Justia Iowa Supreme Court Opinion Summaries

The Supreme Court remanded this case alleging negligence and products liability for a new trial, holding that statements made by Plaintiff’s counsel during closing arguments were prejudicial.On appeal, the Supreme Court reviewed numerous issues that arose during litigation between the estate of Larry Kinseth, who passed away from mesothelioma, and Weil-McLain, a boiler manufacturer whose products exposed Kinseth to asbestos. The jury awarded Kinseth's Estate compensatory and punitive damages. The Supreme Court remanded the case for a new trial, holding that to the extent the Estate’s counsel made repeated, deliberate references to Weil-McLain’s expenditures in defending this suit and other asbestos actions and issued instructions to use this case to send a message about such expenditures, counsel’s rhetoric prejudiced Weil-McLain. View "Kinseth v. Weil-McLain" on Justia Law

The thirty-day period set forth in Iowa Code 414.15, which requires a petition for writ of certiorari seeking review of a decision of a city zoning board of adjustment to be filed in district court “within thirty days after the filing of the decision in the office of the board,” is triggered when the board posts the decision on its public website, and what is posted must be an actual decision.Plaintiffs filed a petition for certiorari challenging two of the Board of Adjustment’s decisions. The City filed a motion to dismiss, asserting that the petition was untimely because it was not filed within thirty days of the challenged decisions. The district court granted the City’s motion. The Supreme Court reversed the district court’s order to the extent it dismissed the challenge brought by Plaintiffs to the Board’s refusal to revoke a special use permit but affirmed the order to the extent it dismissed their challenge to the Board’s initial recognition of that special use permit, holding that the challenge to the refusal to revoke the permit was timely because the unapproved minutes of a meeting posted to the Board’s website did not amount to “the filing of the decision.” View "Burroughs v. City Of Davenport Zoning Board Of Adjustment" on Justia Law

At issue was Mother’s and Father’s parental responsibility for postsecondary education for their daughter following the dissolution of their marriage.On Mother’s motion, the district court entered an order requiring the parents to each pay $6629 toward their daughter’s education for the 2016-2017 school year. The Supreme Court reversed, holding (1) the presumptive cost of attending an in-state institution under section 598.21F(2)(a) is the cost of attendance as published by the in-state public institution; (2) a child’s scholarship funds, work earnings, and savings may be considered as part of a child’s expected contribution to her education, but available student loans should not be considered as part of a child’s expected contribution; and (3) in this case, Mother and Father must each contribute $6362 toward their daughter’s postsecondary education. View "Larsen v. Larsen" on Justia Law

Assertion of the Fifth Amendment privilege against self-incrimination excuses compliance with forfeiture threshold pleading requirements in Iowa Code 809A.13(4)(d), such as identifying the source of cash.Claimants’ property was seized after a drug interdiction traffic stop. The State sought forfeiture of the impounded vehicle and money discovered in a hidden compartment after issuance of a search warrant. Claimants sought return of the cash and vehicle but their pleadings omitted information required by section 809A.13(4)(d). The district court dismissed the driver’s claims for noncompliance with the statute’s pleading requirements. Following months of litigation, the State consented to return of the vehicle to the owner. The district court denied the owner’s claim for attorney fees. The Supreme Court remanded, holding (1) the district court erred by failing to rule on Claimants’ motions to suppress before adjudicating the forfeiture claims and erred by overruling Fifth Amendment objections to the pleading requirements; and (2) the vehicle owner was a prevailing party entitled to recover his reasonable attorney fees under the forfeiture statute. View "In re Property Seized from Jean Carlos Herrera and Fernando Rodriguez" on Justia Law

The Supreme Court reversed the district court’s decision granting postconviction relief to Defendant on his claim that he had received ineffective assistance of counsel from an immigration attorney when he tried to get a driver’s license, holding that no right to counsel had attached when Defendant went to the driver’s license station.Defendant’s visit to the driver’s license station triggered a criminal investigation and ultimately a conviction for a previously committed fraudulent practice. The district court set aside Defendant’s guilty plea and sentence, holding that Defendant’s counsel, who was representing Defendant in a pending federal immigration case, breached his essential duty to provide necessary advice to Defendant. The Supreme Court reversed, holding that neither the right to counsel under Iowa Const. art. I, 10, nor the United States Constitution Sixth Amendment right to counsel had attached at the time Defendant’s attorney advised Defendant regarding getting a driver’s license, as this was before any investigation or criminal proceedings had begun. View "Hernandez-Ruiz v. State" on Justia Law

