Justia Iowa Supreme Court Opinion Summaries

After their leases expired, three tenants, on behalf of themselves and other similarly situated residential tenants, brought suit against their landlord. The district court granted summary judgment for the tenants, declaring that certain of the landlord's lease provisions violated the Iowa Uniform Residential Landlord and Tenant Act. The court also certified a class of tenants. The landlord brought this interlocutory appeal. The Supreme Court affirmed in part and reversed in part, holding (1) some, but not all, of the challenged lease provisions were prohibited under the Act; and (2) the class certification was procedurally flawed in the absence of findings required under Iowa R. Civ. P. 1.263(1). The court remanded the cause for further proceedings. View "Kline v. Southgate Property Management, LLC" on Justia Law

Plaintiff, who was paralyzed in an accident during a work accident, filed a petition seeking a determination of permanent total disability (PTD) and also sought partial commutation of benefits in a lump sum. Defendant, the workers’ compensation insurer, disputed whether Plaintiff was PTD and resisted the commutation, although it continued to pay full weekly PTD benefits and explore settlement. The Iowa Workers’ Compensation Commissioner granted Plaintiff’s petition for partial commutation. Plaintiff then sued Defendant for first-party bad faith. On summary judgment, the district court determined that Defendant acted in bad faith. The jury awarded punitive and compensatory damages at a ratio of 88:1. The Supreme Court (1) reversed the judgments for compensatory and punitive damages, holding that, while Defendant knew or should have known it lacked any reasonable basis to dispute Plaintiff’s PTD status, the district court erred in ruling that Defendant was in bad faith as a matter of law for resisting the commutation; and (2) the district court properly denied Plaintiff an award of attorney fees incurred in prosecuting the bad-faith action. View "Thornton v. American Interstate Insurance Co." on Justia Law

Jeffrey Anderson challenged a district court order placing him in a transitional release program at the Civil Commitment Unit for Sexual Offenders (CCUSO) as a violation of his due process rights.After a jury determined that Anderson was a sexually violent predator, Anderson was civilly committed to CCUSO under the Sexually Violent Predators Act. Anderson was later granted release with supervision but violated the terms of his release-with-supervision plan. The district court revoked Anderson’s release-with-supervision status and ordered him placed at a transitional release program housed at CCUSO. It was this order that Anderson challenged on appeal. The Supreme Court affirmed, holding that the order revoking Anderson’s release-with-supervision status and placing him at the transitional release program at CCUSO did not violate his substantive or procedural due process rights under either the Iowa Constitution or the United States Constitution. View "In re Detention of Jeffrey Anderson" on Justia Law

The district court did not abuse its discretion by certifying this case as a class action.Plaintiffs alleged that air pollution from a corn wet milling plant interfered with the use of their property. Plaintiffs filed a complaint alleging nuisance, trespass, and negligence under common law and statute. The district court granted Plaintiffs’ motion for class certification and divided the class into two subclasses, one for members in close proximity to the plant and the other for those in peripheral proximity. The Supreme Court affirmed, holding that the district court did not abuse its discretion in certifying the class and that Defendant failed to show that the class certification order violated its due process rights. View "Freeman v. Grain Processing Corp." on Justia Law

On December 8, after a hearing, a judicial hospitalization referee entered an order finding M.W. seriously mentally impaired and ordered M.W. involuntarily hospitalized. M.W. appealed the denial of his motion to continue the hearing. On December 9, the district court entered a ruling determining that the referee did not abuse her discretion in denying M.W.’s motion to continue and noted that M.W. had the right to challenge all of the rulings of the referee at a de novo hearing before the district court. Thereafter, M.W. was released from involuntary hospitalization. The district court thus dismissed the case. M.W. appealed the December 8 referee order and the December 9 district court order. The Supreme Court dismissed the appeal, holding that neither the referee’s order issued on December 8 nor the district court’s order issued on December 9 were appealable as a matter of right. View "In re M.W." on Justia Law

