Justia Iowa Supreme Court Opinion Summaries

The equitable tolling doctrines of the discovery rule and equitable estoppel are available with respect to the 300-day filing limitation in the Iowa Civil Rights Act (ICRA).Plaintiff, an applicant for the position of Deputy Workers’ Compensation Commissioner at Iowa Workforce Development (IWD), brought a failure-to-hire claim against the IWD. The district court dismissed the claim, concluding that Plaintiff could not escape the 300-day filing requirement in the ICRA through application of the discovery rule or equitable estoppel. The Supreme Court affirmed, holding (1) the discovery rule and equitable estoppel apply to the 300-day filing limitation in the ICRA; but (2) Plaintiff was not entitled to toll the filing limitation through application of either the discovery rule or equitable estoppel. View "Mormann v. Iowa Workforce Development" on Justia Law

Retaliatory discharge claims are not categorically reserved for at-will employees.A state administrative law judge (ALJ) brought suit alleging wrongful termination in violation of public policy after she was terminated for giving unfavorable testimony about the director of her division to the Iowa Senate Government Oversight Committee. The ALJ’s employment was covered by a collective bargaining agreement (CBA). The State filed a motion to dismiss, asserting that the common law claim of wrongful discharge is reserved for at-will employees. The district court agreed and dismissed the case. The court of appeals reversed, concluding that the ALJ’s status as a CBA-covered employee did not preclude her wrongful-discharge claim. The Supreme Court affirmed, holding that the common law tort of retaliatory discharge against public policy is generally available to contract employees. View "Ackerman v. State" on Justia Law

Retaliatory discharge claims are not categorically reserved for at-will employees.A state administrative law judge (ALJ) brought suit alleging wrongful termination in violation of public policy after she was terminated for giving unfavorable testimony about the director of her division to the Iowa Senate Government Oversight Committee. The ALJ’s employment was covered by a collective bargaining agreement (CBA). The State filed a motion to dismiss, asserting that the common law claim of wrongful discharge is reserved for at-will employees. The district court agreed and dismissed the case. The court of appeals reversed, concluding that the ALJ’s status as a CBA-covered employee did not preclude her wrongful-discharge claim. The Supreme Court affirmed, holding that the common law tort of retaliatory discharge against public policy is generally available to contract employees. View "Ackerman v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeals finding substantial evidence that the juvenile in this case committed a sex offense by force and that the sex offender registry requirements imposed upon the juvenile by law did not violate the prohibition against cruel and unusual punishment under either the state or federal Constitutions.The juvenile court found the juvenile committed a sex offense by force and required him to register as a sex offender under Iowa Code 692A.103(4), the mandatory sex offender registry statute. The court of appeals affirmed. The Supreme Court affirmed, holding that automatic, mandatory registration for certain juvenile sex offenders is punishment but that such registration does not amount to cruel and unusual punishment. View "In re T.H." on Justia Law

In this medical malpractice action, the Supreme Court affirmed in part and reversed and remanded in part the judgment of the district court removing Plaintiffs’ informed consent claims from this case and entering judgment for Defendants on Plaintiffs’ specific negligence claim.Plaintiffs, a patient and his family, brought this lawsuit against Defendants, a physician and the physician’s employer. The district court granted summary judgment in favor of Defendants on the informed consent claim based on the physician’s failure to disclose his lack of training and experience in performing the procedure and, during trial, refused to allow the informed consent claim based on the physician’s failure to disclose the risk of the surgery considering the patient’s bad heart. The jury then returned a verdict for Defendants on the specific negligence claim. The court of appeals affirmed. The Supreme Court affirmed the judgment on the specific negligence claim but remanded the case to allow Plaintiffs to proceed on their two informed consent claims, holding that the district court erred in removing the two informed consent claims from the case. View "Andersen v. Khanna" on Justia Law

