Justia Iowa Supreme Court Opinion Summaries

Appellant pleaded guilty to failure to appear for sentencing. Appellant filed a postconviction relief action asserting that his counsel provided ineffective assistance for several reasons. The district court denied relief. Appellant appealed, arguing that counsel was ineffective by allowing Appellant to plead guilty when a factual basis did not exist for the plea. The court of appeals concluded that it could not reach this issue on appeal because the record was insufficient to determine whether a factual basis existed at the time Appellant pleaded guilty. The Supreme Court vacated the decision of the court of appeals and affirmed the district court judgment, holding (1) a factual basis existed in the record for the court to accept Appellant’s plea; and (2) Appellant’s remaining claims were without merit. View "Yocum v. State" on Justia Law

Rosalva Ochoa was terminated from her employment with JBS Swift & Company for absenteeism. Ochoa filed two workers’ compensation petitions against Swift and its workers’ compensation carrier, alleging a cumulative left groin injury and a cumulative injury to the neck and right shoulder during the course and scope of her employment. A workers’ compensation deputy commissioner ordered Swift to pay Ochoa permanent partial disability benefits and permanent total disability benefits, but the award eliminated what would otherwise amount to overlapping partial disability benefits and total disability benefits. The workers’ compensation commissioner concluded that Ochoa’s permanent partial disability payments should not have terminated as of the date when her permanent total disability payments commenced, which resulted in Ochoa receiving more than six years of overlapping weekly benefits. The district court and court of appeals affirmed. The Supreme Court affirmed, holding that Iowa workers’ compensation law does not prohibit an employee from collecting both permanent partial disability benefits and permanent total disability benefits at the same time when the employee suffers successive injuries at the same workplace. View "JBS Swift & Co. v. Ochoa" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to theft in the first degree. The district court sentenced Defendant to a term of imprisonment and imposed fines and restitution. The sentencing order also included a provision for the forfeiture of Defendant’s pretrial bond in payment of the various financial obligations imposed as part of his sentence. Defendant moved for reconsideration and requested that he be sentenced to probation. The district court denied the motion. Defendant appealed, arguing, inter alia, that the district court lacked authority to order forfeiture of the bail. The court of appeals affirmed. The Supreme Court vacated the decision of the court of appeals with regard to the issue pertaining to the appearance bond, holding that the district court lacked the authority to forfeit bail as a term of sentencing. View "State v. Letscher" on Justia Law

Testator executed a last will and testament devising property to her adult son and daughter. After the will was executed but before Testator’s death, Son was adopted by his paternal aunt. After Testator’s death, Daughter filed this action seeking a declaratory judgment establishing that the adoption terminated Son’s ability to inherit under Mother’s will, which identified him as a beneficiary both by name and by membership in a class. The district court concluded that Son’s adoption out of his biological family did not preclude him from taking under Mother’s will. The Supreme Court affirmed, holding that the testamentary gift to Son as a named beneficiary and as a member of a class did not fail because of his adoption as an adult after Testator executed her will. View "Roll v. Newhall" on Justia Law

An inmate pled guilty to domestic abuse assault in a plea bargain that dismissed a related sex abuse charge. After the inmate arrived at a facility of the Iowa Department of Corrections (IDOC), the IDOC required the inmate to participate in a Sex Offender Treatment Program (SOTP). For the initial classification mandating SOTP, the IDOC relied on the dismissed sex abuse charge and the victim’s detailed written statement included in a police report. An administrative law judge (ALJ) upheld the determination following an evidentiary hearing based on the inmate’s admission that he assaulted his girlfriend and the victim’s statement. The district court reversed, concluding that the IDOC cannot use unproven charges to require SOTP. The Supreme Court reversed and reinstated the IDOC’s decision, holding (1) the IDOC may rely on the victim’s written statement in a police report for the initial classification requiring SOTP provided that the inmate is afforded due process; (2) the ALJ may uphold the classification based on the inmate’s testimony admitting to a sexual component to the assault along with other evidence; and (3) the inmate in this case was provided with appropriate procedural protections, and there was no other error in these proceedings. View "State v. Iowa District Court for Jones County" on Justia Law

