Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction but vacated that part of the sentencing order regarding restitution and remanded the case to the district court to impose restitution consistent with State v. Albright, __ N.W.2d __(Iowa 2019), holding that remand was necessary because the district court did not have the benefit of the procedures outlined in Albright when it entered its order regarding restitution.Defendant was convicted of second-degree sexual abuse of a child under the age of twelve. On appeal, Defendant argued, among other things, that the district court erred in imposing the jail fee without first determining the amount of the fee. The court of appeals affirmed Defendant's conviction but vacated that portion of the sentence dealing with restitution. The Supreme Court let the court of appeals' decision stand as the Court's final decision, thus affirming Defendant's conviction. As to Defendant's sentence, the Court held that the restitution part of Defendant's sentence should be vacated because Albright, which clarified restitution requirements, was filed after the court of appeals decision in this case. View "State v. Tournier" 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 the district court order requiring Defendant to pay restitution for court costs and attorney fees, holding that the part of the sentencing order regarding restitution must be vacated and remanded for resentencing consistent with this Court's decision in State v. Albright, __ N.W.2d __ (Iowa 2019).The court of appeals affirmed Defendant's conviction for first-degree burglary and assault causing bodily injury but remanded the case for resentencing because it found the assault causing bodily injury conviction merged with the first-degree burglary conviction. The court of appeals also affirmed the part of the sentencing order requiring Defendant to pay restitution for court costs and attorney fees. The Supreme Court let the court of appeals' decision stand as the Court's final decision regarding all of Defendant's claims except Defendant's claim that the district court erred in ordering him to pay restitution without first determining his reasonable ability to pay these items of restitution. The Supreme Court vacated the restitution portion of Defendant's sentence, holding that because the district court did not have the benefit of the procedures outlined in Albright when it entered its restitution order, remand was required. View "State v. Mosley" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment for a judgment creditor and dismissed the petition filed by the judgment debtor and his wife to vacate a charging order to execute foreign judgments in Iowa district court against the judgment debtor's membership interests in an Iowa limited liability company (LLC), holding that there was no reason to reverse the judgment of the district court.The judgment debtor and his wife sought to vacate the charging order on the grounds that the creditor could not attach the debtor's interests in the Iowa LLC since the debtor and his wife owned them as a tenancy by the entireties in their domicile of Florida. The Supreme Court affirmed the district court's judgment in favor of the creditor, holding (1) the district court properly applied Iowa law because membership interests in an LLC are located in the state where the LLC is formed; (2) the district court correctly dismissed the petition to vacate the charging order since Iowa law does not recognize the ownership of property by a married couple as tenants in the entireties; and (3) the foreign judgments were properly registered, and the charging order was properly issued. View "Wells Fargo Equipment Finance Inc. v. Retterath" on Justia Law

The Supreme Court affirmed the ruling of the district court holding that mechanic's liens arising from the provision of materials and labor to a lessee did not attach to the property of the lessor under the circumstances of this case and that a construction mortgage lien ultimately obtained by the owner of the land on the leasehold and property of the lessee had prior over the later-filed mechanic's liens, holding that the district court's judgment was without error.Specifically, the Court held (1) the legislature has reworked Iowa Code 572.2 to limit mechanic's liens to property belonging to a narrowly defined owner, and therefore, Denniston & Patridge Co. v. Romp, 56 N.W.2d 601 (Iowa 1953), and Stroh Corp. v. K&S Development Corp., 247 N.W.2d 750 (Iowa 1976), are no longer good law; (2) the priority of the after-acquired construction mortgage lien was not defeated by the doctrine of merger; and (3) there was no fraud under the circumstances presented. View "Winger Contracting Co. v. Cargill, Inc." on Justia Law

The Supreme Court vacated the restitution portion of Defendant's sentence and affirmed the remainder of the sentence, holding that the district court erred in ordering restitution without first conducting the applicable reasonable-ability-to-pay analysis but otherwise did not err.Defendant was convicted and sentenced for domestic abuse assault and second-degree burglary. The Supreme Court remanded the case for resentencing in light of this opinion and the Court's opinion in State v. Albright, __ N.W.2d __ (Iowa 2019), holding (1) the district court did not abuse its discretion by considering the risk assessment tools on their face as contained within the presentence investigation report (PSI); (2) Defendant failed to preserve error on his due process and abuse of discretion claims regarding the court's consideration of the risk assessment tools contained in the PSI; (3) the district court did not abuse its discretion in considering the department of correctional services' sentencing recommendation; (4) the district court did not err in requiring Defendant to pay the court costs associated with dismissed charges; but (5) the district court improperly ordered restitution without first determining Defendant's reasonable ability to pay. View "State v. Headley" on Justia Law

