Justia Iowa Supreme Court Opinion Summaries

Sondra Irving was employed as a medical assistant at the University of Iowa Hospitals and Clinics (UIHC). She was arrested on November 28, 2013, and incarcerated through December 24, but the charges were ultimately dismissed. Irving was scheduled to resume work on December 3. At Irving’s request, her mother called UIHC every work day between December 2 and December 11 to report that Irving would be absent from work. On December 11, an employee at UIHC told Irving’s mother that she did not need to call anymore because Irving had been placed on a leave of absence. Irving’s supervisors at UIHC visited her on December 5 and told her they were doing everything they could to make sure she did not lose her job. Irving’s supervisors continued to visit on visiting days, and they told her that she had been placed on a leave of absence. After she was released, Irving attempted to return to work and was told that she was no longer employed. Irving attempted to reapply for her job and was rejected. Irving applied for unemployment insurance benefits on January 16, 2014, under the Iowa Employment Security Law. Iowa Workforce Development denied her application in a letter stating, “Our records indicate you voluntarily quit work on 12/20/13, because you were arrested and confined in jail. Your quitting was not caused by your employer.” Irving appealed the decision. The district court affirmed. Irving then sought certiorari review. The Supreme Court found that the EAB record did not support a finding of misconduct, and that there was no substantial support to show that Irving's absence from the workplace due to her incarceration was a voluntary quit. Accordingly, the Iowa Supreme Court reversed the EAB's decision and remanded for further proceedings. View "Irving v. Employment Appeal Board" on Justia Law

David Taft, Jr. was convicted in 1987 for lascivious acts with a minor. He received one two-year and two five-year sentences. The sentences were ordered to be served concurrently. Taft was discharged in 1991. He was arrested for reoffending one week later with two more children. He was convicted and served a sentence of incarceration until discharged on January 10, 2005. On March 30, 2005, district court proceedings were initiated to commit Taft as a sexually violent predator under the Commitment of Sexually Violent Predators Act, Iowa Code chapter 229A (2005). The jury found Taft suffered from a mental abnormality that made it more likely than not that he would reoffend. Taft was committed to the Civil Commitment Unit for Sexual Offenders (CCUSO). In this case, the issue presented for the Iowa Supreme Court's review was the constitutionality of statutory conditions on the suitability of a civilly committed sexually violent predator for the transitional release program. As part of an annual review, the district court denied a final hearing for discharge or suitability for placement in a transitional release program to Taft based in part on his failure to fulfill statutory criteria for a finding of suitability for a transitional release program. Taft challenged two of the criteria as violating his due process rights and denying him equal protection under the Iowa and United States Constitutions. The Supreme Court concluded the issues were not ripe for consideration under the posture of this case. Therefore the Court affirmed the district court's order. View "Taft v. District Court" on Justia Law

In 2012, seventeen-year-old appellant Isaiah Sweet shot and killed Richard and Janet Sweet. Richard and Janet had cared for Sweet since he was four years old, as his biological mother was unable to do. Richard was Sweet’s biological grandfather. Richard and Janet had been married for thirty years. Sweet was arrested three days after the murder. After being given Miranda warnings, Sweet described events leading to the murders, the details of the murders themselves, and his activities in the days after the murders. Sweet was charged and convicted on first-degree murder charges. While his maturity was debatable, the district court stressed that the crimes were premeditated. The district court felt that Sweet's proffered expert's characterization of Sweet’s possibility of rehabilitation as "mixed" was overly optimistic. Further, the district court found Sweet’s case was the rare case in which a sentence of life without the possibility of parole was warranted, as the murders were horrific and showed utter lack of humanity. The district court concluded that Sweet was currently, and will continue to be, a threat to society and that the interests of justice and community safety outweighed mitigating factors. Sweet was sentenced to life without the possibility of parole. The Supreme Court reversed and remanded for resentencing, finding that a sentence of life without the possibility of parole for a juvenile offender violated article I, section 17 of the Iowa Constitution. View "Iowa v. Sweet" on Justia Law

