Justia Iowa Supreme Court Opinion Summaries

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

The Supreme Court dismissed this appeal, holding that Appellant failed to file a timely notice of appeal, which left the Court without subject matter jurisdiction to hear the appeal.This appeal concerned a dispute over workers’ compensation penalty benefits. Appellees filed a motion to dismiss the appeal on the grounds that Appellant failed timely to file his notice of appeal with the district court. The Supreme Court agreed and dismissed the appeal, holding that Appellant’s counsel did not file the notice of appeal with the clerk of court within a reasonable time after the first notice of appeal was served on Appellees. View "Evenson v. Winnebago Industries, Inc." on Justia Law

The Supreme Court affirmed Defendant’s conviction of operating while intoxicated (OUI), second offense, holding that Defendant’s rights under Iowa Code 804.20 were not violated when a law enforcement officer denied Defendant’s request to call his wife until after sobriety testing occurred.Defendant was driving a motor vehicle when he was involved in an accident in the midst of a snowstorm. Because of the weather conditions, the law enforcement officer that responded to the scene transported Defendant to a protected location - the sally port of the nearby law enforcement center - for the completion of field sobriety testing. Before leaving the scene, Defendant asked to talk to his wife, but the request was denied. Defendant subsequently failed field sobriety tests. Defendant was later convicted of OUI. Defendant appealed, arguing that his rights were violated because he had been “restrained of his liberty” within the meaning of section 804.20 at the sally port. The Supreme Court affirmed, holding that Defendant’s rights under section 804.20 were not violated when the officer refused to allow Defendant the opportunity to speak with his wife until after field sobriety testing had been completed at the sally port because the sally port was a location for testing, not a “place of detention” within the meaning of section 804.20. View "State v. Davis" on Justia Law

The Supreme Court upheld the Iowa Department of Revenue’s sales tax assessment on labor installing building components sold by Lowe’s Home Centers, LLC, except as to those transactions in which the predominant service or only service provided was carpentry installation work, holding that because the Department’s own regulations limit the definition of carpentry services subject to sales tax to those performed for repairs and omits installations services, the sales tax did not apply.The parties here disagreed whether the sales tax applied to labor installing items sold by Lowe’s to homeowners through installation contracts. The Supreme Court held that the sales tax did not apply to carpentry for installations other than repairs but that installation services by electrical and plumbing subcontractors, which involved no structural changes to the homes of customers, did not fall within the statutory exemption for “new construction, reconstruction, alteration, remodeling, or the services of a general building contractor.” See Iowa Code 423.3(37). View "Lowe's Home Centers, LLC v. Iowa Department of Revenue" on Justia Law