Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed in part and reversed in part the judgment of the district court dismissing Plaintiff’s unjust enrichment, quantum meruit, and promissory estoppel claims, holding that the district court erred in granting Defendants’ motion for summary judgment on the promissory estoppel claim.Plaintiff, a farmer, sued Defendants, his neighbor’s heirs, claiming that he and the decedent entered into an option contract to purchase farmland that Plaintiff leased from he decedent and upon which Plaintiff had made substantial improvements. After the farm was sold, Plaintiff brought this action claiming that Defendants breached an option contract to sell him the property. Alternatively, Plaintiff alleged various equitable theories of promissory estoppel, quantum meruit, and unjust enrichment. A jury found in favor of Plaintiff on his contract claim, but the district court granted Defendants’ motion for directed verdict and refused to order a new trial on Plaintiff’s alternative equitable theories. The court of appeals remanded the case for further proceedings on the equitable claims. On remand, the district court granted Defendants’ motion for summary judgment on the remaining equitable claims. The Supreme Court reversed in part, holding that Plaintiff’s promissory estoppel claim survived summary judgment. View "Kunde v. Estate of Arthur D. Bowman" on Justia Law

The Supreme Court reversed the decision of the district court denying Defendant’s motion to suppress evidence resulting from a stop by an Iowa Department of Transportation (IDOT) Motor Vehicle Enforcement (MVE) officer, holding that the IDOT MVE lacked the authority to stop and arrest Defendant.The MVE in this case stopped Defendant for speeding in a construction zone. After determining that Defendant’s driver’s license had been revoked the MVE arrested Defendant and took him to jail. Defendant was convicted of driving while revoked. On appeal, Defendant argued that IDO MVE officers lacked authority at the time he was stopped to engage in general traffic enforcement under Iowa Code chapter 321 and that the stop and arrest could not be sustained as a citizen’s arrest under Iowa Code 804.9. The Supreme Court agreed, holding that today’s decision in Rilea v. Iowa Department of Transportation, __ N.W.2d ___ (Iowa 2018), required that Defendant’s conviction be vacated and this case remanded for further proceedings. View "State v. Werner" on Justia Law

The Supreme Court held tha before May 11, 2017, Iowa Department of Transportation (IDOT) Motor Vehicle Enforcement (MVE) officers lacked authority to stop vehicles and issue speeding tickets or other traffic citations unrelated to operating authority, registration, size, weight, and load.In 2016, two motorists were separately cited by MVE officers for speeding in a construction zone. In declaratory order proceedings, the IDOT concluded that MVE officers possessed authority to stop vehicles and issue these citations. The district court reversed. The Supreme Court affirmed, holding that, prior to May 11, 2017, IDOT peace officers were conferred only limited authority by chapter 321 of the Iowa Code to enforce violations relating to operating authority, registration, size, weight, and load of motor vehicles and trailers. View "Rilea v. Iowa Department of Transportation" on Justia Law

The Supreme Court reversed Defendant’s convictions for assault causing bodily injury and child endangerment and remanded for a new trial, holding that the jury instructions were prejudicially erroneous.On appeal, Defendant argued that there was insufficient evidence to support his convictions because the State did not establish that his actions exceeded the scope of legal corporal punishment, that the verdict was contrary to the weight of the evidence, and that the jury instructions misled the jury. While rejecting Defendant’s first two assignments of error, the Supreme Court held that Defendant was prejudiced because the instructions misled the jury and that the error was prejudicial. View "State v. Benson" on Justia Law

The Supreme Court vacated Richard Eugene Noll’s sentence as a habitual offender for operating while intoxicated (OWI), third offense, holding that the habitual offender provisions in Iowa Code 902.8 and 902.9 do not apply to OWI, third and subsequent offenses.After he was sentenced, Noll filed a motion to correct an illegal sentence arguing that the statutory scheme did not allow him to be sentenced as a habitual offender. The district court denied the motion. The Supreme Court vacated the sentence, holding that Iowa Code 321J.2(5) prescribes the maximum and minimum sentence for OWI, third and subsequent offenses, and therefore, the habitual offender sentence contained in sections 902.8 and 902.9 did not apply to Noll. View "Noll v. Iowa District Court for Muscatine County" on Justia Law

The Supreme Court reversed the judgment of the trial court convicting Defendant of operating while intoxicated (OWI), holding that the stop of the van in which Defendant was a passenger violated Iowa Const. art. I, section 8.After responding to a dispatch report of a vehicle in a roadside ditch, officers saw a van pass by on the road. Discovering that the van’s license plate was registered to another member of the same household that the vehicle in the ditch had been registered to, the officers followed the van and pulled it over. The driver of the car that had gone into the ditch was riding as a passenger in the van. That person, Defendant, was convicted of OWI. Defendant appealed the denial of his motion to suppress, arguing that the stop of the van was not permissible under the community caretaking doctrine. The Supreme Court agreed and reversed Defendant’s conviction and sentence, holding that the community caretaking exception did not apply under article I, section 8. View "State v. Smith" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the decision of the Iowa Department of Inspections and Appeals denying the petition filed by a manufacturer and seller of electronic game devices (Petitioner) seeking a declaration that its games were not subject to the registration provisions contained in Iowa Code 99B.53, holding that the Department’s actions were not unreasonable, arbitrary, capricious, or an abuse of discretion.In denying the petition, the Department concluded that the outcomes of the games were not primarily determined by the skill or knowledge of the operator, and therefore, the games were subject to registration. The district court affirmed. The Supreme Court affirmed, holding that the Department (1) properly interpreted the relevant statutes; (2) did not prejudice the substantial rights of Petitioner based upon an irrational, illogical, or wholly unjustifiable application of law to fact; and (3) did not prejudice the substantial rights of Petitioner unreasonably, arbitrarily, capriciously, or through an abuse of discretion. View "Banilla Games, Inc. v. Iowa Department of Inspections & Appeals" on Justia Law

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