The Supreme Court reversed the decision of the district court denying Employer’s motion for summary judgment on Employee’s lawsuit filed under the Iowa Civil Rights Act (ICRA) alleging that Employer discriminated against him based on his age, sex, and national origin.Matthew Jahnke, an employee of Deere & Co., worked as a factor manager at Harbin Works in Harbin, China under a contract with a Deere Chinese subsidiary. As discipline for Jahnke engaging in sexual relationships with two Chinese employees, Jahnke was ultimately removed as the factor manager, repatriated back to the United States, and assigned to a position of lesser authority and lower pay in Waterloo, Iowa. Jahnke filed suit under the ICRA. In its motion for summary judgment, Deere claimed that the ICRA did not apply extraterritorially and that Jahnke based his claims on allegations of discriminatory acts that occurred outside of Iowa. The district court denied the motion. The Supreme Court reversed, holding (1) the ICRA does not apply extraterritorially; and (2) because Jahnke failed to show that either he or Deere was located within Iowa for purposes of the alleged discriminatory act, Jahnke had no claim under the ICRA. View "Jahnke v. Deere & Co." on Justia Law

The Supreme Court vacated the decision of the court of appeals reversing the judgment of the district court that granted summary judgment in favor of Defendants - Plaintiff’s attorney and the attorney’s law firm - in Plaintiff’s legal negligence action, holding that the statute of limitations barred Plaintiff’s action. Specifically, the Court held (1) Iowa Code 614.1(4) barred Plaintiff’s action, and the discovery rule, the continuous-representation rule, and the doctrine of fraudulent concealment did not toll the limitations period or estop Defendants from raising the statute of limitations as an affirmative defense; and (2) no genuine issues of fact existed, and Defendants were entitled to judgment. View "Skadburg v. Gately" on Justia Law

The Supreme Court reversed the rulings of the district court in this appeal from the denial of Defendant’s application for postconviction relief and remanded for further proceedings.As part of his application, Defendant alleged that between the time of his convictions for two counts of sexual abuse and his sentencing, the police department was investigating claims of sexual abuse that his victim was making against local gang members. Defendant further alleged that the ongoing investigation was concealed from his trial counsel and that, prior to sentencing, the police determined that the claims made against the gang members were false. The district court denied disclosure of the investigative reports to Defendant and ruled that all evidence and testimony related to the alleged false claims of the victim would be excluded from the postconviction-relief trial. The Supreme Court reversed and ordered the disclosure of these investigative reports, holding that the reports were relevant, and Defendant advanced a good-faith factual basis demonstrating how the information was reasonably calculated to lead to admissible evidence germane to an element or fact of the claim or defense. View "Powers v. State" on Justia Law

The Supreme Court reversed the ruling of the district court denying Defendant’s motion for credit for time served based on the time he spent in the Bridges of Iowa (Bridges) program, holding that Bridges qualified as a community correctional residential treatment facility, and therefore, Iowa Code 907.3(3) mandated that Defendant be given credit for time served in the facility.Defendant pled guilty to third-degree burglary and was placed on supervised probation for two years. The conditions of Defendant's probation required that he complete the treatment program at Bridges. Defendant participated in the Bridges program for 126 days. Defendant's probation was later revoked, and Defendant pled guilty to second-degree theft. In sentencing Defendant, the district court did not provide credit for the 126 days Defendant was at Bridges, concluding that Bridges was not a correctional or mental health facility under Iowa Code 903A.5(1), nor an alternate jail facility or a community correctional residential treatment facility under section 907.3(3). The Supreme Court reversed for the reasons set forth above. View "State v. Hensley" on Justia Law

In this private action filed by Mother under Iowa Code chapter 600A, the Supreme Court concluded that Father’s parental rights to his children should not be terminated.Mother filed petitions to terminate the parental rights of Father, alleging abandonment, failure to support, and a crime against a child. The district court concluded that Mother proved by clear and convincing evidence that grounds for termination existed and that termination of Father’s parental rights was in the children’s best interest. The Supreme Court reversed, holding (1) Mother met the threshold requirement for private termination by clear and convincing evidence; but (2) Mother did not show by clear and convincing evidence that the best interest of the children will be advanced by termination of Father’s parental rights. View "In re Q.G." on Justia Law