Justia Iowa Supreme Court Opinion Summaries

The Supreme Court overruled its cases holding that defendants may attack the voluntary and intelligent character of their pleas, holding that the Iowa Constitution allows freestanding claims of actual innocence, and therefore, applicants may bring such claims to attack their pleas even though they entered their pleas knowingly and voluntarily.Appellant filed an application for postconviction relief under Iowa Code 822.2(1)(d), claiming that he was innocent and that he pled guilty because he was “scared.” The district court granted summary judgment for the State, concluding that Appellant waived his claim of actual innocence by pleading guilty. The Supreme Court reversed, holding (1) the Court hereby adopts a freestanding claim of actual innocence that applicants may bring under the postconviction relief statute; and (2) thus, Appellant’s pleas did not preclude him from filing a postconviction-relief action. View "Schmidt v. State" on Justia Law

The relief-required rule, which ordinarily requires proof that a criminal client had been exonerated from the underlying conviction, does not apply to a convicted criminal suing one of his defense attorneys for legal malpractice over an alleged missed opportunity to shorten his period of supervised probation.In this case, Plaintiff’s defense attorney successfully vacated two of Plaintiff’s convictions. Meanwhile, Plaintiff was incarcerated for a probation violation. The district court later determined, sua sponte, that Plaintiff’s term of supervised probation should have ended earlier, which would have avoided almost one year in prison. The district court granted summary judgment to the defendant attorney based on the relief-required rule. The court of appeals reversed, ruling that Plaintiff could sue over the sentencing error without proving his exoneration from the conviction as long as he obtained relief from the sentencing error. The Supreme Court affirmed, holding that Plaintiff here must prove relief from the sentencing error allegedly caused by the malpractice, not the underlying conviction. View "Kraklio v. Simmons" on Justia Law

The Supreme Court reversed the judgment of the district court enjoining Mark Ogden from continuing his nonconforming use of his property as a mobile home park, holding that the City of Des Moines failed to prove that Ogden had exceeded the property’s legal nonconforming use or that it was necessary to enjoin Ogden from continued operation of the mobile home park for the safety of life or property.In its decision, the district court concluded that the nonconforming use of the property exceeded its authorized nonconforming use and that it was necessary to cease operation of the nonconforming use for the safety of life or property. The Supreme Court disagreed, holding that the City did not prove that Ogden had lost the vested right he had in the operation of the mobile park as a legal nonconforming use. View "City of Des Moines v. Ogden" on Justia Law

The Supreme Court reversed Defendant’s conviction for robbery in the first degree and remanded for entry of judgment and sentencing for robbery in the second degree, holding that Defendant’s conviction for robbery in the first degree as an aider and abettor was not supported by sufficient evidence.Defendant agreed to be the getaway driver for his two codefendants, who were going to rob a pharmacy. The codefendants robbed the pharmacy, but Defendant did not give them a ride because they were apprehended by the police before the planned rendezvous took place. All three individuals were convicted of first-degree robbery because a gun had been used in the robbery. On appeal, Defendant argued that the evidence was insufficient to support his conviction because he did not know a gun would be used in the robbery. The court of appeals affirmed. The Supreme Court reversed, holding (1) proof that Defendant had knowledge or intent of the use of the gun was required to support his conviction under an aiding and abetting theory; and (2) there was insufficient evidence to convict Defendant of first-degree robbery as an aider and abettor due to a failure of proof on the dangerous weapon element. View "State v. Henderson" on Justia Law

A corporation does not have family members and therefore cannot qualify for the family-member exception to the employee-numerosity requirement in the Iowa Civil Rights Act (ICRA).Plaintiff worked for Defendant, a small insurance agency, and alleged that she was sexually harassed by her supervisor, the sole owner’s husband. Defendant, a subchapter S corporation, employed the owner, the owner’s husband and two other family members, Plaintiff, and another nonfamily member. Defendant moved for summary judgment on the ICRA claims on the grounds that it employed fewer than four individuals, not counting the family members. The district court denied summary judgment, concluding that a corporate employer is ineligible for the family-member exception to the ICRA contained in Iowa Code 216.6(6)(a). The court of appeals affirmed. The Supreme Court affirmed, holding that Defendant could not avail itself of the family-member exception. View "Cote v. Derby Insurance Agency, Inc." on Justia Law

