Justia Iowa Supreme Court Opinion Summaries

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

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

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