Justia Iowa Supreme Court Opinion Summaries

Iowa may constitutionally deny an inheritance tax exemption for bequests to stepchildren when the marriage between parent and stepparent was dissolved before the stepparent’s death, while granting an exemption when the marriage was not dissolved.The Supreme Court affirmed the judgment of the district court affirming the administrative ruling of the Iowa Department of Revenue denying an estate’s request for a tax refund. An administrative law judge rejected the decedent’s stepchildren’s protest challenging the denial of the tax refund on the ground that Iowa Code 450.1(1)(e)’s classification of stepchildren violated their equal protection rights under Iowa Const. art. I, 6. The district court affirmed the Department’s decision. The Supreme Court affirmed, holding that section 450.1(1)(e) does not violate article I, section 6 of the Iowa Constitution because a rational basis exists for the legislature to exclude stepchildren postdivorce from the inheritance tax exemption for surviving spouses lineal descendants, lineal ascendants, and other stepchildren. View "Tyler v. Iowa Department of Revenue" on Justia Law

The Supreme Court affirmed the judgment of the juvenile court adjudicating Child as one in need of assistance. The juvenile court specifically found that Father was imminently likely to abuse or neglect Child and that Child was immediately likely to suffer harmful effects due to Father’s failure to exercise a reasonable degree of care in supervising Child. The court of appeals reversed, concluding that Father’s physical abuse against other family members did not establish that Child was at risk of imminent harm. The Supreme Court vacated the decision of the court of appeals and affirmed the juvenile court’s judgment, holding that, given Father’s history of domestic violence, combined with his lack of participation throughout this process, the juvenile court properly adjudicated Child a child in need of assistance based on the harmful effects Child was imminently likely to suffer due to Father’s domestic violence. View "In re L.H." on Justia Law

Defendant was not entitled to an automatic new trial after the district court, over Defendant’s objection, required a standby interpreter for his jury trial.Defendant requested, and was provided, an interpreter for all of his pretrial hearings. Defendant sought to waive the interpreter for his jury trial, however. The district court nevertheless ordered a standby interpreter to sit in the gallery translating through a wireless earpiece Defendant could remove at his option. Defendant waived the jury and, after a bench trial, was convicted of selling cocaine. The Supreme Court affirmed, holding (1) Defendant had a right to waive the interpreter, but the district court did not abuse its discretion by ordering a standby interpreter over Defendant’s objection; and (2) the record was inadequate to review Defendant’s claim that his counsel was ineffective in waiving the jury. View "State v. Garcia" on Justia Law

A “criminal case” as used in Iowa’s recently enacted expungement law, Iowa Code 901C.2, refers to a single numbered legal proceeding.In 2011, Defendant was charged with several aggravated misdemeanors in a single trial information. At the same time, he was separately charged by criminal complaint with a single misdemeanor. Defendant pleaded guilty to a lesser included offense of one count of the trial information, and all other charges, including the simple misdemeanor criminal complaint, were dismissed. In 2016, Defendant sought expungement of the record of the dismissed simple misdemeanor complaint. The magistrate and district court denied relief, concluding that the misdemeanor and the offense to which Defendant had pled guilty in the trial information comprised a single criminal case within the meaning of section 901C.2(1)(a)(1) because they were factually related. The Supreme Court reversed the district court’s judgment denying expungement, holding that Defendant was entitled to expungement of the record of the dismissed simple misdemeanor complaint. View "State v. Clemens" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment on Plaintiff’s malicious prosecution claim on the ground that Defendants did not instigate Plaintiff’s criminal prosecution.Linda Linn and Mark Shuck (together, Plaintiffs) brought suit against Defendants claiming defamation and malicious prosecution. The district court granted summary judgment and partial summary judgment on the defamation claim based on the running of the statute of limitations and granted summary judgment on the malicious prosecution claim. Shuck appealed. The Supreme Court held (1) due to an answer to a special interrogatory by the jury, the court will not reach the statute of limitations arguments made by Shuck on the defamation claim; and (2) the district court did not err in granting summary judgment on the malicious prosecution claim where Defendants merely furnished information to law enforcement. View "Linn v. Montgomery" on Justia Law

