Justia Iowa Supreme Court Opinion Summaries

The Supreme Court conditionally affirmed Defendant's conviction of two counts of first-degree murder while remanding the case for further proceedings consistent with State v. Lilly, __ N.W.2d __ (Iowa 2019), also decided today, holding that further consideration of Defendant's claim of violation of his right to an impartial jury drawn from a fair cross section of the community was warranted.Defendant was an African-American. Although the jury venire contained five African-Americans, no African-American was seated on the jury that heard Defendant's case. On appeal, Defendant asserted a number of trial-related issues, including the claim that his jury was not drawn from a fair cross section of the community in violation of the Sixth Amendment. The Supreme Court held (1) as in Lilly, the appropriate course of action is to remand the case to offer Defendant a further opportunity to develop his arguments that his Sixth Amendment right to an impartial jury was violated; and (2) Defendant's remaining claims did not warrant reversal. View "State v. Veal" on Justia Law

The Supreme Court conditionally affirmed Defendant's conviction for aiding and abetting a bank robbery and remanded for further consideration of Defendant's claim that his jury was not drawn from a fair cross section of the community, in violation of the Sixth Amendment to the United States Constitution and article I, section 10 of the Iowa Constitution, holding that further consideration of this claim was warranted.Defendant, an African-American, was convicted following a trial by a jury that contained no African-Americans. Further, there were no African-Americans in the jury venire that reported that day. On appeal, Defendant argued that the racial composition of the jury pool violated his rights to an impartial jury under both the federal and the state constitution. The Supreme Court held that the typical jury management practices can support a systematic exclusion claim under the framework established in State v. Plain, 898 N.W.2d 801 (Iowa 2017), and Duren v. Missouri, 439 U.S. 357 (1979), where the evidence shows one or more of those practices have produced underrepresentation of a minority group, and this case will be remanded to give Defendant a further opportunity to develop his fair-cross-section claim. View "State v. Lilly" on Justia Law

The Supreme Court affirmed the district court's grant of summary judgment dismissing this action filed by a public employee union seeking to enforce a collective bargaining agreement entered into with the Iowa Board of Regents, holding that the Public Employment Relations Board (PERB) acted within its statutory authority in promulgating Iowa Admin. Code R. 621-6.5(3), which has the force of law, and that the district court correctly applied rule 621-6.5(3) to hold the parties had no enforceable collective bargaining agreement (CBA) without the Board's vote to ratify it.The Board moved for summary judgment on the union's action to enforce the CBA, relying on rule 621-6.5, which requires the Board to meet to vote to accept a tentative voluntary agreement ratified by the union before the contract becomes effective. The union argued that the agency rule was invalid because it imposed a ratification requirement not included in Iowa Code 20.17(4). The district court upheld the validity of the agency rule and dismissed the union's enforcement action. The Supreme Court affirmed, holding (1) rule 621-6.5(3) is valid; and (2) therefore, no enforceable agreement was reached without the requisite vote by the Board to approve the CBA. View "Service Employees International Union, Local 199 v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court interpreting the 2017 amendments to Iowa Code chapter 20, the Public Employment Relations Act, limiting the mandatory subjects of collective bargaining and the matters an arbitrator may consider if the dispute enters binding arbitration, holding that the Iowa Public Employment Relations Board (PERB) and the district court correctly interpreted the amendments.A union sought a declaratory order from PERB and then judicial review of the declaratory order seeking to clarify certain provisions in the amendments. The Supreme Court affirmed the judgment of the district court affirming PERB's decision, holding (1) "base wages" under Iowa Code 20.9(1) means the floor level of pay for each job before upward adjustments such as for job shift or longevity; and (2) the term "past collective bargaining agreement" in the context of Iowa Code 20.22(10)(b)(1) allows an arbitrator to consider the existing collective bargaining agreement but not ones that came before. View "United Electrical, Radio & Machine Workers of America v. Iowa Public Employment Relations Board" on Justia Law

The Supreme Court affirmed the district court's judgment against the State enforcing a collective bargaining agreement (CBA) between the State and a public employee union, holding that the district court had subject matter jurisdiction and correctly ruled that the State had not withdrawn its offer before the union's acceptance and ratification resulted in an enforceable CBA.The State moved to dismiss or stay the action in favor of administrative proceedings pending at the Public Employment Relations Board arguing no contract was formed after the union accepted the State's pending offer and the union membership voted to ratify the terms . The district court denied the State's motion and then granted the union's motion for summary judgment. The Supreme Court affirmed, holding (1) the State failed to preserve its argument that Iowa Admin. Code R. 621-6.5(3) requires the State to vote to ratify after the union vote; (2) the union's ratification resulted in an enforceable CBA; and (3) the district court's rulings rejecting the primary-jurisdiction and exhaustion doctrines were correct. View "UE Local 893/IUP v. State" on Justia Law

