Justia Iowa Supreme Court Opinion Summaries

Following the death of Cletus Roth, a resident of a nursing facility operated by The Evangelical Lutheran Good Samaritan Society, Roth’s estate and his adult children filed an action against Good Samaritan, alleging, inter alia, wrongful death, negligence, and loss of consortium. After removing the case to federal court, Good Samaritan moved to compel arbitration. The federal district court directed that the claims of Roth’s estate be submitted to arbitration but asked the Supreme Court to answer two certified questions of Iowa law relating to the adult children’s loss-of-consortium claims. The Supreme Court answered (1) Iowa Code 613.15 does not require that adult children’s loss-of-parental-consortium claims be arbitrated when the deceased parent’s estate’s claims are otherwise subject to arbitration; and (2) in light of the Court’s answer to the previous question, the second question has become moot. View "Roth v. Evangelical Lutheran Good Samaritan Society" on Justia Law

The Iowa District Court for Story County issued an order appointing the local public defender of Nevada, Iowa to represent a juvenile, who had been detained. The public defender filed a motion to withdraw, citing conflicts of interest between the juvenile and other clients. After a detention hearing, the court ordered the juvenile’s transfer from detention to shelter care and then withdrew the local defender’s appointment and appointed new conflict-free counsel for the juvenile. The court subsequently taxed to the state public defender the court and travel costs related to the hearing for withdrawing from the representation of the juvenile prior to the hearing without first taking steps to secure alternative representation for the juvenile. The state public defender filed a petition for writ of certiorari in the Supreme Court, claiming that the district court acted illegally when it taxed the court and travel costs against the state public defender. The Supreme Court sustained the writ, holding that the district court exceeded its authority and made an error of law in determining that the state public defender or the local public defender violated either statutory or ethical duties under the circumstances of this case. View "State Public Defender v. Iowa District Court" on Justia Law

This case involved a dispute over a change in hauling fees paid by a dairy cooperative to an independent contractor who transported milk from farms to the cooperative’s facilities. When the co-op notified the hauler that it would be phasing out a trip fee it had been paying the hauler, the hauler objected but continued to transport milk. Thereafter, the co-op paid the agreed hauling rate without the trip fees. Several months later, the hauler sued the co-op for unpaid trip fees. The co-op, in turn, declared the contract terminated. The district court granted summary judgment for the co-op, concluding that the change in payment terms was a new offer that the hauler accepted by performance. The court of appeals reversed, concluding that summary judgment was inappropriate where questions of fact existed as to acceptance. The Supreme Court vacated the decision of the court of appeals and affirmed the district court’s summary judgment, holding that, under the parties’ oral contract, the co-op could alter payment terms prospectively upon reasonable notice, and the hauler accepted the new terms by performance, notwithstanding its protests. View "Johnson v. Associated Milk Producers, Inc." on Justia Law

Dennis Smith, a former employee of Iowa State University (ISU), sued ISU and the State of Iowa (collectively, ISU) after his position at the university was eliminated. Smith ultimately recovered $150,000 on his statutory whistleblower claim - reduced from an initial award of $784,027 - and his other claims were dismissed. The district court awarded Smith $368,607 in attorney fees, which amounted to almost all of Smith’s attorney fees incurred in this litigation and other satellite proceedings. The district court awarded the attorneys fees pursuant to Iowa’s whistleblower statute. ISU appealed, arguing that the attorney-fee award should be reduced for work not performed on the whistleblower claim and to account for an overall lack of success on that claim. The Supreme Court reversed that aspect of the district court’s judgment awarding attorney fees to Smith, holding that, given the time Smith’s counsel devoted to unrelated matters for which attorney fees were not authorized and Smith’s limited success on the statutory whistleblower claim, the district court’s attorney fee ruling was an abuse of discretion. Remanded. View "Smith v. Iowa State Univ. of Science & Tech." on Justia Law

Defendant pled guilty to carrying weapons, an aggravated misdemeanor. Defendant appealed, arguing that the sentencing judge should have sua sponte recused himself from the case based on his prior familiarity with Defendant. In the alternative, Defendant asserted that his counsel provided ineffective assistance for not requesting that the judge recuse himself. The court of appeals affirmed the judgment and sentence. The Supreme Court affirmed in part and vacated in part, holding (1) the court of appeals correctly found that the judge was not required to recuse himself; and (2) the record on appeal was inadequate to determine whether counsel was ineffective for failing to file a motion for recusal at the sentencing hearing. View "State v. Toles" on Justia Law

