Justia Iowa Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the district court finding Defendant guilty beyond a reasonable doubt of operating while intoxicated (OWI) in violation of Iowa Code 321J.2, holding that an initial laboratory test that was positive for controlled substances was insufficient to support Defendant’s conviction.On appeal, Defendant argued that the evidence was insufficient to establish the presence of a controlled substance in his system because the initial screen test found only the “possible presence” of drugs, not their actual presence. Without a confirmatory test, Defendant contended, the evidence was insufficient to support a finding of guilt. The Supreme Court agreed and reversed, holding (1) without other evidence, a test that identifies only the “possible presence” of a controlled substance falls short of satisfying the reasonable doubt standard; and (2) the plain meaning of section 321J.2(1)(c) could not be satisfied in this case by relying on the circumstantial evidence of impairment. View "State v. Myers" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the ruling of the district court denying Plaintiff’s motion for a new trial after the jury returned a unanimous verdict finding that Defendant was not negligent, holding that Plaintiff was not prejudiced by the district court’s failure to respond in the affirmative to a certain jury question.Plaintiff suffered a disabling stroke while confined in a halfway house. Plaintiff sued both the halfway house and an attending emergency room physician at a nearby hospital. Plaintiff settled with the halfway house before trial, and the case proceeded to trial against the physician. During deliberations, the jury asked, “If we attribute 25% fault to [the physician] and 75% to [the halfway house] would [the plaintiff] only get 25% since [the halfway house] has been released?” The district court answered by directing the jury back to the original instructions, which did not explain the effect of any fault allocation. The jury returned a verdict finding Defendant not negligent. On appeal, Plaintiff argued that the district court should have answered “yes” to the jury’s question. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court probably should have given an affirmative answer but that there was no prejudice. View "Mumm v. Jennie Edmundson Memorial Hospital" on Justia Law

The Supreme Court reversed the final order of the juvenile court terminating Mother’s parental rights to her three children, entered twenty months after the evidentiary hearing on the issue, holding that the juvenile court erred in denying Mother’s motion to reopen the record filed more than nineteenth months after the original hearing.Approximately six months after the evidentiary hearing, the juvenile court granted the State’s motion to reopen the record and present additional evidence in support of its petition to terminate Mother’s parental rights. Thirteen months later, Mother moved to reopen the evidence seeking to show that she had made reasonable efforts toward reunification. The juvenile court denied Mother’s motion and entered a written order terminating Mother’s parental rights. The Supreme Court reversed the termination order and remanded with instructions to grant Mother’s motion to reopen the record, holding that the juvenile court erred in failing to allow Mother to present additional contemporary evidence. View "In the Interest of L.T." on Justia Law

