Justia Iowa Supreme Court Opinion Summaries

In this case, a private citizen, Robert Teig, appealed a summary judgment granted to city officials in his lawsuit alleging violations of the Iowa Open Records Act. Teig had requested job applications and other documents related to the City of Cedar Rapids' hiring processes for a new city clerk and city attorney. The City refused many of Teig's requests, citing attorney-client privilege and the Act's confidentiality provisions as reasons for withholding several documents.The district court granted the City's motion for summary judgment, leading to Teig's appeal. He argued that job applications submitted to governmental bodies are not confidential under chapter 22, municipalities cannot claim attorney-client privilege in the context of an open records request, search and retrieval fees are not authorized by chapter 22, the defendants unreasonably delayed fulfilling certain requests, and the district court should have granted him leave to submit additional interrogatories in the ensuing litigation.The Supreme Court of Iowa affirmed in part and reversed in part the district court's decision. The court held that documents subject to attorney-client privilege are protected from disclosure under chapter 22 and that chapter 22 authorizes municipalities or governmental bodies to charge search and retrieval fees. However, the court found that while job applications are generally protected from disclosure, that protection extends only to persons "outside of government." Therefore, the City was obligated to disclose those applications submitted by current employees of the City, although it properly withheld external applications. The court also found that the district court failed to address Teig’s claims of undue delay related to billing records. The case was remanded for further proceedings. View "Teig v. Chavez" on Justia Law

The case involves a landowner, Medardo Rivera, who sought to clear an easement from his property. The easement was granted by a previous owner of the property to Clear Channel Outdoor, Inc., and later assigned to TLC Properties, Inc., an affiliate of Lamar Advertising Company. The easement allowed for the construction and operation of billboards on the property. Rivera argued that the easement was void as it was granted after he had already purchased the property.The district court granted summary judgment in favor of the easement holder, ruling that Rivera's action was time-barred under Iowa Code section 614.17A. This statute prevents actions to recover or establish an interest in real estate if the action is based on a claim arising more than ten years earlier, is against the holder of the record title to the real estate in possession, and the holder and their grantors have held chain of title to the real estate for more than ten years.The Supreme Court of Iowa reversed the district court's decision. The court agreed with Rivera's argument that section 614.17A could not apply to an action to clear an easement. The court reasoned that by its terms, section 614.17A only applies to claims against a "holder of the record title to the real estate in possession." Because easements are nonpossessory interests, an easement holder does not possess the encumbered real estate, and so section 614.17A cannot apply to an action to clear an easement. The case was remanded for further proceedings. View "Rivera v. Clear Channel Outdoor, LLC" on Justia Law

The case revolves around a legal malpractice action against a state public defender, who represented a client convicted of sexual abuse. The client, Donald Lyle Clark, was convicted and sentenced to prison. The conviction was affirmed on appeal. However, in postconviction proceedings, the court determined that Clark's defense counsel had provided ineffective assistance and ordered a new trial. The state declined to prosecute, and Clark filed a civil action for legal malpractice against the state as the lawyer’s employer. The district court granted partial summary judgment, holding that the finding of ineffective assistance in the postconviction proceedings established counsel’s negligence as a matter of law. The jury found the lawyer negligent and awarded Clark $12 million in emotional distress damages.The Supreme Court of Iowa reversed the judgment for emotional distress damages. The court clarified that to recover emotional distress damages for legal malpractice, the plaintiff must prove more than negligence. The court held that the plaintiff must prove by a preponderance of clear, convincing, and satisfactory evidence that the criminal defense attorney acted with willful and wanton disregard for the client’s rights or safety. The court concluded that the district court erred by instructing the jury that negligence was sufficient. The case was remanded for further proceedings consistent with this opinion. View "Clark v. State of Iowa" on Justia Law

Timothy Smith was convicted of two counts of sexual abuse in the second degree for the sexual abuse of his former stepdaughter, H.R. Smith filed an application for postconviction relief, arguing that his trial counsel provided ineffective assistance in failing to request additional peremptory strikes after the trial court denied his for-cause challenges to four prospective jurors, in failing to move for a mistrial due to claimed juror misconduct, and in failing to call favorable defense witnesses. The postconviction court denied Smith’s application for postconviction relief.The Iowa Court of Appeals held that the postconviction court erred in denying Smith’s claim regarding trial counsel’s failure to request additional peremptory strikes but did not address the remaining claims. The court of appeals reversed Smith’s convictions and remanded the case for further proceedings. The State of Iowa appealed this decision to the Supreme Court of Iowa.The Supreme Court of Iowa vacated the decision of the court of appeals and affirmed the judgment of the district court. The Supreme Court held that Smith failed to establish that his trial counsel breached an essential duty in not moving for a mistrial due to alleged jury misconduct. The court also held that Smith failed to prove his trial counsel breached an essential duty in failing to call certain witnesses that would have been favorable to Smith’s defense. The court concluded that the cumulative prejudice analysis set forth in Clay was inapplicable here because the court found no breaches of duty for those claims. View "Smith v. State of Iowa" on Justia Law

