that a variety of substantive and procedural rights are required when a juvenile offender is considered for parole. The district court denied the Board's motion to dismiss and then proceeded to rule in favor of the Board on the merits. The Supreme Court affirmed, holding (1) dismissal was not appropriate without analyzing the merits of the underlying constitutional claims; (2) the statute and rules governing the parole process can be applied in a constitutional manner through the required Graham-Miller lens; (3) a juvenile offender has a liberty interest in the proper application of Graham-Miller principles under the Due Process Clause; and (4) Petitioner failed to establish any constitutional violations. View "Bonilla v. Iowa Board of Parole" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence discovered by law enforcement after a stop of Defendant's automobile that resulted in her arrest for driving while barred, holding that the district court did not err in denying Defendant's motion to suppress.Specifically, the Court held (1) Defendant was not subject to an impermissible pretextual seizure because the subjective motivations of an individual officer in making a traffic stop are irrelevant as long as the officer has objectively reasonable cause to believe the motorist violated a traffic law; (2) Defendant's stop was supported by reasonable suspicion; and (3) Defendant's claim that her trial court provided ineffective assistance for declining to challenge whether the vehicle's license plate was malfunctioning failed on the merits. View "State v. Haas" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress all evidence obtained after a stop of his vehicle, holding that the subjective motivations of an individual officer for making a traffic stop are irrelevant as long as the officer has objectively reasonable cause to believe the motorist violated a traffic law.A police officer observed Defendant making an improper turn and, after following Defendant, noticed Defendant's vehicle had an improperly functioning license plate light. The vehicle information for the registered owner - who was not Defendant - revealed the registered owner's affiliation to gang activity. The officer pulled Defendant over and discovered Defendant's open beer container in the center cupholder. Defendant filed a motion to suppress, arguing that the stop was unconstitutional because the officer's reasons for the stop were not the traffic violations themselves. The Supreme Court affirmed, holding that traffic stops for traffic violations are reasonable regardless of the officer's subjective motivation. View "State v. Brown" on Justia Law

In this intrafamily dispute regarding farmland the Supreme Court affirmed the rulings of the district court denying substitute petitioners' petition for relief from elder abuse specifically seeking relief for the loss associated with certain real estate transactions, holding that the substitute petitioners failed to prove that their father was a vulnerable elder at the time of the challenged transactions.The substitute petitioners for their father filed this petition pursuant to Iowa Code 235F alleging that their brother and his son committed elder abuse against their father by unduly influencing the father to enter into below-mark-rate lease agreements to farm the father's land, to gift some of the land to the brother and his son, and to write a new will to reflect the gifted land. The district court concluded that the substitute petitioners failed to establish that their father was a "vulnerable elder" subject to "financial exploitation" within the meaning of chapter 235F. The Supreme Court affirmed, holding that the substitute petitioners filed to prove by a preponderance of the evidence that their father was vulnerable elder at the time of the challenged transactions. View "Struve v. Struve" on Justia Law

The Supreme Court answered questions certified to it by the United States District Court for the Northern District of Iowa, holding, among other things, that a municipality can assert qualified immunity to a claim for damages for violation of the Iowa Constitution based on its officers' exercise of "all due care."Specifically, the Supreme Court held (1) the due care exemption under Iowa Code 670.4(1)(c) could provide the City immunity; (2) section 670.4(1)(e) precludes an award of punitive damages against the municipality that employed the constitutional tortfeasor; (3) in a Godfrey v. State, 898 N.W.2d (Iowa 2017), action a court cannot award attorney fees against the municipal employer of the constitutional tortfeasor unless there is a statute expressly allowing such an award; and (4) it is appropriate to retroactively apply this Court's conclusion that in a Godfrey action, common law attorney fees may be available against the municipal employer of the constitutional tortfeasor. View "Baldwin v. City of Estherville, Iowa" on Justia Law