The Supreme Court affirmed the ruling of the district court on the question on whether the crimes of involuntary manslaughter by a public offense and delivery of a controlled substance merge, holding that the district court did not err in failing to merge the convictions.Defendant was convicted and sentenced for delivery of a controlled substance and involuntary manslaughter by a public offense other than a forcible felony or escape. On appeal, the court of appeals held, among other things, that the crimes did not merge. The Supreme Court granted further review to consider the merger question and then affirmed the judgments of the courts below, holding that Defendant’s crimes should not have merged. View "State v. West" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing Plaintiff’s two-count petition, holding that the district court erred in holding that a seller of auction services of certain machinery is entitled to summary judgment on a claim brought by a buyer of those services under the Door-to-Door Sales Act (DDSA), Iowa Code chapter 555A.Plaintiff brought this action claiming a violation of the DDSA and seeking a declaratory judgment challenging the underlying sales contract because of an invalid execution by a third party and because of fraud in the inducement. The district court granted summary judgment in favor of Defendant, concluding, among other things, that the DDSA does not apply to a contract for auction services, such as the contract in this case. The Supreme Court reversed, holding (1) Defendant was not entitled to summary judgment on the DDSA claim where Defendant presented no evidence that Plaintiff’s purpose in purchasing the auction services was not “primarily for personal, family, or household purposes”; and (2) because the declaratory judgment count had allegations beyond the DDSA the district court erred in dismissing this count of the petition. View "Morris v. Steffes Group, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court vacating an award of fees incurred during agency proceedings under a fee-shifting provision in Division II of the Davenport Civil Rights Ordinance for a housing discrimination violation charged under Division III that lacked a corresponding fee-shifting remedy, holding that that the district court correctly denied an award of attorney fees.A tenant filed a complaint with the Davenport Civil Rights Commission alleging discrimination based on familial status in violation of the Davenport Civil Rights Ordinance and the Federal Fair Housing Act (FHA). An administrative law judge found that the landlord committed a Division III fair housing violation and award the tenant both damages and attorney fees and costs. The Commission approved the ALJ’s decision. The district court reversed the damages award and vacated the fee award. The court of appeals reinstated the fee award. The Supreme Court held that the court of appeals erred in awarding attorney fees because (1) the fee-shifting provision in Division II of the Ordinance was inapplicable to the fair housing violation in Division III; and (2) the Commission could not award fees under the FHA. View "Seeberger v. Davenport Civil Rights Commission" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the judgment of the district court in this challenge to the decision of the Iowa Department of Human Services (DHS) denying a dentist’s requests for a state fair hearing, holding, among other things, that the district court erred in finding that Iowa Code 249A.4(11) requires DHS to afford the dentist a state fair hearing but correctly found that the administrative rules require DHS to give the dentist a state fair hearing.After a managed care organization (MCO) denied reimbursement of claims submitted by Plaintiff, a dentist who contracted with the MCO as a provider, Plaintiff sought review. DHS concluded that the issue of the MCO’s denials of reimbursement was not appealable to DHS. The district court concluded that Plaintiff was entitled to a state fair hearing and that Plaintiff could seek reimbursement from his indigent patients for claims not covered or reimbursed by the MCO. The Supreme Court remanded the case, holding (1) Plaintiff was entitled to a state fair hearing; (2) Plaintiff may bill patents for services not covered or reimbursed by the MCO, but only to the extent as set forth in this opinion; and (3) the district court erred in awarding Plaintiff attorney fees. View "Colwell v. Iowa Department of Human Services" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment to the insurer in this coverage dispute, holding that an electrical-currents exclusion in the policy applied to the loss in this case.A squirrel climbed onto an outdoor electrical transformer at the City of West Liberty’s power plant, eventually triggering an electrical arc that caused substantial damage to the City’s property. The City sought coverage from Employer’s Mutual Casualty Company (EMC) under its all-risks insurance policy. EMC denied coverage based on the electrical-currents exclusion in the policy, which excluded “loss caused by arcing or by electrical currents other than lightning.” The City sought a declaratory judgment of coverage and damages, arguing that the squirrel was an efficient proximate cause of the loss, and therefore, two independent causes, one covered and one excluded, contributed to the loss. The district court disagreed and granted summary judgment to EMC. The Supreme Court affirmed, holding that the loss here was “caused by arcing” and therefore was excluded even though the squirrel triggered the arcing. View "City of West Liberty v. Employers Mutual Casualty Co." on Justia Law

Upon rehearing in this case involving issues related to an automated traffic enforcement (ATE) system, the Supreme Court concluded that the district court properly granted summary judgment in favor of Defendants, the City of Cedar Rapids and Gatso USA, Inc., holding that Plaintiffs’ challenges to the ATE system were unavailing.The City enacted an ordinance designed to authorize and implement the establishment of an ATE system and contracted that Gatso to install the system. Plaintiffs filed a class-action petition against Defendants claiming, among other things, that the ATE system as implemented violated the equal protection, due process, and privileges and immunities clauses of the Iowa Constitution and that the ordinance as implemented unconstitutionally delegated governmental power to a private entity. The district court granted summary judgment in favor of Defendants. The Supreme Court originally affirmed in part and reversed in part and then vacated its earlier opinion and granted the City’s petition for rehearing. On review, the Court held that it relied on an incorrect version of the City’s ATE ordinance in discussing the issue of preemption and then concluded that the district court did not err in granting summary judgment in favor of Defendants. View "Behm v. City of Cedar Rapids" on Justia Law

The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the district court affirming the determination of the Department of Public Safety (DPS) that Appellant was required to register as a sex offender for life, holding that the DPS must accept an earlier court of appeals decision regarding the length of Appellant’s sex offender registration.In 2008, Appellant pled guilty to assault with intent to commit sexual abuse. At his sentencing hearing, the district court informed Appellant that he was only required to register as a sex offender for ten years, when, in fact, Appellant was subject to lifetime registration. When Appellant was informed he was required to register for life, Appellant sought postconviction relief. In 2015, the court of appeals determined that Appellant was only required to register as a sex offender for ten years. The DPS declined to accept the court of appeals’ decision. On judicial review, the district court and court of appeals affirmed the DPS’s determination, concluding that they lacked the authority to determine the length of Appellant’s sex offender registration requirements. The Supreme Court remanded this case to the DPS, holding that the 2015 court of appeals’ decision had preclusive effect over the DPS’s determination. View "Barker v. Iowa Department of Public Safety" on Justia Law