The Supreme Court sustained Defendant's petition for writ of certiorari filed after the district court summarily dismissed Defendant's motion to correct an illegal sentence and denied appointment of counsel, holding that Iowa R. Crim. P. 2.28(1) requires the court to appoint counsel when an indigent defendant files a motion to correct illegal sentence under Iowa R. Crim. P. 2.24(1).Defendant pleaded guilty to third-degree sexual assault. The district court sentenced Defendant to an indefinite term of imprisonment, ordered his placement on the sex offender registry, and imposed a special lifetime sentence pursuant to Iowa Code section 903B.1. After Defendant was discharged from prison, a parole judge revoked Defendant's parole and found him in violation of four parole conditions. The judge ordered Defendant to serve up to five years in prison. Defendant later filed a second motion for correction of an illegal sentence claiming that his lifetime special sentence was unconstitutional. Defendant also filed an application for appointment of counsel. The district court denied Defendant's motions. The Supreme Court sustained Defendant's petition for writ of certiorari, holding (1) Rule 2.28(1) affords a right to counsel on a motion to correct an illegal sentence; and (2) Defendant was entitled to the appointment of counsel. View "Jefferson v. Iowa District Court for Scott County" on Justia Law

In this tort action, the Supreme Court affirmed the judgment of the district court compelling Defendants to produce police investigative reports without a protective order preventing disclosure to the public, holding that the district court properly balanced the competing interests in confidentiality and transparency through its time limit, a carve-out for police internal review records, and directives to handle remaining confidentiality issues by redaction or further proceedings.An African-American motorist was rendered a quadriplegic from being shot at by a Caucasian police officer who had stopped the motorist. The police department released the dash cam video of the incident to the public, and the video went viral on social media. Plaintiffs, the injured motorist and his wife, filed suit against the police officer and City. When Plaintiffs sought discovery of the police investigative reports Defendants refused to produce the documents without a protective order prohibiting disclosure to the media or other nonparties. The district court denied the motion for protective order but limited the order compelling production to reports prepared within ninety-six hours of the incident. The Supreme Court affirmed, holding that the police investigative reports were not exempt from public disclosure under Hawk Eye v. Jackson, 521 N.W.2d 750 (Iowa 1994). View "Mitchell v. City of Cedar Rapids" on Justia Law

The Supreme Court affirmed the judgment of the district court holding that sex offender registration requirements are not punitive and convicting Defendant of failing to report his Internet identifier for a Facebook account he was using under an assumed name, holding that the Internet identifier reporting requirement withstands challenge under the First Amendment and article I, section 7 of the Iowa Constitution.Defendant pleaded guilty to lascivious acts with a child and was placed on the sex offender registry pursuant to Iowa Code chapter 692A. The legislature's 2009 amendment to that statute added the requirement that the offender disclose his Internet identifiers. Defendant was later charged with failing to report his Internet identifier. Defendant argued that the statute, as applied, violated the Free Speech and Ex Post Facto Clauses in the state and federal constitutions. The district court rejected Defendant's constitutional challenges. The Supreme Court affirmed, holding that the Internet identifier reporting requirement of Iowa Code chapter 692A.104(1) is narrowly tailored to serve a significant governmental interest. View "State v. Aschbrenner" on Justia Law

The Supreme Court vacated the decision of the court of appeals affirming the district court's denial of Defendant's motion for summary judgment, reversed the decision of the district court, and remanded to the district court for entry of summary judgment in favor of Defendants, holding that Plaintiffs' action was untimely.Plaintiffs, two beneficiaries of a trust, filed an action asking the district court to resolve a dispute with Defendant concerning the valuation date of the trust. Defendants moved for summary judgment on the grounds that Plaintiffs' action was untimely and the terms of the trust clearly provided the valuation date. The district court denied the motion. The court of appeals affirmed. The Supreme Court reversed the denial of summary judgment, holding that Plaintiffs failed timely to commence their action, and therefore, their claims were barred under Iowa Code 633A.4504. View "Konrardy v. Vincent Angerer Trust" on Justia Law

The Supreme Court affirmed the evidentiary ruling of the district court and grant of summary judgment in favor of Medical School on Student's complaint that Medical School failed to accommodate her mental disability under the Iowa Civil Rights Act, Iowa Code chapter 216, holding that the district court properly declined to impute a staff psychotherapist's knowledge of Student's depression to Medical School's academic decision-makers and that the failure-to-accommodate claim failed as a matter of law.Student was treated for depression by the psychotherapist during the school year but did not consent to allow the psychotherpiast to discuss her depression with the faculty. Medical School eventually expelled Student based on her failing grades and lack of academic promise. In this complaint, Student filed an evidentiary motion to impute her psychotherapist's knowledge of her depression to the school's academic decision-makers. The district court denied the motion after applying statutory confidentiality requirements for mental health information. The court then granted Medical School summary judgment on Student's failure-to-accommodate claim. The Supreme Court affirmed, holding (1) the district court correctly ruled that confidential information the psychotherapist learned while treating Student was not imputed to Medical School; and (2) Medical School adequately engaged in the interactive process. View "Slaughter v. Des Moines University College of Osteopathic Medicine" on Justia Law