The Supreme Court affirmed the district court's grant of summary judgment in favor of Defendants on Plaintiffs' claim that the 2017 amendments to Iowa Code chapter 20, the Public Employment Relations Act (PERA), violate the equal protection clause of the Iowa Constitution, holding that the 2017 amendments withstood the constitutional challenges.The 2017 amendments resulted in new classifications that made many public employees lose significant statutory bargaining rights compared to other public employees with ostensibly similar jobs. A public employee union and some of its members filed this action against the State and the Public Employment Relations Board (PERB) seeking injunctive and declaratory relief alleging that the amendments violated the equal protection clause of the Iowa Constitution and their right to freedom of association. The district court dismissed the action on summary judgment. The Supreme Court affirmed, holding that the legislative classifications are not so overinclusive or underinclusive as to be unconstitutional and that the amendments do not violate constitutional rights of freedom of association. View "AFSCME Iowa Council 61 v. State" on Justia Law

The Supreme Court affirmed the district court's summary judgment in favor of Defendants on Plaintiffs' claim that the 2017 amendments to Iowa Code chapter 20, the Public Employment Relations Act (PERA), violate the equal protection clause of the Iowa Constitution, holding that the 2017 amendments withstood the constitutional challenges.The 2017 amendments resulted in new classifications that made many public employees lose significant statutory bargaining rights compared to other public employees with ostensibly similar jobs. Two unions representing public school employees filed this action seeking injunctive and declaratory relief against the State, the Iowa Public Employment Relations Board (PERB), and three PERB board members, alleging that the amendments violated the equal protection clause of the Iowa Constitution. The district court dismissed the action on summary judgment. The Supreme Court affirmed, holding that the legislative classifications are not so overinclusive or underinclusive as to be unconstitutional under this Court's rational basis test. View "Iowa State Education Ass'n v. State, Iowa Public Employment Relations Board" on Justia Law

The Supreme Court affirmed the ruling of the district court denying Jane Doe's motion to expunge her record, holding that the condition in Iowa Code 901C.2, the expungement statute, that an individual pay all court-imposed costs and fees does not violate the Equal Protection Clauses of the United States or Iowa Constitutions.Section 901C.2 creates a statutory right to expungement subject to several conditions. Doe was an indigent defendant who was denied expungement for failure to pay off her court-appointed attorney fees. On appeal, Defendant argued that the condition that she pay her court-appointed attorney fees violated her equal protection rights. The district court denied Doe's constitutional challenge and denied her motion to expunge her record. The Supreme Court affirmed, holding that the requirement to pay court costs, including court-appointed attorney fees, is rationally related to the government interest in collecting court debt. View "State v. Doe" on Justia Law

The Supreme Court answered a certified question of Iowa law by holding that, under Iowa law, a common law cause of action for bad faith failure to pay workers' compensation benefits is not available against a third-party claims administrator of a worker's compensation insurance carrier.Plaintiff, who suffered a work-related injury, filed a claim for benefits with the workers compensation commissioner. Plaintiff was denied benefits. Plaintiff later filed a bad faith action against his employer's workers' compensation carrier and its third-party administrator. The action was removed to the federal district court, and the court certified the following question to the Supreme Court: “In what circumstances, if any, can an injured employee hold a third-party claims administrator liable for the tort of bad faith for failure to pay workers’ compensation benefits?” The Supreme Court held that a third-party administrator cannot be sued for bad faith as if it were an insurer. View "De Dios v. Indemnity Insurance Co. of North America" on Justia Law

The Supreme Court vacated the decision of the court of appeals declining to give preemptive effect to a no-hazard determination by the Federal Aviation Administration (FAA) and affirmed as modified the judgment of the district court, holding that the Federal Aviation Act allows for local zoning regulation, and the FAA's no-hazard letter did not preempt the local airport zoning regulations as a matter of law.A farmer built a twelve-story grain leg near an airport. The airport commission informed the farmer he needed a variance and refused to grant one. Thereafter, the FAA approved the structure. The local commissioners later brought this action in equity to force the farmer to modify or remove the structure. The district court issued an injunction. The court of appeals affirmed. The Supreme Court granted further review and held (1) state and local regulators can impose stricter height restrictions on structures in flight paths notwithstanding an FAA no-hazard determination, and therefore, the no-hazard letter did not preempt the local airport zoning regulations; and (2) the district court properly found that the structure constituted a threat to aviation requiring abatement, but the $200 daily penalty is vacated and the judgment is modified to require the farmer to abate the nuisance within nine months of this opinion. View "Carroll Airport Commission v. Danner" on Justia Law