Kelli Jo Griffin was convicted for the crime of delivery of a controlled substance. Griffin later registered to vote and cast a provision ballot in a municipal election. The county auditor concluded that Griffin was not eligible to vote due to her felony conviction and rejected her ballot. Griffin filed a petition asking the district court to declare that her felony conviction did not disqualify her from voting under the Iowa Constitution. The district court denied relief. At issue on appeal was whether the felony crime of delivery of a controlled substance is an “infamous crime” under the voter disqualification provision of the Iowa Constitution. The Supreme Court affirmed, holding that the Constitution permits persons convicted of a felony to be disqualified from voting in Iowa until pardoned or otherwise restored to the rights of citizenship. View "Griffin v. Pate" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The court of appeals reversed, concluding (1) the State violated Appellant’s Sixth Amendment right to counsel by acquiring incriminating evidence through a jailhouse informant when Defendant was represented by counsel, and the error was not harmless; and (2) the trial court’s instructions on aiding and abetting and joint criminal conduct were not supported by substantial evidence. The Supreme Court affirmed in part and vacated in part the court of appeals’ decision and reversed in part the trial court’s judgment, holding that the trial court erred in overruling Defendant’s motion to suppress as to one of the jailhouse informants. View "State v. Marshall" on Justia Law

Defendant was detained at the police station for suspicion of drunk driving but was not yet formally charged when he made a phone call with a lawyer to get advice regarding the implied-consent procedure and his decision whether to refuse a breathalyzer test. The arresting officer was present during Defendant’s phone call, which was allowed under Iowa Code 804.20. Defendant’s lawyer did not arrive in time, and Defendant submitted to the test. Defendant was subsequently charged with operating a motor vehicle while intoxicated. Defendant filed a motion to suppress the test result, arguing that he was entitled to a private phone consultation with counsel before chemical testing was conducted. The district court denied the motion, and Defendant was convicted as charged. The Supreme Court affirmed, holding (1) the right to counsel under the Iowa and United States Constitutions does not attach until formal criminal charges are filed; and (2) Defendant’s right to counsel had not attached at the time Defendant was asked to submit to the chemical breath test, and therefore, Defendant’s constitutional right to counsel was not violated. View "State v. Senn" on Justia Law

Erika Spitz and Bradley Gentz, the parents of three minor children, were divorced in 2011. Erika and Bradley were later found in contempt for willfully violating provisions of the dissolution decree. Both Erika and Bradley were given an opportunity to avoid jail by purging their respective contempts. After a hearing, the district court ordered each party to serve time in jail, concluding that neither party had purged their contempt. Erika sought a writ of certiorari. The court of appeals rejected her arguments and annulled the writ. The Supreme Court affirmed, holding (1) Erika’s constitutional rights were not violated at the hearing when she was allowed to proceed without counsel, as she was not entitled to the right to counsel at the hearing; (2) the district court did not err in imposing a time limitation on the hearing; and (3) the district court did not err in refusing to allow the children to testify. View "Spitz v. Iowa Dist. Court for Mitchell County" on Justia Law

Plaintiffs’ daughter fatally fell over the railing of an apartment balcony. The railing complied with the local housing code when the apartment complex was built but was ten inches shorter than allowed under the current housing code. Three days before the accident, the City of Des Moines Housing Appeal Board (HAB) found the property was in violation but granted a three-month extension to install compliant railings. Plaintiffs filed a premises liability action against Landlord. The jury found Landlord sixty-five percent at fault and Plaintiffs’ daughter thirty-five percent at fault. In posttrial rulings, the district court ordered a new trial, concluding that the doctrine of negligence per se did not apply to a local housing code. The Supreme Court affirmed in part and reversed in part, holding (1) the doctrine of negligence per se applies to the violation of a municipal housing code and is not limited to statewide laws; (2) Landlord’s argument that the old code applied as a matter of law was correctly rejected; (3) the HAB’s extension of time for Landlord to comply with the code simply suspended administrative penalties without excusing tort liability; and (4) the district code erred by instructing the jury on the basis that the new code applied as a matter of law. View "Winger v. CM Holdings, LLC" on Justia Law