The City of Albia was statutorily immune from a homeowner’s nuisance claim stemming from reoccurring flooding in the basement of her home due to rainwater discharge from a storm sewer located near the home.The Supreme Court held (1) Iowa Code 670.4(1)(h), which grants immunity to municipalities for tort claims based on claims of negligent design and construction of public improvements and facilities, or failure to upgrade public improvements and facilities, bars those nuisance claims based on conditions created by public improvements and facilities designed and constructed pursuant to generally recognized engineering or safety standards in existence at the time of construction and without evidence that the harmful condition creating the nuisance was inherent in the operation of the improvement or facility itself or evidence of negligent conduct other than the designated conduct immunized under statute; and (2) because the homeowner in this case did not offer any evidence that the City’s storm sewer system was inherently dangerous beyond the dangers associated with failing to upgrade the pipe to accommodate increased water flow, or that the claim was otherwise based on conduct not given immunity, summary judgment on the homeowner’s nuisance claim was properly granted. View "Kellogg v. City of Albia" on Justia Law

Iowa Code 902.1(2)(a)(1), which gives the district court the option to sentence a juvenile offender convicted of murder in the first degree to life imprisonment without the possibility of parole, is unconstitutional based on the Supreme Court’s holding in State v. Sweet, 879 N.W.2d 811 (Iowa 2016), which held that such a sentence for all juvenile offenders violates article I, section 17 of the Iowa Constitution. However, the unconstitutional portion of the statute does not render the remainder of section 902.1(2)(a) unconstitutional.Defendant was convicted of first-degree murder as a juvenile offender. Defendant challenged his sentence of life imprisonment with the possibility of parole after serving a minimum term of twenty-five years confinement. Defendant filed a motion to correct an illegal sentence, arguing that the sentencing scheme for juvenile offenders convicted of first-degree murder set forth in section 902.1(2) was cruel and unusual punishment under the Iowa Constitution. The Supreme Court held (1) section 902.1(2)(a)(1) is unconstitutional, but the remainder of section 902.1(2) is constitutional; and (2) Defendant’s case must be remanded for resentencing under State v. Roby, 897 N.W.2d 127 (Iowa 2017), which was decided subsequent to Defendant’s resentencing. View "State v. Zarate" on Justia Law

A premarital agreement waiver of attorney fees related to child or spousal support adversely affects the right to such support and, therefore, is unenforceable under Iowa Code 596.5(2).Here, Wife and Husband executed a premarital agreement waiving the right to seek an award of attorney fees in the event of a dissolution of their marriage. During the parties’ dissolution proceeding, Wife requested an award of attorney fees arising from litigating issues of child custody, child support, and spousal support. The district court denied the request for attorney fees, concluding that the waiver provision in the premarital agreement was enforceable. The court of appeals reversed with regard to the attorney fees issue, ruling that the waiver provision violated public policy and was unenforceable to the extent that the attorney fees arise from litigation of child-related issues. The Supreme Court vacated the portion of the court of appeals’ decision pertaining to attorney fees and affirmed the decision on all other issues, holding that the district court erred in relying on the attorney-fee-waiver provision in the parties’ premarital agreement to deny Wife’s request for support-related attorney fees. View "Erpelding v. Erpelding" on Justia Law

The court of appeals erred in ruling that a taxpayer avoided in Iowa inheritance tax through a private postmortem family settlement agreement (FSA).Here, the decedent, before his death, signed a beneficiary form listing the taxpayer as a contingent beneficiary of his brokerage account. That account transferred to the taxpayer upon the decedent's death. The Iowa Department of Revenue (IDOR) determined that the estate owed the inheritance tax on the full account value. The decedent’s grandchildren sued the taxpayer claiming that they were entitled to the brokerage account under the decedent’s will because the decedent lacked the mental capacity to execute an enforceable beneficiary designation for the account. The taxpayer settled the suit by transferring half the account value to the plaintiffs under an FSA. The taxpayer then sought a refund of part of the inheritance tax already paid. The IDOR denied a refund, determining that the taxpayer failed to establish incapacity. The district court affirmed. The court of appeals reversed, concluding that the FSA controlled the tax issue. The Supreme Court vacated the decision of the court of appeals and affirmed the district court judgment, holding that, without an adjudication of incapacity, the FSA was not binding on the IDOR and could not avoid the inheritance tax. View "Nance v. Iowa Department of Revenue" on Justia Law

The Supreme Court reversed the district court’s dismissal of Appellant’s motion to reinstate its application for postconviction relief (PCR), which the district court dismissed for want of prosecution under Iowa R. Civ. P. 1.944, holding that Lado v. State, 804 N.W.2d 428 (Iowa 2011) controlled this matter.In Lado, the Supreme Court held that PCR counsel was ineffective in failing to avoid dismissal of a PCR application under Rule 1.944 and that the error was structural. On appeal in the instant case, the court of appeals declined to consider Appellant’s Lado argument because it was raised for the first time in his reply brief. The Supreme Court vacated the decision of the court of appeals, reversed the orders of the district court, and remanded for further proceedings, holding that Appellant’s ineffective assistance argument should be considered for several reasons even though it was not raised until the reply brief. View "Villa v. State" on Justia Law