Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed the district court's judgment granting summary judgment and dismissing Plaintiffs' claims challenging the decisions of a county board of supervisors approving a wind energy ordinance and a specific wind energy project, holding that Plaintiffs' claims were matters for the board of supervisors, and not the courts, to resolve.The board unanimously passed and approved a "wind energy conversion systems ordinance" and then granted conditional approval for the wind energy project at issue in this case. Plaintiffs then filed a petition for declaratory and injunctive relief and for a writ of certiorari against the board seeking a declaration that the ordinance was arbitrary, capricious, unreasonable, void and unenforceable and a writ determining that the approval of the project should be set aside as illegal, arbitrary and capricious, unreasonable and void. The district court granted summary judgment for the defendants. The Supreme Court affirmed, holding that the board did not act illegally, arbitrarily, or capriciously. View "Mathis v. Palo Alto County Board of Supervisors" on Justia Law

In this case concerning an Iowa Utilities Board (IUB) legal standard for when a series of wind turbines constitute an "electric power generating plant or combination of plants at a single site" within the meaning of Iowa Code 476A.1(5), the Supreme Court affirmed the district court's judgment upholding the IUB's declaratory order declining to require a certificate of public convenience, use, and necessity for a large 170-turbine wind project, holding that the IUB did not err in interpreting Iowa Code 476A.1(5).Since 1997, the IUB has ruled that for wind energy purposes all turbines connected to a single gathering line shall be considered a "single site" or "facility" within the meaning of section 476A.1(5) and that turbines connected to separate gathering lines shall be treated as different sites or facilities. Landowners in Palo Alto County in this case argued that the IUB should have exercised jurisdiction over the turbine wind project at issue in this case because, under the common gathering line standard, it did not exceed the minimum power output requirements. The district court upheld the IUB's position declining to require a certificate for the facility. The Supreme Court affirmed, holding that the phrase "single site" is ambiguous and that the IUB's interpretation of section 476A.1(5) is not erroneous. View "Mathis v. Iowa Utilities Board" on Justia Law

The Supreme Court affirmed the judgment of the district court granting an employer's workers' compensation insurance carrier's motion to dismiss Plaintiffs' common law tort claim and ruling that Iowa Code 517.5 was constitutional, holding that the statute is not violative of equal protection, inalienable rights, or due process under article I, sections 1, 6, and 9 of the Iowa Constitution.Plaintiffs, employees and former employees of an Iowa manufacturing company, brought this action alleging that the insurance carrier failed to conduct or negligently conducted an insurance inspection at their employer's manufacturing facility, causing serious health problems for Plaintiffs. The insurance carried moved to dismiss the petition under section 517.5, which provides that "no inspection of any place of employment made by insurance company inspectors...shall be the basis for the imposition of civil liability upon the inspector or upon the insurance company..." The district court dismissed the actions after determining that the provision was constitutional. The Supreme Court affirmed, holding that there is no claim for negligent inspection against a workers' compensation carrier. View "Clark v. Insurance Co. State of Pennsylvania" on Justia Law

The Supreme Court vacated in part Defendant's sentence, holding that because the district court did not have the benefit of the procedures outlined in State v. Albright, __ N.W.2d __ (Iowa 2019), when it entered its order regarding restitution, the part of the sentencing order regarding restitution must be vacated and the case remanded to the district court to impose restitution consistent with Albright.Defendant pled guilty to driving while her license was barred. On appeal, Defendant argued that the district court erred in ordering her to pay restitution for attorney fees and correctional costs without determining the amounts of those obligations or her ability to pay court costs. The Supreme Court vacated the part of the sentencing order regarding restitution, holding that remand was necessary for reconsideration in light of Albright. View "State v. Perry" on Justia Law

The Supreme Court affirmed the judgment of the district court dissolving an injunction that had precluded a sale after ruling that the City of Waterloo had complied with Iowa Code 306.23 in transferring land from an unused right-of-way to a developer of a residential subdivision.Plaintiffs, adjacent landowners and taxpayers, alleged that the City violated the requirements set forth in section 306.23 imposing notice and appraisal requirements when transferring land from the unused right-of-way. The district court entered an injunction precluding the sale but later lifted its injunction after finding that the City complied with section 306.23. The district court subsequently refused to hold the City in contempt and dismissed Plaintiffs' mandamus claim and application for sanctions. The Supreme Court affirmed, holding that the City complied with section 306.23. View "Hartog v. City of Waterloo, Iowa" on Justia Law

