Justia Iowa Supreme Court Opinion Summaries

Plaintiff, an agricultural supply company, was delivering its own products in a semi-trailer when the semi-trailer wrecked and spilled fertilizers and chemicals, contaminating several hundred cubic yards of soil. Plaintiff suffered a loss of almost $1 million due to the environmental remediation and for the value of the trailer and its contents. Plaintiff had been leasing the semi-tractor and its driver from another source at the time of the accident. Plaintiff, on behalf of itself and its insurer, filed suit against the lessors and their driver, alleging negligence and breach of contract. The district court granted summary judgment in favor of Defendants, concluding that the terms of the lease and Iowa Code 325B.1 barred any recovery by Plaintiff. The Supreme Court reversed, holding (1) section 325B.1 governs relations between authorized motor carriers and shippers and does not apply to the lease in this dispute because Plaintiff is a private carrier rather than a motor carrier; (2) the indemnification provisions in the lease are valid and enforceable; and (3) the anti-subrogation rule limits potential recovery in this case. View "United Suppliers, Inc. v. Hanson" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The trial court instructed the jury on both the premeditation and felony-murder alternatives of first-degree murder, with the underlying predicate felony being terrorism. In 2006, the Supreme Court decided State v. Heemstra, which was not given retroactive effect. If Heemstra had been controlling at the time of Defendant’s conviction, terrorism could not have been used as the predicate felony and the felony-murder instruction could not have been given as a theory to convict Defendant. Defendant later filed this second application for postconviction relief, arguing that his conviction should be vacated and a new trial ordered because the nonretroactive application of Heemstra violates constitutional due process, separation of powers, and equal protection guarantees. Defendant also argued for the first time on appeal that his postconviction counsel were ineffective. The Supreme Court affirmed, holding (1) the nonretroactivity of the rule set forth in Heemstra does not violate the due process, separation of powers, or equal protection clauses of the Iowa Constitution or the equal protection clause of the United States Constitution; and (2) Defendant’s postconviction counsel provided effective assistance. View "Nguyen v. State" on Justia Law

The juvenile court terminated Mother’s parental rights to two of her children, M.W. and Z.W., concluding that each of the statutory grounds advanced by the State in its petition for termination of parental rights as to the children was supported by clear and convincing evidence and that termination was in the best interest of each child. The court of appeals affirmed the termination of parental rights to M.W. but reversed the termination of parental rights as to Z.W. The State appealed. The Supreme Court affirmed in part and reversed in part, holding (1) the juvenile court order terminating parental rights to M.W. was proper; but (2) the juvenile court order terminating parental rights to Z.W. was also proper and supported by clear and convincing evidence in the record. View "In re Interest of M.W." on Justia Law

Defendant pled guilty to two counts of sexual abuse in the third degree. The district sentenced Defendant to two concurrent, indeterminate ten-year sentences. Defendant appealed, arguing that the district court applied the wrong Code section at his sentencing and that the error could not be corrected by the use of a nunc pro tunc order. The court of appeals agreed with Defendant and vacated the judgment and sentence to allow the district court to amend the judgment and sentence to reflect Defendant’s intent in entering the plea. On remand, the district court resentenced Defendant to two indeterminate ten-year sentences to be served consecutively instead of merely correcting the error in the sentencing order. The Supreme Court vacated the judgment and sentence of the district court, holding that the district court exceeded its mandate when it resentenced Defendant upon remand. Remanded. View "State v. Pearson" on Justia Law

After a jury trial, Defendant was found guilty of domestic abuse assault and domestic abuse assault causing bodily injury. Defendant appealed, arguing that the district court erred in (1) admitting hearsay statements made to police and medical personnel, and (2) failing to merge the two convictions for purposes of sentencing. The court of appeals (1) concluded that the district court erred by admitting the alleged victim’s statements to police but did not err in admitting the alleged victim’s statements made to the nurse or doctor and that Defendant was not prejudiced by the admission of the hearsay statements to police; and (2) merged the convictions and affirmed the judgment and sentence for domestic abuse assault causing bodily injury. The Supreme Court affirmed in part and vacated in part the decision of the court of appeals, holding that the trial court erred by admitting the alleged victim’s hearsay statements through the testimony of the emergency room nurse and doctor without sufficient foundation, and the error was prejudicial. View "State v. Smith" on Justia Law

Plaintiff, a former agent of the Iowa Division of Criminal Investigation brought this action alleging wrongful discharge in violation of public policy. The Supreme Court dismissed the common-law wrongful discharge claim. Plaintiff filed a motion to amend findings and conclusions under Iowa R. Civ. P. 1.904(2), which the district court denied. Plaintiff appealed. Plaintiff’s application for leave to appeal was filed more than thirty days after the district court’s order but within thirty days of the court’s denial of Plaintiff’s Rule 1.904(2) motion. The Supreme Court dismissed the appeal, holding that Plaintiff’s appeal was untimely. View "Hedlund v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of lascivious acts with a child for inappropriately touching his granddaughter’s genitals over her clothing on more than one occasion. Defendant appealed, arguing that the evidence was insufficient to support his convictions under Iowa Code 709.8 because he did not make skin-to-skin contact with his granddaughter’s genitals. The court of appeals affirmed. The Supreme Court affirmed, holding that a person can “touch the pubes or genitals of a child” within the meaning of section 709.8(1) without making skin-to-skin contact, and therefore, the evidence was sufficient to support Defendant’s convictions. View "State v. Alvarado" on Justia Law

After a jury trial, Defendant was found guilty of drug dealing, child endangerment, and possession of firearms. The trial court sentenced Defendant to 100 years in prison with a mandatory one-third minimum term. The court of appeals affirmed Defendant’s convictions and sentence. The Supreme Court affirmed in part and vacated in part the decision of the court of appeals, holding (1) the evidence was insufficient to prove Defendant’s constructive possession of firearms; (2) Defendant’s remaining convictions were supported by sufficient evidence; and (3) the court of appeals’ rejection of Defendant’s ineffective assistance of counsel claims remains intact. Remanded for resentencing without the firearm conviction and enhancement. View "State v. Reed" on Justia Law

Defendant was arrested for driving while intoxicated. Defendant was transported to a law enforcement center and placed in the booking room. Defendant telephoned an attorney, who went into the booking room to meet with Defendant. The attorney was aware that the room had audio and video monitoring but took no steps to disable them or to request another room. Defendant was subsequently charged with operating while intoxicated. Defendant filed a motion to suppress evidence obtained following the attorney-client meeting, alleging, inter alia, a failure to honor his rights under Iowa Code 804.20. The district court denied the motion to suppress. Thereafter, the jury returned a guilty verdict. The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress, holding that, under the circumstances of this case, no violation of section 804.20 occurred. View "State v. Lamoreux" on Justia Law

After a bench trial, Defendant was found guilty of going armed with a dangerous weapon concealed on or about her person. The conviction stemmed from Defendant's act of carrying a stun gun with her in her purse. The court of appeals reversed the conviction, holding that there was insufficient evidence that the stun gun was a dangerous weapon. At issue before the Supreme Court was whether there was sufficient evidence to conclude that an inoperable stun gun - or a stun gun that has not been shown to be operable - qualifies as a dangerous weapon under Iowa Code 702.7. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding that a stun gun, even if inoperable, is per se a dangerous weapon under Iowa Code 702.7. View "State v. Howse" on Justia Law