The case involves Kari Schwartz, a high school teacher, who was found guilty of sexual exploitation by a school employee. The charges stemmed from her relationship with a 17-year-old student, A.S., in her art class. Schwartz began spending more time with A.S., both in and outside of school, and started sharing personal, intimate stories. She also made comments about A.S.'s physical appearance and initiated physical contact, including hugging. Schwartz also sent multiple messages to A.S., expressing her love and inviting her to do things outside of school. The most serious incident occurred when Schwartz touched A.S. inappropriately in a school stairwell.The case was first heard in the Iowa District Court for Buchanan County, where Schwartz was found guilty. She appealed her conviction and sentence, raising four challenges. The Iowa Court of Appeals affirmed the conviction and sentence. Schwartz then sought further review from the Supreme Court of Iowa.The Supreme Court of Iowa affirmed the decisions of the lower courts. The court found substantial evidence supporting Schwartz's conviction, including her systematic conduct towards A.S. and the sexual nature of her actions. The court also rejected Schwartz's challenge to the jury instruction, which included hugging as a form of sexual conduct. The court held that the instruction was a correct statement of the law and that the jury was not misled by it. The court concluded that Schwartz was not prejudiced by the instruction and affirmed her conviction and sentence. View "State of Iowa v. Schwartz" on Justia Law

Darius Wade was pulled over for speeding, and the officer detected the smell of marijuana. A search of Wade's truck revealed a 9mm handgun in a backpack. Wade was charged and convicted of possession of a firearm by a felon as a habitual offender and operating while intoxicated, second offense. For the firearm conviction, the district court sentenced him to an indeterminate term of incarceration not to exceed fifteen years with a three-year mandatory minimum, but then suspended the prison sentence and imposed formal probation “for a period of 2 - 5 years.”The case was appealed to the Iowa Court of Appeals, where Wade argued that there was insufficient evidence to support his firearm conviction and that his term of probation constituted an illegal sentence because it failed to specify the length of his probation. The court of appeals upheld Wade's firearm conviction and ruled that the district court was authorized to impose a period of probation not less than two years and not more than five years. Wade sought further review from the Supreme Court of Iowa.The Supreme Court of Iowa affirmed the court of appeals' decision regarding the sufficiency of evidence for the firearm conviction. However, it disagreed with the court of appeals' interpretation of the probation statute. The Supreme Court of Iowa interpreted the word "fix" in the statute to mean that the court must establish a specific length for the term of probation, not a range. Therefore, the Supreme Court of Iowa ruled that the district court imposed an illegal sentence by setting Wade's probation period as a range of 2-5 years. The court affirmed the court of appeals decision in part, vacated it in part, and remanded the case for a new sentencing consistent with its interpretation of the probation statute. View "State v. Wade" on Justia Law

The case revolves around a dispute over the will of Richard D. Janssen, who had six children: Dean, Sheryl, Debra, Jeff, Larry, and Gary. Richard and his wife Melva owned three parcels of farmland, which they held as tenants-in-common. Over the years, they executed several "mirror image" wills, with the final one in 2014 leaving the farmland to Larry and Gary, $60,000 each to Dean, Jeff, and Debra, and nothing to Sheryl. After Melva's death in 2017, Richard, upset about the terms of his 2014 will, drafted a new will in 2018 with the help of his daughter Sheryl. This will left his one-half interest in each of the farm properties to Debra and Sheryl, and the remainder of his estate would be equally divided between Larry, Gary, Sheryl, and Debra. Richard passed away in June 2018.After Richard's 2018 will was admitted to probate, Dean, Larry, Gary, and Jeff filed a petition for will contest against Sheryl, Debra, and Security National Bank, seeking to set aside Richard’s 2018 will based on lack of testamentary capacity or undue influence exercised by their sisters. The first trial ended in a hung jury. Before the second trial, Gary and Larry sought dismissal of all claims against Debra. The second trial resulted in a verdict in favor of Larry and Gary, concluding that Sheryl had unduly influenced Richard in drafting his 2018 will and that her tortious interference caused actual damages to Larry and Gary in the amount of $480,000.After the verdict, the district court granted Sheryl’s posttrial motion to dismiss for lack of an indispensable party (Debra), ordering a new trial instead of dismissal. Larry and Gary appealed this decision, arguing that Debra's dismissal did not entitle Sheryl to a new trial where section 633.312’s joinder requirement was satisfied.The Supreme Court of Iowa reversed the district court's decision, holding that when a party, once joined and actively participating in a will contest, affirmatively agrees to be dismissed from the lawsuit without objection from any other party, section 633.312 has been satisfied and does not prevent their dismissal. The court remanded the case for the district court to address any unresolved issues in the pending posttrial motions and for further proceedings consistent with this opinion. View "Janssen v. The Security National Bank of Sioux City" on Justia Law