The Supreme Court held that Iowa’s theft-by-taking prohibition in Iowa Code 714.1(1) is limited to situations where a person obtains property without the consent or authority of another, and therefore, a defendant does not violate the statute when he or she obtains property or services by delivering a counterfeit check or money order. Defendant was convicted of “theft by taking” after she removed money from her bank account after depositing several counterfeit checks and money orders and later endorsed a counterfeit money order to a veterinary clinic to pay for boarding services. The Court reversed Defendant’s theft-by-taking convictions, holding that Defendant’s conduct did not constitute theft by taking. View "State v. Nall" on Justia Law

Defendant appealed his first-degree murder conviction entered after a retrial. The State prosecuted Defendant on the theory that Defendant aided and abetted Louis Woolheater in the murder of Lance Morningstar and was motivated to do so because Morningstar had an affair with Defendant’s wife. During Defendant’s second trial, Defendant was precluded from presenting out-of-court statements that he argued were admissible as statements against interest. The Supreme Court reversed Defendant’s conviction and remanded the case for a new trial, holding that Defendant should have been allowed to present to the jury the challenged statements because they would have given Defendant a powerful argument that Woolheater acted to “save his own skin” rather than at the direction or encouragement of Defendant. View "State v. Huser" on Justia Law

David Steinberg and Steven Steinberg, brothers and the sole beneficiaries of the Steinberg Family Living Trust, requested a declaration of how a Minnesota farm and an Iowa farm should be distributed. The Minnesota farm, which was part of the trust, was acquired after the creation of the trust through a like-kind tax exchange of property. The exchanged property was specifically bequeathed to Steven but the acquired farm was not specifically bequeathed to either beneficiary. The district court ordered the Minnesota farm to be distributed equally between the brothers, concluding that the specific bequest was adeemed because the bequeathed parcel of land was no longer an asset of the trust and there was no exception to the doctrine of ademption for the like-kind tax exchange of property. The court also struck a provision of the trust granting Steven the option to purchase the Iowa farm from David. The Supreme Court (1) affirmed the district court’s decision to the extent the court declared the specific bequest to Steven was adeemed and concluded that the Minnesota farm was to be distributed equally between the brothers; and (2) reversed the decision to the extent it granted summary judgment to David on the disputed trust provision due to genuine issues of material fact. View "Steinberg v. Steinberg" on Justia Law

Joseph Gantner died in 2015, survived by his wife, Rachel Gantner, and two daughters, Meredith and Paige Gantner. After Joseph’s will was admitted to probate, Rachel filed for an elective share of Joseph’s estate and also requested a spousal support allowance. Meredith and Paige resisted Rachel’s application for spousal support, maintaining that several individual retirement accounts (IRAs) did not constitute part of the probate estate and, therefore, were beyond the reach of Rachel’s spousal allowance. As relevant to this appeal, Rachel was not a beneficiary of those IRAs. Rather, the executor confirmed that Meredith and Paige were their cobeneficaries. The probate court denied Rachel’s application for spousal allowance, concluding that the IRAs could not be used to pay an allowance to Rachel, who was not a beneficiary of those IRAs. Rachel appealed, arguing that she may reach the IRAs because they were “a transfer at death of a security registered in beneficiary form” under Iowa Code 633D.8. The Supreme Court affirmed, holding that chapter 633D does not apply to an IRA where one or more nonspouses are designated the beneficiaries. View "In re Estate of Joseph C. Gantner III" on Justia Law

Several Iowa chiropractors brought this class-action lawsuit against Wellmark, Inc., Iowa’s largest health insurer, alleging that it conspired with competitors to fix prices, allocate markets, and engage in other anticompetitive conduct in violation of the Iowa Competition Law. The district court stayed the case pending further proceedings in federal multidistrict litigation (MDL) in Alabama brought under federal antitrust laws. The Supreme Court vacated the order staying this action, holding that the district court abused its discretion in staying the Iowa litigation pending further proceedings in the Alabama MDL because (1) resolution of the Alabama MDL could take years, and (2) there are considerable differences in the issues the two cases present. Remanded. View "Chicoine v. Wellmark, Inc." on Justia Law