Justia Iowa Supreme Court Opinion Summaries

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

An aviation company challenged the application of a statutory immunity provision to its claim of a breach of the implied warranty of merchantability found in the Uniform Commercial Code (UCC) arising from an alleged defect in product design or manufacturing. The issue this appeal presented for the Supreme Court's review was whether the immunity provision only applied in tort cases or if it also applied to contracts. The Court held the statutory immunity only applied in products liability cases involving personal injury or property damage, not in cases based solely on economic loss. View "Des Moines Flying Service, Inc. v. Aerial Services, Inc." on Justia Law

In this appeal, the issue this case presented for the Iowa Supreme Court's review was whether an employer’s matching contributions to an employee’s 401k plan should be considered part of weekly earnings for purposes of calculating workers’ compensation weekly benefits. The Court had to also decide whether the district court erred in affirming the workers’ compensation commissioner’s decision on the amount of healing period benefits owed, the extent of permanent disability, and the penalty to be awarded. After review of the specific facts of this case, the Court concluded that an employer’s matching contributions to an employee’s 401k plan were not weekly earnings for purposes of calculating workers’ compensation weekly benefits. The Court also concluded the district court did not err in affirming the decision of the commissioner with respect to the extent of permanent disability. However, the district court erred in affirming the date when healing period benefits commenced, the date when the healing period benefits ended, and the date when permanent partial disability (PPD) benefits commenced. The case was remanded to the district court: (1) to affirm the commissioner’s findings as to the weekly benefit rate and the extent of permanent partial disability; and (2) for a redetermination of the date when healing period benefits commenced, of the date when healing period benefits ended and PPD benefits commenced, and for a recalculation of penalty and interest benefits. View "Evenson v. Winnebago Insudtries, Inc." on Justia Law

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