Justia Iowa Supreme Court Opinion Summaries

Mathahs has practiced law in Iowa since 2001. In October 2001, he contracted with the Iowa State Public Defender (SPD) to provide legal services to indigent adults and juveniles in certain Iowa counties. The contract was renewed until 2013. Mathahs submitted General Accounting Expenditure (GAX) forms to the SPD detailing the dates, services performed, and the amount of time for each service. In March 2013, the SPD contacted Mathahs with concerns over the accuracy of Mathahs’s GAX forms. Mathahs had claimed more than 3000 hours and had received more than $180,000 in fiscal year 2010. Mathahs initially blamed inaccuracies on his secretary. SPD rejected Mathahs’s explanation. On April 26, Mathahs self-reported his misconduct to the Iowa Supreme Court Attorney Disciplinary Board. On September 23, 2015, after investigating, the attorney general’s office informed the SPD that it found no provable evidence of intent to steal or defraud. In June 2017, the Board filed a complaint, alleging violations of Iowa Rules of Professional Conduct 32:1.5(a) (unreasonable fees or expenses) and 32:5.3(b) (lack of supervision over a nonlawyer employee). Mathahs moved to dismiss, claiming laches because the Board delayed for more than four years in bringing its complaint after he had self-reported and such delay unduly prejudiced his defense. A panel of the Supreme Court Grievance Commission found that Mathahs violated the rules. The Supreme Court of Iowa imposed a 60-day suspension, declining to address the issue of laches. View "Iowa Supreme Court Attorney Disciplinary Board v. Mathahs" on Justia Law

In this case challenging an automated traffic enforcement (ATE) program implemented by the City of Des Moines and its private contractor, Gatso USA, Inc., the Supreme Court reversed in part and affirmed in part the district court’s judgment, holding that the district court (1) erred in finding that the City’s ATE ordinance violated procedural due process; (2) properly granted Defendants’ motion to dismiss on grounds of preemption; (3) did not err in granting summary judgment to Gatso on Plaintiffs’ unjust enrichment claims; (4) erred in dismissing Plaintiffs’ equal protection, substantive due process, and privileges and immunities claims; and (5) erred in holding that there was no action for damages under the Iowa Constitution. Further, in light of the changed posture of the case, the Supreme Court vacated the district court’s order on unjust enrichment and the order on class certification and remanded for further consideration. View "Weizberg v. City of Des Moines" on Justia Law

The Supreme Court affirmed the judgment of the district court and the decision of the court of appeals concluding that Appellant violated the ordinance established by City of Cedar Rapids regarding the operation of an automated traffic enforcement (ATE) system.A magistrate found clear and convincing evidence that Appellant violated the ATE ordinance while speeding where the ATE system was operating. The district court affirmed. The Supreme Court affirmed, holding (1) substantial evidence supported that Cedar Rapids established that Appellant was speeding in violation of the ordinance by clear, satisfactory, and convincing evidence; (2) Appellant was not entitled to relief as to her arguments raised with respect to equal protection, privileges and immunities, and substantive due process; and (3) there was no unlawful delegation in this case. View "City of Cedar Rapids v. Leaf" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court granting summary judgment in favor of Defendants on Plaintiffs’ class-action petition claiming that an automated traffic enforcement system (ATE) as implemented by Defendants violated the due process, privileges and immunities, and equal protection clauses of the Iowa Constitution.Specifically, hte Supreme Court held (1) the ATE system does not infringe on a fundamental right to intrastate travel; (2) the ATE system does not violate substantive due process; (3) the district court properly granted summary judgment on Plaintiffs’ equal protection and privileges and immunities claims; (4) the provisions of the ordinance that purportedly impose liability on a protesting vehicle owner under certain circumstances are irreconcilable with the provisions of Iowa Code 364.22 and are thus preempted; (5) the process outlined in the ATE ordinance complies with due process; (6) Plaintiffs’ unlawful delegation claims failed; and (7) because the district court’s judgment on the issue of preemption is reversed, the court’s judgment on unjust enrichment must be vacated and remanded for further consideration in light of the changed posture of the case. View "Behm v. City of Cedar Rapids" on Justia Law

The Supreme Court held that a premarital agreement provision waiving an award of attorney fees related to issues of child or spousal support is categorically prohibited by Iowa Code 596.5(2), and Iowa Code 596.5(1)(g) prohibits fee-shifting bar provisions as to child-custody issues.The parties in this case executed a premarital agreement waiving the right to seek an award of attorney fees in the event of a dissolution of their marriage. During their dissolution proceeding, Wife requested an award of attorney fees arising from litigating issues of child custody, child support, and spousal support. The district court declined to award attorney fees, concluding that, in the absence of any articulated public policy of the state, it did not have authority to ignore the plain language of the parties’ premarital agreement. The court of appeals reversed, concluding that the waiver provision in the premarital agreement was unenforceable as to child-related issues because it violates public policy. The Supreme Court affirmed the court of appeals decision on its award of attorney fees for child-related issues but vacated the part of the decision regarding attorney fees for spousal support, holding that the premarital agreement was also unenforceable as to the spousal-support issues. View "Erpelding v. Erpelding" on Justia Law