The Supreme Court affirmed the decision of the district court affirming the Carroll County Board of Adjustment's denial of Appellants' application for a variance from Carroll County Airport Zoning Ordinance height restrictions, holding that this Court's opinion rejecting Appellants' preemption defense in a companion case, was fatal to Appellants' appeal of the zoning variance denial.Appellants built a grain leg on their farmland that violated the zoning ordinance's height restrictions. The Federal Aviation Administration (FAA) made a no-hazard determination. The Carroll Airport Commission disagreed with the FAA's determination and filed an equitable action to have the grain leg declared a nuisance. After Appellants unsuccessfully sought a variance, the district court entered judgment for the Commission on its nuisance claim. In both the nuisance action and the zoning appeal Appellants argued that the FAA's no-hazard determination preempted local regulations as a matter of law. The district court rejected that defense in the nuisance action. The court of appeals and Supreme Court affirmed. The district court then affirmed the Board's denial of the variance, again rejecting the preemption defense. Because the nuisance case adjudicated the same federal preemption issue Appellants raised in this preceding, the Supreme Court's opinion rejecting Appellants' preemption defense in the nuisance action was fatal to Appellants' appeal of the zoning appeal. View "Danner v. Carroll County Board of Adjustment" on Justia Law

The Supreme Court affirmed the district court's judgment upholding the revocation of a Driver's license, holding that this Court declines to overrule precedent and apply the exclusionary rule to driver's license revocation proceedings when an Iowa statute dictates otherwise.Driver in this case was pulled over by an officer with the Iowa Department of Transportation (DOT) after he made an unauthorized use of a median crossover to turn around and head in the other direction. Driver had an open container in his car and smelled of an alcoholic beverage, but Driver was never charged with operating while intoxicated (OWI). Adhering to precedent set in Westendorf v. Iowa Department of Transportation, 400 N.W.2d 553 (Iowa 1987), and Manders v. Iowa Department of Transportation, 454 N.W.2d 364 (Iowa 1990), in which the Court declined to apply the exclusionary rule to driver's license revocation proceedings so long as the enumerated statutory conditions for license revocation were met, the DOT upheld Driver's license suspension. The Supreme Court affirmed, holding that where the only flaw in the stop was the officer's lack of statutory authority, this Court declines to expand the legislature's post-Westendorf statutory exception and apply the exclusionary rule to all driver's license revocation proceedings if there was any problem with the stop. View "Westra v. Iowa Department of Transportation" on Justia Law

In this wrongful death action the Supreme Court affirmed the order of the district court entering judgment for Defendant, holding that Plaintiffs did not preserve any issues for appellate review.A jury determined that Defendant was not liable for wrongful death and awarded no damages. The district court subsequently entered judgment for Defendant. Plaintiff filed a posttrial combined motion for new trial and change of venue, alleging a violation of a granted motion in limine, undue influence of Defendant over the jury, and other trial court errors. The district court denied the post trial motion. Plaintiff appealed. The Supreme Court affirmed, holding that Plaintiff was deemed to have waived and abandoned her posttrial motion, and therefore, Plaintiff did not preserve any issues for appellate review. View "Freer v. DAC, Inc." on Justia Law

The Supreme Court reversed the judgment of the district court summary judgment for the State on Appellant's application for postconviction relief (PCR) after denying Appellant's request to appoint an expert, holding that the district court abused its discretion in denying the expert and that the summary disposition was erroneous.After a jury trial, Appellant was found guilty of first-degree murder. Appellant was sentenced to life imprisonment. In her petition for postconviction relief Appellant asserted, among other claims, that her trial counsel was ineffective for failing to raise battered woman syndrome (BWS) in her trial and for not adducing BWS evidence. To prove her claim, Appellant sought a court-appointed BWS expert. The district court denied Appellant's request to appoint an expert and, simultaneously, cited Appellant's failure to provide an expert in granting summary judgment. The Supreme Court reversed, holding that the summary disposition was erroneous where the court, among other errors, concluded that the record did not show facts to support Appellant's claim that BWS should have been raised at her trial. View "Linn v. State" on Justia Law

In this case brought by a former employee alleging discrimination and retaliation, the Supreme Court reversed the judgment of the district court entering judgment on a jury verdict for Plaintiff, awarding him back pay, emotional distress damages, front pay and attorney fees, holding that the district court erred in admitting hearsay, and the hearsay was not harmless.Plaintiff, a terminated employee, brought this action against his former employer and the employer's agents under the Iowa Civil Rights Ac, alleging that Defendants discriminated against him because of his age and his status as a cancer patient and retaliated against him due to his refusal to retire or quit. The jury entered a verdict for Plaintiff. The Supreme Court reversed and remanded the case for a new trial, holding that the district court erred in admitting hearsay and the record failed to rebut the presumption of prejudice associated with the admitted hearsay evidence. View "Hawkins v. Grinnell Regional Medical Center" on Justia Law