The district court correctly granted summary judgment in favor Humboldt County on Plaintiff’s claim that the county was liable for the injuries she received when her vehicle went off the county road and into a ditch then struck a concrete embankment in the ditch based on the public-duty doctrine.The embankment in this case had been constructed by a private landowner and was on the private landowner’s land, but the county had a right-of-way easement where part of the embankment was located. In her complaint, Plaintiff alleged that the county should have caused the removal of the concrete embankment from the ditch. The Supreme Court affirmed the district court’s grant of summary judgment, holding that the public-duty doctrine is “alive and well in Iowa” and applies to the facts of this case. View "Johnson v. Humboldt County" on Justia Law

The Supreme Court affirmed the decision of the district court affirmed the decision of the workers’ compensation commissioner that Claimant was not entitled to healing period benefits under Iowa Code 85.34(1).Claimant filed a petition seeking workers’ compensation benefits after developing bilateral carpal tunnel injuries allegedly arising out of and in the course of her employment with Employer. Employer admitted liability and authorized Claimant to undergo medical care with its chosen medical providers. Claimant, however, sought medical treatment from an unauthorized physician. The physician performed two surgeries on Claimant, and Employer refused to pay healing period benefits for the time Claimant was recovering from the unauthorized surgeries. The commissioner concluded that Claimant was not entitled to healing period benefits because Employer provided a valid authorization defense. The district court affirmed. The Supreme Court affirmed, concluding that where Claimant received unauthorized medical care she was not entitled to healing benefits. View "Brewer-Strong v. HNI Corp." on Justia Law

At issue was negligence and defamation claims brought by two female parishioners and their spouses against a church based on sexual abuse and exploitation perpetrated on the women by the church pastor and the subsequent response by the governing body of the church.The district court granted summary judgment for the church on all claims except negligent supervision. The court then found that the negligent supervision claims brought by the female parishioners were barred by the statute of limitations. The Supreme Court affirmed in part and reversed in part, holding (1) the Religion Clauses of the Iowa and United States Constitutions barred two of the negligence claims brought against the church; (2) the First Amendment does not bar negligent supervision claims against religious entities, and while the relevant statute of limitations barred one parishioner’s claim of negligent supervision, it did not bar the other female parishioner’s negligent supervision claim; and (3) the district court properly dismissed the defamation claims. View "Bandstra v. Covenant Reformed Church" on Justia Law

Appraisers may determine the factual cause of damage to insured property to ascertain the amount of the loss, but coverage questions are to be resolved by the court.In the instant case, the district court rejected an insurance appraisal award for hail damage to roofing shingles. The property insurer denied coverage for hail caused damage to the asphalt shingles based on a preexisting manufacturing defect. The insured townhome association sued the insurer for breach of contract and invoked the appraisal provision of the property insurance policy to ascertain the amount of the loss from the hailstorm. The appraisal panel valued the hail damage loss at $1.4 million. The district court found no shingle damage from hail, applied an exclusion for defective materials, and rejected the appraisal award. The Supreme Court remanded the case, holding (1) the district court erred by disregarding the appraisal award’s determination of the amount of the loss for shingles damaged by the hailstorm; and (2) the issue of the extent of preexisting shingle damage excluded from coverage must be decided by the court on remand. View "Walnut Creek Townhome Ass’n v. Depositors Insurance Co." on Justia Law

The Supreme Court reversed the judgment of the district court in favor of the Board of Adjustment in this action brought of developers seeking the right to build apartments on adjoining properties they owned in Iowa City and remanded with directions to enter judgment in favor of the developers.After the City denied the developers’ plans, the developers brought actions against the City and its Board of Adjustment. The district court ruled against the developers, thus rejecting the developers’ argument that a 1987 court order allowed them to proceed. The Supreme Court reversed the district court’s ruling in favor of the Board, holding (1) the Board should have permitted the developers to proceed in accordance with the 1987 decree, and the developers were entitled to enforce the decree as “successors and assigns”; (2) the statute of limitations did not bar enforcement of the decree; and (3) the Board’s argument that the decree had expired by its terms because “a use [had] been developed or established” on the properties failed. View "TSB Holdings, LLC v. City of Iowa City, Iowa" on Justia Law