The Supreme Court answered a question asked by the federal district court as to whether a defendant can raise a defense of qualified immunity to an individual’s claim for damages in violation of Iowa Const. art. I, 1 and 8.The operator of an ATV was arrested then released based on the finding that his conduct was not prohibited by law. Thereafter, the ATV operator brought suit against the city and the police officers under article I, sections 1 and 8 of the Iowa Constitution. The case was removed to federal court, which granted summary judgment to Defendants. The federal district court then certified a question of law to the Supreme Court. The Supreme Court answered that a defendant who pleads and proves as an affirmative defense that the defendant exercised all due care to conform with the requirements of the law is entitled to qualified immunity on an individual’s claim for damages in violation of article I, sections 1 and 8 of the Iowa Constitution. View "Baldwin v. City of Estherville, Iowa" on Justia Law

The Supreme Court held that Division I of Senate File 471 (the Act), which creates new prerequisites for physicians performing an abortion, violates both the due process and equal protection clauses of the Iowa Constitution because its restrictions on women are not narrowly tailored to serve a compelling interest of the State.The district court held that the Act, which includes a mandatory seventy-two-hour waiting period between informational and procedure appointments, did not violate the Iowa Constitution. The Supreme Court reversed, holding that the “seventy-two hour[]” waiting requirement of the Act violates the right to equal protection and due process under the Iowa Constitution. View "Planned Parenthood of the Heartland v. Reynolds ex rel. State" on Justia Law

The conduct of an attorney who was removed by order of the district court from his elected position as Van Buren County Attorney, while deserving of disapproval, did not rise to the level of misconduct that would warrant the “drastic” remedy of a court order removing an elected official from office.The Supreme Court reversed the judgment of the district court and vacated the order removing Defendant from the office of county attorney, holding that the State’s evidence was insufficient to meet the high bar necessary for the removal of Defendant from his elected office. The Supreme Court remanded the case for entry of an order reinstating Defendant as Van Buren County Attorney. View "State v. Watkins" on Justia Law

At issue was whether the three-year statute of limitations in Iowa Code 822.3 applies where a postconviction relief (PCR) petitioner files an untimely second petition for PCR alleging that counsel for his timely filed first petition for PCR was ineffective.The district court concluded that the second petition’s allegations of ineffective assistance of postconviction counsel were not grounds to avoid the three-year statutory bar. The court of appeals affirmed, citing the Supreme Court’s decision in Dible v. State, 557 N.W.2d 881, 883, 886 (Iowa 1996).The Supreme Court qualified Dible and held that where a PCR petition alleging ineffective assistance of trial counsel has been timely filed per section 822.3 and there is a successive PCR petition alleging that postconvcition counsel was ineffective in presenting the ineffective-assistance-of-trial-counsel claim, the timing of the filing of the second PCR petition relates back to the timing of the filing of the original PCR petition for purposes of Iowa Code section 822.3 if the successive PCR petition is filed promptly after the conclusion of the first PCR petition. The Court therefore vacated the court of appeals and reversed the decision of the district court and remanded the case. View "Allison v. State" on Justia Law

The Supreme Court adopted a tighter legal framework for warrantless inventory searches and seizures of automobiles under Iowa Const. art. I, 8 than provided under the recent precedents of the United States Supreme Court.In his challenge to the search and seizure provision of article I, section 8 of the Iowa Constitution Defendant noted that a number of state courts have rejected the approach of the United States Supreme Court - which generally provides that warrantless inventory searches of automobiles are permissible if they are conducted pursuant to law enforcement policies that govern the decision to impound the vehicle and the nature and scope of any subsequent search - in favor of a more restrictive approach that sharply limits warrantless searches and seizures of automobiles.The Supreme Court ultimately held (1) the police should advise the owner or operator of the vehicle of the options to impoundment, and when impoundment is necessary, personal items may be retrieved from the vehicle, and if the vehicle is impounded, containers found within the vehicle will not be opened but stored for safekeeping as a unit unless the owner or operator directs otherwise; and (2) the impoundment and search in this case was outside the bounds of any constitutionally permissible local impoundment and inventory policy. View "State v. Ingram" on Justia Law