A hearing conducted by the district court to determine if a juvenile offender should be sentenced to a minimum term of incarceration without eligibility for parole did not, in this case, comply with constitutional safeguards.The district court concluded that the juvenile in this case should serve the statutory mandatory minimum term of incarceration before becoming eligible for parole. The court of appeals affirmed. The Supreme Court reversed, holding that the district court abused its discretion in its application of the sentencing factors because critical conclusions drawn by the court at the sentencing hearing were not grounded in science but rather based on generalized attitudes of criminal behavior that may or may not be correct as applied to juveniles. The court remanded the case for resentencing in light of State v. Roby, 897 N.W.2d, 127 (Iowa 2017). View "State v. White" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment to Defendants in this case brought by an independent contractor who sued for damages when he purchased a used tractor from a John Deere implement dealer that proved to be a “lemon.” The contractor brought suit against several parties, including the implement dealer. The court of appeals affirmed the judgment of the district court in all respects but reversed the district court’s grant of summary judgment on the contractor’s express warranty claim against the implement dealer. The Supreme Court vacated in part the decision of the court of appeals, holding that the disclaimers contained in the purchase agreement negated any express warranties allegedly made by the implement dealer. View "Cannon v. Bodensteiner Implement Co." on Justia Law

Defendant was required to register as a sex offender under Iowa Code 692A.103(1) upon his conviction of lascivious conduct with a minor and release on bond, notwithstanding this appeal.Defendant argued that he had no obligation to register after posting an appeal bond to stay execution of the underlying criminal judgment and before he began serving any prison sentence or was placed on probation. The district court concluded that Defendant was required to register as of the date he was sentenced to prison for the sex offense and was released on the appeal bond. Defendant’s conviction was later affirmed on appeal. Now Defendant faced new criminal charges for violating chapter 692A’s sex offender residency restrictions before his conviction was affirmed. The Supreme Court affirmed the judgment of the district court, holding (1) the stay of execution on Defendant’s criminal judgment did not delay the automatic administrative registration requirement for convicted sex offenders; and (2) Defendant’s release on the appeal bond constituted a “release from incarceration” within the meaning of section 692A.103(1). View "Maxwell v. Iowa Department of Public Safety" on Justia Law

In this will contest, the district court did not abuse its discretion in denying the unsuccessful will contestant’s motion to amend the pleadings to conform to the proof at the close of his case.The contestant’s motion at issue sought to broaden the contestant’s undue influence claim to include all of the testator’s prior wills and codicils. The Supreme Court held that the last-minute amendment would have broadened the issues and the proof. In addition, this issue fell within precedent upholding denials of motions to amend under Iowa R. Civ. P. 1.457 when the motion is based on facts the movant knew or should have known before trial. As to the contestant’s other issue asking the Supreme Court to overturn a ruling on burden of proof that was incorporated within a pretrial order denying summary judgment, this issue was not preserved for review. Accordingly, the Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court. View "In re Estate of Margaret E. Workman" on Justia Law

Under the circumstances of this case, Defendant was denied procedural protections for determining his status as an habitual offender at trial, and Defendant did not need to preserve error by filing a motion in arrest of judgment.After a bench trial, Defendant was convicted of indecent exposure and sentenced as a habitual offender. Defendant also pled guilty to indecent exposure. On appeal, the State conceded that the plea colloquy was insufficient. However, contrary to Defendant’s arguments, the State argued that the stipulation relating to Defendant’s prior convictions was sufficient. The court of appeals concluded that Defendant failed to preserve error on his claim that the stipulation concerning his prior convictions was deficient and that Defendant was required to challenge the sufficiency of the proceedings either by filing a motion in arrest of judgment or by another means. The Supreme Court vacated the decision of the court of appeals and reversed the judgment and sentences of the district court, holding (1) requirements of the enhanced-penalty hearing were not followed by the district court; and (2) the error preservation rule established in State v. Harrington, 893 N.W.2d 36 (Iowa 2017) was not in existence at the time. View "State v. Steiger" on Justia Law