The case revolves around Lasondra Johnson, who was charged with first-degree murder following a series of events that led to her shooting and killing Jada YoungMills. Johnson claimed she acted in self-defense, invoking Iowa's "stand your ground" law, which negates the requirement to retreat before using force if one is lawfully present and not engaged in illegal activity. The jury acquitted Johnson of first-degree murder but found her guilty of the lesser charge of assault causing serious injury. Johnson appealed, arguing that the district court incorrectly instructed the jury on the stand-your-ground defense and a related instruction on the presumed reasonableness of using deadly force.The Iowa Court of Appeals affirmed Johnson's conviction but reversed the restitution order. Johnson sought further review, arguing that the jury instructions were misleading and confusing because there was no evidence to support an instruction to the jury that she was engaged in a separate illegal activity—assault—at the time of the shooting. She also argued that the district court imposed an unconstitutional restitution award against her and erred in relying on improper considerations and by applying a fixed sentencing policy.The Supreme Court of Iowa found that the jury instructions were indeed misleading and confusing. The court noted that the instructions allowed the jury to consider the shooting itself as an assault, which would defeat Johnson's justification defense. This interpretation would effectively nullify the stand-your-ground statute, as every use of deadly force could be considered an assault. The court concluded that the jury instructions failed to convey the law in such a way that the jury had a clear understanding of Johnson's justification defense. As a result, the court reversed Johnson's conviction, vacated the sentence, and remanded the case for a new trial. View "State v. Johnson" on Justia Law

The case involves Amy Lois Rasmussen, who was charged with two counts of assault causing bodily injury and one count of simple assault following a confrontation with three women outside Boone City Hall. The confrontation turned physical, resulting in injuries to all three women. Rasmussen entered an Alford guilty plea to the two counts of assault causing bodily injury, and in exchange, the State dismissed a related simple misdemeanor charge involving the third victim. The district court rejected both parties’ sentencing recommendations and sentenced Rasmussen to consecutive one-year sentences for each count. It also issued no-contact orders prohibiting Rasmussen's contact with the two victims of assault causing bodily injury and the victim in the dismissed simple misdemeanor case.The case was initially reviewed by the Iowa Court of Appeals, which affirmed Rasmussen's sentence and the no-contact orders. Rasmussen appealed, arguing that the district court considered improper factors in determining her sentence and lacked jurisdiction to issue a no-contact order regarding the victim in the dismissed simple misdemeanor case.The Supreme Court of Iowa affirmed Rasmussen's conviction and sentence concerning the consecutive one-year sentences and the no-contact orders involving the two victims of assault causing bodily injury. However, it found that the no-contact order in the dismissed case was void. The court held that the district court lacked jurisdiction to enter a no-contact order after it dismissed the charge related to the third victim. The court remanded the issue to the district court for a hearing solely on whether a no-contact order involving the third victim should be entered in the serious misdemeanor case. View "State of Iowa v. Rasmussen" on Justia Law

The case revolves around a medical malpractice claim filed by Darrin P. Miller against Catholic Health Initiatives-Iowa, Corp. and several medical professionals. The claim arose from the death of Miller's wife, Meredith, who died after a car accident when an endotracheal tube was incorrectly placed in her esophagus instead of her trachea. Miller alleged that the medical providers breached the standard of care by incorrectly performing the intubation and failing to identify and correct the error.The defendants sought dismissal of the case on two grounds: the expert's certificate of merit was not signed under oath as required by Iowa Code section 147.140, and the expert, an anesthesiologist, was not qualified to testify against the defendant surgeons or respiratory therapist. The district court denied the defendants' motions, ruling that the expert's unsworn but signed letter substantially complied with the affidavit requirement and that the expert's qualifications satisfied section 147.139.The Supreme Court of Iowa reversed the district court's decision. The court held that the expert's signed but unsworn report did not substantially comply with section 147.140's affidavit requirement, and this violation was not cured by the expert's sworn declaration served over three months after the statutory deadline. The court did not reach the question of whether the expert anesthesiologist was qualified under section 147.139 to testify against these defendants. The case was remanded for dismissal of the medical malpractice claims with prejudice. View "Miller v. Catholic Health Initiatives-Iowa, Corp." on Justia Law