Justia Iowa Supreme Court Opinion Summaries

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

Appellant, a high school football player, was charged with possession of a firearm as a felon, carrying a weapon on school grounds, carrying a weapon, and possession of a controlled substance after the school superintendent searched Appellant’s school-issued equipment bag. The superintendent was moving the bag to the floor when he heard a “metallic sound.” Appellant filed a motion to suppress the evidence found in the bag. The district court denied the motion to suppress, concluding that, under New Jersey v. T.L.O., the search was justified at its inception and the scope of the search was reasonable. The Supreme Court affirmed, holding that the search fell within the general parameters of reasonableness as outlined in T.L.O. View "State v. Lindsey" on Justia Law

The Iowa Commission on Judicial Qualifications recommended that a magistrate, who maintained a website where he posted information regarding his availability to perform marriage ceremonies - for a fee - at locations other than the courthouse, be publicly reprimanded for violating the Iowa Code of Judicial Conduct. Some of the photos showed the magistrate wearing his judicial robes. Before the matter was submitted to the Supreme Court, the magistrate resigned. The Supreme Court concluded that the magistrate committed violations of Canon 1 and Iowa Code of Judicial Conduct Rules 51:1.2 and 51:1.3, holding that the code does not per se bar a judicial officer from publicizing his availability to perform marriage ceremonies but that some aspects of the advertising at issue in this case violated the code. View "In re James H. Martinek" on Justia Law

Defendant was charged with one count of driving while barred and one count of prostitution. Defendant filed a motion to dismiss, asserting that the state failed to try her case within ninety days of filing the trial information. After a hearing, the district court ruled that Defendant waived speedy trial. The trial court subsequently found Defendant guilty. Defendant appealed, arguing that the State failed to bring her to trial within the speedy trial deadline, that she did not waive her speedy trial rights, that there was not good cause for the delay, and that she timely asserted her speedy trial rights. The Supreme Court reversed, holding (1) the State did not meet its burden of showing good cause for the delay; and (2) the State did not meet its burden in showing that Defendant waived her right to a speedy trial. Remanded for dismissal of all charges. View "State v. Taylor" on Justia Law

Plaintiff’s ten-year-old child died when Plaintiff’s boyfriend drove the speedboat in which the child was riding between two danger buoys and struck a submerged dredge pipe. Plaintiff settled claims against her boyfriend, the boat manufacturer, and the entities that operated and marked the dredge. Plaintiff also sued the State, alleging that its department of natural resources was liable for the accident. The district court granted summary judgment for the State, concluding that discretionary-function immunity applied, the public-duty doctrine applied, and there was no private cause of action. The Supreme Court affirmed, holding (1) Iowa Code chapters 461A and 462A do not create an implied private right to sue; and (2) the public-duty doctrine bars Plaintiff’s common law tort claims against the State. View "Estate of McFarlin v. State" on Justia Law

Plaintiff filed a class action petition against J.C. Penney asserting that the internet retailer unlawfully charged Iowa sales tax on shipping and handling charges. J.C. Penney forwarded the tax to the Iowa Department of Revenue (IDOR) pursuant to the Iowa version of the Streamlined Sales and Use Tax Act (SSUTA). The district court granted summary judgment in favor of J.C. Penney. The Supreme Court affirmed, holding (1) the district court correctly granted J.C. Penney’s motion for summary judgment on Plaintiff’s statutory claims grounded in SSUTA, as the SSUTA does not create a private cause of action; (2) the district court did not err in granting summary judgment on Plaintiff’s claims related to the alleged unlawful payment of taxes on the ground that the remedies under Iowa Code 423.45(3) and 423.47 are exclusive remedies barring other claims for relief for wrongful payment of taxes under SSUTA; and (3) Plaintiff was not entitled to recover on her claims alleging shipping and handling misrepresentations. View "Bass v. J.C. Penney Co., Inc." on Justia Law

Developers and a general contractor of an apartment complex purchased a primary commercial general liability (CGL) insurance policy from Arch Insurance Group and an excess CGL insurance policy from National Surety Corporation (NSC). Westlake Investments, LLC, which purchased the complex, sued the insureds for construction defects. Arch defended the suit on behalf of the insureds, and the parties eventually settled. Pursuant to the settlement agreement, the insureds assigned their claims against NSC on the excess CGL policy to Westlake. Thereafter, NSC initiated this declaratory judgment action seeking a declaration that it had no obligation to pay any portion of the judgment awarded to Westlake. Westlake counterclaimed for breach of contract. The district court granted partial summary judgment in favor of Westlake, concluding that property damage resulting from defective work performed by an insured’s subcontractor may constitute an accident that qualifies as an occurrence covered by the Arch policy, and therefore, the NSC policy. After a trial, the jury returned a verdict in favor of Westlake. The Supreme Court affirmed in part and reversed in part, holding that defective workmanship by an insured’s subcontractor may constitute an occurrence under the terms of the Arch policy incorporated by reference into the NSC policy. View "Nat’l Surety Corp. v. Westlake Invs., LLC" on Justia Law

While she was a business guest at the Courtyard by Marriott, Plaintiff slipped and fell on its icy sidewalk, breaking her ankle. After a trial, the jury found Marriott ninety-eight percent at fault and awarded Plaintiff damages. The Supreme Court reversed and ordered a new trial, holding that the district court erred by (1) submitting a negligent-training theory without testimony on the standard of care for training employees on deicing or breach of that standard, and (2) instructing the jury that an icy walkway violated a private safety code governing slip-resistant construction materials. View "Alcala v. Marriott Int’l, Inc." on Justia Law

After a jury trial, Defendant was found guilty of involuntary manslaughter by commission of public offense and child endangerment resulting in death. The trial court merged the sentences for the charges under the one-homicide rule and imposed a mandatory indeterminate fifty-year sentence. The court of appeals affirmed. The Supreme Court affirmed in part and vacated in part the decision of the court of appeals, holding (1) the district court did not err in denying Defendant’s motion to suppress; but (2) trial counsel was ineffective for failing to move for a judgment of acquittal on the child endangerment conviction under the theory that Defendant used unreasonable force that resulted in bodily injuries to the victim. Remanded for a new trial. View "State v. Schlitter" on Justia Law