A federal district court certified two questions of law to the Iowa Supreme Court in a priority dispute between competing creditors of a bankrupt hog operation. Crooked Creek Corporation operated a farrow-to-finish hog facility where it bred gilts and sows and raised their litters for slaughter. After the company filed for bankruptcy, the hogs were sold, but the sale did not generate enough money to pay off competing liens asserted by two of Crooked Creek’s creditors: Oyens Feed & Supply, Inc. and Primebank. Oyens Feed held an agricultural supply dealer lien because it sold Crooked Creek feed “on credit . . . to fatten the hogs to market weight.” Primebank had a perfected article 9 security interest in the hogs to secure two promissory notes predating Oyens Feed’s section 570A.5(3) agricultural supply dealer lien in the hogs. At trial, Oyens Feed claimed it was entitled to all of the escrowed funds because its agricultural supply dealer lien had superpriority over Primebank’s earlier perfected security interest. The bankruptcy court concluded the plain meaning of section 570A.4 created a “discrete window of time,” beginning with the farmer’s purchase of feed and ending thirty-one days later, within which an agricultural supply dealer must file a financing statement to perfect its lien. The bankruptcy court concluded Oyens Feed had only perfected its lien as to amounts for feed delivered in the thirty-one days preceding the filing of each of its financing statements. In reaching its decision on the extent of Oyens Feed’s lien in the escrowed funds, the bankruptcy court reasoned the acquisition price of the hogs was zero because Crooked Creek raised hogs from birth rather than purchasing them. The court concluded “the ‘purchase price’ comprises the vast majority, if not all of, the ‘acquisition price’ for . . . purposes of Iowa Code § 570A.5(3).” The United States District Court for the Northern District of Iowa asked the Iowa Supreme Court: (1) whether, pursuant to Iowa Code section 570A.4(2), was an agricultural supply dealer required to file a new financing statement every thirty-one (31) days in order to maintain perfection of its agricultural supply dealer’s lien as to feed supplied within the preceding thirty-one (31) day period?; and (2) whether pursuant to Iowa Code section 570A.5(3), was the “acquisition price” zero when the livestock are born in the farmer’s facility? The Supreme Court answered both certified questions in the affirmative. View "Oyens Feed & Supply, Inc. v. Primebank" on Justia Law

A jury convicted Glendale More Jr. of first-degree murder in connection with the death of his girlfriend, Wauneita Townsend. He applied for postconviction relief, arguing that he was entitled to a new trial because at his trial the State introduced expert witness testimony on Compositional Bullet Lead Analysis (CBLA). According to More, recent scientific developments have discredited CBLA and that as a result of these new developments, he was entitled to a new trial. He also alleged that the use of CBLA testimony violated due process under both the State and Federal Constitutions by depriving him of a fair trial. The district court denied relief. The court of appeals affirmed. The Iowa Supreme Court granted further review and affirmed: "We certainly recognize that one of the roles of this court is to protect defendants from wrongful convictions when subsequently discovered evidence shows that an error has probably occurred. Yet after examination of the record in this case, we cannot conclude that More’s trial, though flawed, was fundamentally unfair in light of the entire record, which points in the direction of More’s guilt." View "More v. Iowa" on Justia Law

The Iowa Commission on Judicial Qualifications filed an application for discipline of a judicial officer recommending the Supreme Court publicly reprimand district court judge Mary E. Howes, Seventh Judicial District. Judge Howes petitioned for dissolution of her marriage to her husband, Jack Henderkott, in June 2011. In 2013, Henderkott sent Judge Howes an email indicating the Internal Revenue Service had deducted $3192 from his 2012 income tax return because she did not claim income she received from liquidating an individual retirement account on the couple’s 2010 joint income tax return. Henderkott claimed he was entitled to reimbursement in the full amount of the deduction per the terms of the settlement agreement. Judge Howes retained a "Ms. Pauly" to assist with her dissolution of marriage, but different counsel for the lingering tax dispute with her ex-husband. Ms. Pauly represented a different client before Judge Howes on a family law matter. Ms. Pauly's client became "distraught" upon hearing that the lawyer representing the client's husband was representing the very judge who had signed an order granting a temporary injunction in the client's case. A complaint against Judge Howes was subsequently filed. Because the Supreme Court concluded the judge violated the Iowa Code of Judicial Conduct, it granted the application for judicial discipline. Rather than publicly reprimand the judge, however, the Court publicly admonished the judge. View "In the matter of Honorable Mary E. Howes" on Justia Law