The Supreme Court affirmed Defendant's conviction, holding that the district court did not err in denying Defendant's motion to suppress the results of a chemical breath test where the officer administering the test allegedly violated Defendant's statutory right to obtain additional chemical testing.On appeal, Defendant argued that the district court erred in denying his motion to suppress evidence allegedly obtained in violation of his statutory right under Iowa Code 321J.11. The statute creates a right for a detainee or arrestee to have an independent chemical test administered at the person's own expense in addition to any test administered at the direction of an officer. A detainee or arrestee invokes the statutory right by making "any statement that can be reasonably construed as a request for an independent chemical test." The Supreme Court affirmed, holding that substantial evidence supported the district court's finding that Defendant did not inquire about his right to take an independent test, and therefore, the district court did not err in denying Defendant's motion to suppress evidence. View "State v. Smith" on Justia Law

The Supreme Court affirmed Defendant's conviction but vacated the portion of Defendant's sentence regarding restitution, holding that remand was required because the district court did not have the benefit of the procedures outlined in State v. Albright, __ N.W.2d __ (Iowa 2019).The court of appeals affirmed Defendant's conviction, holding that Defendant's counsel was not ineffective for failing to challenge the sufficiency of the evidence. The court further found that the district court did not err in assessing restitution for appellate attorney fees. The Supreme Court granted further review and affirmed Defendant's conviction, letting the court of appeals decision stand as this Court's final decision regarding Defendant's ineffective assistance of counsel claims. As to Defendant's argument that the district court erred in ordering him to pay restitution in the form of appellate attorney fees without first determining his reasonable ability to pay those fees, the Court held that the restitution part of Defendant's sentence regarding those fees should be vacated and the case remanded to the district court to impose restitution consistent with this Court's decision in Albright. View "State v. Dieckmann" on Justia Law

The Supreme Court affirmed Defendant's sentencing procedure but vacated the portion of Defendant's sentence regarding restitution, holding that remand was necessary for the district court to impose restitution consistent with this Court's decision in State v. Albright, __ N.W.2d __ (Iowa 2019).Defendant was convicted of domestic abuse assault causing bodily injury. The court of appeals affirmed Defendant's sentence. The Supreme Court granted further review and let the court of appeals decision stand as this Court's final decision regarding the issue of whether the district court gave Defendant his right of allocution. As to Defendant's argument that the district court erred in ordering him to pay restitution without first determining his reasonable ability to pay, the Supreme Court held that Defendant's sentence regarding restitution should be vacated and the case remanded for the district court to impose restitution consistent with Albright. View "State v. Weston" on Justia Law

The Supreme Court affirmed the part of the district court's judgment sentencing Defendant to five years' imprisonment but vacated the restitution part of his sentence, holding that remand was required for the district court to impose restitution consistent with this Court's decision in State v. Albright, __ N.W.2d __ (Iowa 2019).Defendant was sentenced to five years' imprisonment for theft in the second degree. The district court also assessed financial obligations to him. The court of appeals affirmed Defendant's sentence. The Supreme Court granted transfer and let the court of appeals decision stand as this Court's final decision regarding Defendant's term of imprisonment. As to Defendant's argument that the district court erred in ordering him to pay restitution in the form of appellate attorney fees without first determining his reasonable ability to pay those fees, the Court held that the restitution part of Defendant's sentence should be vacated and the case remanded for the district court to impose restitution consistent with Albright. View "State v. Steenhoek" on Justia Law

The Supreme Court affirmed in part and vacated in part the decision of the court of appeals affirming Defendant's conviction and vacating the part of Defendant's sentence dealing with restitution, holding that there was no error in Defendant's conviction but that the case must be remanded to the district court to impose restitution consistent with State v. Albright, __ N.W.2d __ (Iowa 2019).Defendant was convicted of second-degree murder. On appeal, Defendant argued (1) the district court erred in denying his motion to continue the trial and admitting a video recording of his police interview into evidence, and (2) the court erred in requiring him to make restitution of appellate attorney fees without first determining his reasonable ability to pay those fees. The court of appeals vacated the portion of the sentence dealing with restitution and remanded the case for entry of a corrected sentencing order. The Supreme Court affirmed Defendant's conviction but found that the restitution part of his sentence should be vacated. The Court held that because the district court did not have the benefit of the procedures outlined in Albright when it entered its order regarding restitution, the portion of the sentencing order regarding restitution must be vacated and remanded. View "State v. Crawford" on Justia Law