Justia Iowa Supreme Court Opinion Summaries

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The Dyersville City Council voted to rezone the area containing the Field of Dreams movie site from agricultural to commercial in order to facilitate the development of a baseball and softball complex. Community members filed writs of certiorari, arguing (1) since the city council acted in a quasi-judicial function, the city council’s act of passing the ordinances was invalid; and (2) there was sufficient opposition to the rezoning to trigger a unanimous vote of the city council contained in the city code. The district court annulled the writs. The Supreme Court affirmed, holding (1) the city council acted in its proper legislative function when it rezoned the subject property, and both ordinances were validly passed; and (2) no procedural or substantive errors affected the city council’s rezoning decisions. View "Residential & Agricultural Advisory Committee, LLC v. Dyersville City Council" on Justia Law

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Father filed a petition seeking a permanent injunction precluding communication and contact between his minor children and their former softball coach. The district court granted a permanent injunction against the former coach that prevented him from contacting or communicating with the children but allowed him to attend certain extracurricular activities and to be present in the home of the children’s mother. The district court also ordered that the ruling granting permanent injunctive relief be sealed and not be disseminated. Father filed a motion requesting that the district court allow for the redissemination of the ruling and expand the terms of the permanent injunction. The district court denied the motion but allowed redissemination of the terms of the permanent injunction. The Supreme Court affirmed the district court’s decision with regard to the terms of the injunction and remanded for further proceedings, holding (1) because no hearing was conducted pursuant to the Iowa Open Records Act in support of the district court conclusion that the permanent injunction be sealed, the case must be remanded for a hearing regarding redissemination of the ruling granting permanent injunctive relief consistent with the requirements of the Act; and (2) the terms of the permanent injunction should not be expanded. View "In re Petition of Kent Langholz" on Justia Law

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Insured filed a complaint challenging Insurer’s termination of workers’ compensation issuance. The insurance commissioner declined to consider the merits of the complaint on the ground that the complaint raised factual issues that could not be resolved by the agency. Insurer filed a petition for judicial review seeking a declaration that the insurance commissioner should have exercised jurisdiction over the dispute. The district court granted the commissioner’s motion to dismiss, concluding that Insurer lacked standing to litigate the issues. The Supreme Court dismissed Insurer’s appeal, holding that, under the circumstances presented and applying established caselaw, the appeal was moot. View "Auto-Owners Insurance Co. v. Iowa Insurance Division" on Justia Law

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Appellee pled guilty to a crime listed in Iowa Code 902.12, which requires offenders to serve a mandatory minimum term of their sentence before being eligible for parole or work release. Appellee, who was a juvenile when he committed the offense, was sentenced to an indeterminate term of incarceration. The Iowa Department of Corrections (IDOC) classified Appellee’s sentence as category “B” and calculated his earned time accordingly. Appellee later filed a motion for correction of an illegal sentence based on State v. Lyle. The district court resentenced Appellee to an indeterminate term not to exceed ten years, without the mandatory minimum. The IDOC continued to calculate Appellee’s earned time at the rate provided for in category “B” rather than the faster rate provided for in category “A.” Appellee filed a motion to enlarge the sentencing order, arguing that the IDOC was not giving him full credit for his time served. The district court ruled that Appellee’s entire sentence was subject to the accelerated category “A” accumulation rate. The Supreme Court affirmed, holding that Breeden v. Iowa Department of Corrections, decided today, was dispositive and required that Appellant’s earned-time credit be recalculated at the category “A” rate for all his time served. View "State v. Coleman" on Justia Law

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Petitioner received a one-year driver’s license revocation and suspension for failure to submit to chemical testing. The Department of Transportation (DOT) affirmed the ALJ’s decision. Petitioner sought judicial review of the DOT’s ruling. On the thirtieth day after the DOT issued its final decision, the law firm representing Petitioner electronically submitted a petition for judicial review that was received by the Iowa Judicial Branch electronic data management system (EDMS). The next morning, the clerk’s office returned the petition because Petitioner’s address was missing from the electronic cover sheet and the filing had not been described as a “civil-administrative appeal” on that same cover sheet. The law firm resubmitted the petition after correcting the errors. Upon the motion of the DOT, however, the district court dismissed the petition as untimely because it was one day late. The Supreme Court reversed, holding that, for purposes of meeting a deadline, a filing may relate back to the original date it was received by the EDMS when the filing party demonstrates certain conditions are met. Remanded. View "Jacobs v. Iowa Department of Transportation" on Justia Law