Attorney Larry Stoller filed a multicount petition on behalf of NuStar Farms, LLC against Robert and Marcia Zylstra, alleging that the Zylstras agreed to sell NuStar a parcel of farmland but failed to tender the requisite deed and that the Zylstras did not abide by certain terms contained in certain manure easement agreements. The Zylstras filed a motion seeking to disqualify Stoller as the attorney for NuStar based on a conflict of interest. Specifically, the Zylstras alleged that Stoller’s representation of NuStar was a concurrent conflict of interest with his representation of them. The district court denied the motion. The Supreme Court reversed, holding that the district court (1) did not abuse its discretion in holding that Stoller could not be disqualified under the substantial relationship test; but (2) abused its discretion in not disqualifying Stoller from representing NuStar in the action because Stoller did have a concurrent conflict of interest. View "NuStar Farms, LLC v. Zylstra" on Justia Law

Paul Gray’s surviving spouse, Brenna, and daughter, O.D.G., filed suit against Dr. Daniel Baldi and several Iowa healthcare providers, alleging that Defendants negligently treated Paul during his struggle with substance abuse. Paul’s estate asserted a claim for wrongful death, Brenna asserted a loss of spousal consortium, and O.D.G., who was born several months after Paul’s death, asserted a loss of parental consortium. The district court granted summary judgment in favor of Defendants, concluding that Plaintiffs brought suit after the applicable statutes of limitations expired. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) erred in granting summary judgment on O.D.G.’s parental consortium claim, as a child conceived but not yet born at the time of their parent’s death can bring a parental consortium claim after the child is born; but (2) did not err in granting summary judgment on the wrongful-death and spousal consortiums claims, as, even if the discovery rule can extend the time to file wrongful-death claims under Iowa Code 614.1(9)(a), the wrongful-death and spousal consortium claims were untimely under the circumstances of this case. Remanded. View "Estate of Gray v. Baldi" on Justia Law

After Tenants moved out of an apartment, Landlord withheld the rental deposit for an automatic carpet-cleaning charge, replacement of a damaged door, and monthly penalties for failure to pay for the door. Tenant sued in small claims court alleging that Landlord improperly failed to return the rental deposit. The magistrate held for Tenant on most issues and awarded damages. The district court upheld some but not all of the magistrate’s decision, concluding (1) Landlord could charge Tenant for the replacement of the exterior door; (2) Tenant was liable to Landlord for rent during two months when the premises was vacant; but (3) Landlord’s automatic deduction from the rental deposit for carpet cleaning violated the Iowa Uniform Residential Landlord and Tenant Act (IURLTA). The Supreme Court affirmed in part and reversed in part, holding (1) the district court correctly found in favor of Tenant on the issue of cleaning costs; (2) the district court erred in ruling against Tenant on the issue of liability for the door repair and on the claim for damages for failure to permit Tenants from subleasing the apartment; and (3) the district court erred in awarding punitive damages under IURLTA. View "De Stefano v. Apartments Downtown, Inc." on Justia Law

Defendant was charged with domestic abuse assault. During trial, the court admitted evidence about previous incidents during which Defendant allegedly slapped the victim, struck her, and threw her against a refrigerator, concluding that these other acts were admissible because they were probative of Defendant’s intent in committing the charged assault. The jury ultimately convicted Defendant of domestic abuse assault. The court of appeals affirmed, concluding that the district court did not err in admitting the other acts evidence. The Supreme Court affirmed, holding that the district court did not abuse its discretion in admitting the other-acts testimony under the circumstances of this case. View "State v. Richards" on Justia Law