Lumber Specialties was hired as a subcontractor on a construction project to provide the truss package and certain engineering services. Dinsdale Construction was hired to supply the labor and building materials on the project. During a visit to the site, an employee of Lumber Specialties supplied false information to the builder regarding the structural integrity of the building. The visit was done was a courtesy to the builder and for the general goodwill of the business. The structure subsequently collapsed due to inadequate temporary bracing of the trusses. Dinsdale had not followed the industry standard temporary bracing plan. Dinsdale Construction brought suit against Lumber Specialties, alleging breach of contract and negligent misrepresentation. The jury returned a verdict for Dinsdale Construction on the negligent misrepresentation claim. The court of appeals affirmed. The Supreme Court vacated the decision of the court of appeals and reversed the district court judgment, holding (1) a defendant who is not acting in its information-giving capacity does not have a duty of care under the negligent misrepresentation tort; and (2) Lumber Specialties’ employee’s statements were excluded from the imposition of duty under the tort. View "Dinsdale Construction, LLC v. Lumber Specialties, Ltd." on Justia Law

Defendant was on probation after having been convicted of drug offenses related to methamphetamine when his sister and father, concerned that he had relapsed, contacted his probation officer. Probation officers were dispatched to Defendant's residence and, with the father’s consent and without objection from Defendant, entered Defendant’s bedroom. Defendant admitted he had relapsed and used methamphetamine. The State commenced a probation revocation proceeding. Defendant filed a motion to suppress, claiming that the probation officers’ warrantless entry into his bedroom violated article I, section 8 of the Iowa Constitution. The district court denied the motion. The Supreme Court affirmed, holding that assuming, without deciding, that Defendant had a legitimate expectation of privacy in his bedroom, the probation officers’ entry was justified by the special-needs doctrine, and therefore, the entry into Defendant’s room did not violate his rights under article I, section 8 of the Iowa Constitution. View "State v. Brooks" on Justia Law

Plaintiff and Defendant were siblings who owned two farm properties as tenants in common. The first tract was located in Butler County and the second tract was located in Hardin County. In 2013, Plaintiff filed separate actions against Defendant in Butler and Hardin counties seeking partition by sale of both tracts. The actions were consolidated for trial. Defendant opposed the proposed partition by sale and urged the court to partition the tracts in kind instead. The district court ultimately ordered the sale of both tracts. The court of appeals reversed. The Supreme Court vacated the decision of the court of appeals and affirmed the district court’s judgment, holding that Defendant failed to meet her burden to prove it would be equitable and practicable to partition the tracts in kind. View "Newhall v. Roll" on Justia Law

The Department of Human Services filed a petition to terminate Father’s parental rights to his minor child. After a hearing, the district court terminated Father’s parental rights under Iowa Code 232.116(1)(e) and (f). Under section 232.116(1)(e) and (f), a child must be “removed from the physical care” of his parents for at least twelve of the last eighteen months to establish a necessary element for termination of parental rights. Father appealed, alleging, primarily, that physical custody of the child had never been “removed” from him because he at no time had actual physical custody of the child. Therefore, Father argued, the district court erred in granting termination of his parental rights under the statute. The Supreme Court reversed, holding that mere lack of physical custody is insufficient to satisfy the statutory requirement of “removal of physical custody.” View "In re Interest of C.F.-H." on Justia Law

Defendant pleaded guilty to theft in the third degree. The district court sentenced Defendant to a suspended term of imprisonment and ordered that he pay $2950 in restitution to the victim. At a hearing, the victim stated that she had an insurance policy that had a deductible in the amount of $1000 but that she had not filed a claim with her insurance company for the stolen items. Following the hearing, the district court ordered Defendant to pay $2001 in restitution. Defendant appealed, arguing that the restitution award should be limited to reflect only losses not covered by insurance. The Supreme Court affirmed, holding that the victim was entitled to seek full restitution from Defendant for damages not paid by her insurer and that the victim was under no obligation to act for Defendant’s benefit by seeking coverage for her losses. View "State v. Dubois" on Justia Law