Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant’s convictions but vacated certain portions of Defendant’s sentences, holding that the imposition of a surcharge violated the Ex Post Facto Clauses of the state and federal constitutions and that the district court erroneously ordered restitution without determining Defendant’s reasonable ability to pay.Defendant pled guilty to lascivious acts with a child and sexual exploitation of a minor. On appeal, Defendant argued that the district court failed to comply with Iowa R. Crim. P. 2.8(2)(b) in accepting his guilty pleas, did not adequately inquire into an alleged communication breakdown in the attorney-client relationship, violated the Ex Post Facto Clauses by imposing a surcharge, and erred in ordering restitution without first determining his reasonable ability to pay. The Supreme Court held (1) Defendant did not preserve error on his guilty pleas challenge; (2) the record on appeal was insufficient to conduct an ineffective assistance of counsel analysis and to determine whether the district court adequately inquired into the alleged communication breakdown; and (3) the surcharge and restitution were erroneously imposed. View "State v. Petty" on Justia Law

The Supreme Court reversed the portion of Defendant’s sentence regarding restitution but affirmed the district court’s decisions revoking Defendant’s deferred judgment and probation and sentencing him to serve a maximum of twenty-five years in prison, holding that the court erred in finding Defendant reasonably able to pay restitution when it did not have the total amount of restitution owed.Specifically, the Court held (1) the district court did not abuse its discretion in revoking Defendant’s deferred judgment and probation; (2) the district court did not err in ordering Defendant to serve the twenty-five-year sentence he would have served had the court not granted a deferred judgment; but (3) the court erred in ordering Defendant to pay restitution without knowing the total amount of restitution owed. View "State v. Covel" on Justia Law

The Supreme Court affirmed Defendant’s convictions for willful injury causing bodily injury and kidnapping in the first degree but vacated the restitution portion of the sentencing order and remanded the case to the district court to order restitution in a manner consistent with this opinion, holding that the restitution order did not comply with restitution law.Specifically, the Court held (1) substantial evidence supported Defendant’s conviction for first-degree kidnapping; (2) Defendant was not prejudiced when the court instructed the jury on a lesser included charge of kidnapping in the second degree; (3) this Court cannot reach Defendant’s ineffective assistance of counsel claims; and (4) the lower court’s finding that Defendant had the reasonable ability to pay and ordering restitution for certain items without having the amount of each item of restitution before it was contrary to the statutory scheme as outlined in this opinion. View "State v. Albright" on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that challenged portions of Iowa Administrative Code rule 441-78.1(4) violate the Iowa Civil Rights Act (ICRA) and determining that the Iowa Department of Human Services’ (DHS) denial of Medicaid coverage for gender-affirming surgeries was reversible, holding that the rule violates the ICRA’s prohibition against gender-identity discrimination.At issue was the language of rule 441-78.1(4) pertaining to the exclusion of Iowa Medicaid coverage of surgical procedures related to “gender identity disorders” violated the ICRA or the Iowa Constitution’s equal protection clause. The district court concluded that the challenged portions of the rule violated both the ICRA and the Constitution and that the DHS’s denial of Medicaid coverage for gender-affirming surgeries would result in a disproportionate negative impact on private rights and that the decision was unreasonable, arbitrary, and capricious. The Supreme Court affirmed, holding (1) rule 441-78.1(4)’s exclusion of Medicaid coverage for gender-affirming surgery violates the ICRA as amended by the legislature in 2007; and (2) under the doctrine of constitutional avoidance the Court did not address the constitutional claim. View "Good v. Iowa Department of Human Services" on Justia Law

The Supreme Court affirmed Defendant’s conviction of second-degree burglary and reversed the habitual offender judgment and Defendant’s sentence, holding that Defendant’s stipulation to being a habitual offender was not knowingly and voluntarily made.A jury found Defendant guilty of burglary in the second degree. While the jury was in deliberations, Defendant’s counsel informed the court that Defendant would stipulate to predicate priors for the habitual offender charge. The district court sentenced Defendant as a habitual offender to incarceration not to exceed fifteen years and ordered restitution. On appeal, Defendant argued that the district court failed to comply with the requirements set forth in State v. Harrington, 893 N.W.2d 36 (Iowa 2017), in accepting his habitual offender stipulation. The Supreme Court agreed, holding that the stipulation was not knowingly and voluntarily made because the stipulation proceedings did not comply with the Harrington requirements. The Court remanded the case for further proceedings consistent with Harrington. View "State v. Smith" on Justia Law

The Supreme Court affirmed the judgment of the district court entering judgment against a commercial general liability (CGL) insurer on a homeowners’ insurer’s lawsuit seeking reimbursement for the amount it paid to settle a death claim, holding that the district court correctly interpreted the CGL insurance contract, and substantial evidence supported the court’s factual findings on potential liability and the reasonableness of the settlement.A dentist and his wife formed a limited liability company (LLC) that held title to investment properties, including a farmhouse. An accidental shooting at the farmhouse resulted in a death, and a death claim followed. The dentist had purchased homeowners liability insurance and CGL insurance from separate insurers. The CGL insurer denied coverage. The homeowners’ insurer settled the death claim for $900,000. Thereafter, the homeowners’ insurer filed this action seeking subrogation from the CGL insurer. The district court entered judgment against the CGL insurer for $450,000. The Supreme Court affirmed, holding that the LLC, as owner of the farmhouse, had potential liability under a premises liability theory for a dangerous condition and that the CGL insurer, as coinsurer of the farmhouse property, was obligated to indemnify the homeowners’ insurer for half of the $900,000 settlement. View "Metropolitan Property & Casualty Insurance Co. v. Auto-Owners Mutual Insurance Co." on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the decision of the district court annulling a writ of certiorari challenging the decision of the City of Ames’s Zoning Board of Adjustment (ZBA) denying Ames 2304, LLC’s permit for an interior model of a nonconforming use residential structure, holding that the ZBA erred in denying Ames 2304’s interior remodeling permit because the remodel would not increase the number of dwelling units in the structure.The proposed remodel in this case would increase the number of bedrooms while maintaining the same number of apartment dwelling units. The ZBA determined that the local zoning ordinance prohibited this increase in the number of bedrooms because it would increase the intensity of the nonconforming use. The Supreme Court held that the ZBA erred in denying the interior remodeling permit because the zoning ordinance defined an “increase in intensity” as an increase in the number of dwelling units, and the remodel would not increase the number of dwelling units in the structure. View "Ames 2304, LLC v. City of Ames, Zoning Board of Adjustment" on Justia Law

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