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Appellant was convicted of attempted murder and terrorism with intent. Appellant was a juvenile when he committed the offenses. Appellant was sentenced to an indeterminate term of incarceration. A mandatory minimum sentence of five years for each offense was also imposed. Appellant received a sentence with a mandatory minimum, and the IDOC calculated Appellant’s earned-time accumulation according to Iowa Code section 903A.2(1). The IDOC classified Appellant’s sentence as category “B” and computed his earned time accordingly. After State v. Lyle was decided the district court resentenced Appellant to an indeterminate term without the mandatory minimum. The IDCO continued to calculate Appellant’s earned-time accumulation at the rate provided for under category “B” rather than the faster rate provided for under category “A.” The district court upheld the sentence. The Supreme Court reversed, holding that Breeden v. Iowa Department of Corrections, decided today, was dispositive and required that Appellant’s earned-time credit be recalculated at the category “A” rate for all his time served. View "James v. State" on Justia Law

Posted in: Criminal Law
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Shannon Breeden and Laura Hochmuth, both juveniles when their crimes were committed, were convicted of forcible felonies listed in Iowa Code 902.12. Both offenders were subject to the mandatory minimum requirement to serve at least seven-tenths of their sentences before becoming eligible for parole or work release. Each offender received a sentence with a mandatory minimum, and the Iowa Department of Corrections (IDOC) classified their sentences as category “B” for purposes of calculating earned-time credit. The Supreme Court subsequently decided State v. Lyle, which required resentencing of all offenders serving prison sentences with automatically imposed mandatory minimum terms for crimes committed as juveniles. The district court then resentenced Breeden and Hochmuth to an indeterminate term of years but without a mandatory minimum. The IDOC continued to classify the offenders’ sentences as category “B” such that their earned-time continued to accrue at a slower rate than the rate provided for under category “A.” The court of appeals reversed based on the plain language of section 903A.2(1), which provides that earned-time credit accrues at the faster rate for sentences lacking a mandatory minimum term. The Supreme Court affirmed, holding that removal of the mandatory minimum triggers the faster accrual for earned-time credit. Remanded. View "Breeden v. Iowa Department of Corrections" on Justia Law

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Defendant was charged with operating while intoxicated, third offense. Defendant filed a motion to suppress evidence obtained after a police officer pulled his patrol car into Defendant’s driveway with its emergency lights flashing, approached Defendant on foot, and directed him to step down from his front porch onto the driveway. Defendant argued that the officer’s conduct amounted to an unlawful seizure. The district court denied the motion to suppress, concluding that no seizure occurred. The court of appeals affirmed. The Supreme Court reversed, holding that Defendant was seized within the meaning of the Fourth Amendment when the officer directed Defendant to step off the front porch and onto the driveway. Remanded. View "State v. White" on Justia Law

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This petition for injunctive relief and writ of mandamus challenged the Governor’s item veto of appropriations intended to fund the Mount Pleasant and Clarinda Mental Health Institutes. The AFSCME Iowa Council 61 president and twenty state legislators brought suit against the Governor, alleging that the Iowa Code mandates the existence of the Mount Pleasant and Clarinda Mental Health Institutes and their continued operation. The district court granted summary judgment to the Governor and dismissed the petition. The Supreme Court affirmed, holding (1) the appeal was timely, and the issue of the Governor’s veto was not moot; and (2) the Governor’s exercise of his item veto of appropriations for the mental health institutes at issue did not exceed the scope of his constitutional authority. View "Homan v. Branstad" on Justia Law

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Iowa Arboretum, Inc. and Iowa 4-H Foundation entered into a ninety-nine-year lease agreement for a tract of land owned by the Foundation. The majority of the land is used by the Arboretum as an arboretum. The Foundation served the Arboretum with a notice of termination of tenancy, asserting that the land is agricultural for purposes of Iowa Const. art. I, 24, and that the lease violates the constitutional proscription on agricultural leases exceeding a term of twenty years. In response, the Arboretum filed a petition for declaratory judgment and injunctive relief to establish the validity of the lease. The district court granted declaratory relief to the Arboretum and declared the lease valid, determining that the subject land was not agricultural. The Supreme Court affirmed, holding that the land at issue is not agricultural land for purses of Iowa Const. art. I, 24, and therefore, the lease is valid and enforceable. View "Iowa Arboretum, Inc. v. Iowa 4-H Foundation" on Justia Law