Justia Iowa Supreme Court Opinion Summaries

The juvenile court adjudicated J.C. a delinquent child after finding beyond a reasonable doubt that J.C. committed assault with intent to commit sexual abuse. The court of appeals affirmed. At issue before the Supreme Court was whether the juvenile court violated J.C.’s constitutional right to confrontation by admitting the out-of-court statements made by a four-year-old victim to a physician during a medical assessment and to a forensic interviewer. The Supreme Court affirmed, holding (1) admission of the physician’s testimony and report did not violate J.C.’s confrontation rights under either the Sixth Amendment or the Iowa Constitution; and (2) any error in admission of the forensic interviewer’s testimony was harmless beyond a reasonable doubt. View "In re J.C." on Justia Law

Mother and Father were divorced pursuant to a decree that called for the continuation of a rotating custodial framework that the parties had followed during the previous two years. The Supreme Court affirmed, concluding that that parties’ children were thriving under the joint physical care arrangement. Mother later filed a petition for modification, alleging that several changes justifying a modification of the custodial arrangement had occurred after the dissolution decree was entered. The district court denied the motion for modification, concluding that the evidence did not support a finding of a substantial change in circumstances. The Supreme Court reversed and modified the dissolution decree to allocate to Mother the primary physical care of the children, holding that a substantial change of circumstances has occurred since the dissolution decree was entered and that Mother proved she was better suited than Father to minister to the needs of the children. View "In re Marriage of Harris" on Justia Law

Mother and Father were divorced pursuant to a decree that called for the continuation of a rotating custodial framework that the parties had followed during the previous two years. The Supreme Court affirmed, concluding that that parties’ children were thriving under the joint physical care arrangement. Mother later filed a petition for modification, alleging that several changes justifying a modification of the custodial arrangement had occurred after the dissolution decree was entered. The district court denied the motion for modification, concluding that the evidence did not support a finding of a substantial change in circumstances. The Supreme Court reversed and modified the dissolution decree to allocate to Mother the primary physical care of the children, holding that a substantial change of circumstances has occurred since the dissolution decree was entered and that Mother proved she was better suited than Father to minister to the needs of the children. View "In re Marriage of Harris" on Justia Law

Defendant was charged with attempted murder, robbery, and willful injury. During jury deliberations, Defendant moved for a mistrial or, alternatively, a poll of the jurors about their possible exposure to a factually inaccurate media account of the case. The district court denied the motions, concluding that a factually inaccurate media article that appeared online during Defendant’s trial had not prejudiced Defendant. The Supreme Court affirmed, holding that the factually inaccurate article did not raise serious questions of possible prejudice, and therefore, the district court did not abuse its discretion in denying Defendant’s motion for a mistrial and alternative motion to poll the jury. View "State v. Gathercole" on Justia Law

Defendant was charged with attempted murder, robbery, and willful injury. During jury deliberations, Defendant moved for a mistrial or, alternatively, a poll of the jurors about their possible exposure to a factually inaccurate media account of the case. The district court denied the motions, concluding that a factually inaccurate media article that appeared online during Defendant’s trial had not prejudiced Defendant. The Supreme Court affirmed, holding that the factually inaccurate article did not raise serious questions of possible prejudice, and therefore, the district court did not abuse its discretion in denying Defendant’s motion for a mistrial and alternative motion to poll the jury. View "State v. Gathercole" on Justia Law

Defendants participated in an insurance fraud ring that staged car accidents in Illinois. Defendants lived in Wisconsin and Illinois and had never been to Iowa before their extradition. A Wisconsin insurance company paid Defendants’ claims through its Wisconsin bank account. Two of the insurer’s employees interviewed Defendants by phone from the insurer’s Davenport, Iowa branch office. The insurance fraud was reported to detectives at the Davenport Police Department, and all three defendants were arrested in their home states and extradited to Iowa. Defendants were charged with five criminal offenses. Defendants moved to dismiss for lack of jurisdiction. The district court granted the motions to dismiss. The Supreme Court (1) affirmed the district court’s dismissal of one charge, as the State failed to show that any defendant submitted a false written statement or certificate in Iowa; and (2) reversed the district court’s dismissal of the other criminal charges, holding that the phone calls between Defendants and the insurer’s investigators in Davenport induced payments on false insurance claims, a detrimental effect in Iowa, which constituted an element of four of the five crimes charged. View "State v. Rimmer" on Justia Law

Defendants participated in an insurance fraud ring that staged car accidents in Illinois. Defendants lived in Wisconsin and Illinois and had never been to Iowa before their extradition. A Wisconsin insurance company paid Defendants’ claims through its Wisconsin bank account. Two of the insurer’s employees interviewed Defendants by phone from the insurer’s Davenport, Iowa branch office. The insurance fraud was reported to detectives at the Davenport Police Department, and all three defendants were arrested in their home states and extradited to Iowa. Defendants were charged with five criminal offenses. Defendants moved to dismiss for lack of jurisdiction. The district court granted the motions to dismiss. The Supreme Court (1) affirmed the district court’s dismissal of one charge, as the State failed to show that any defendant submitted a false written statement or certificate in Iowa; and (2) reversed the district court’s dismissal of the other criminal charges, holding that the phone calls between Defendants and the insurer’s investigators in Davenport induced payments on false insurance claims, a detrimental effect in Iowa, which constituted an element of four of the five crimes charged. View "State v. Rimmer" on Justia Law

Plaintiffs filed a class action alleging that the fees Defendant charged for providing copies of their medical records and billing statements were excessive in violation of Iowa Code 622.10(6). Defendant filed a motion to dismiss for failure to state a claim, alleging that section 622.10(6) did not apply to it because it was not a provider under the statute. The district court denied the motion to dismiss. The Supreme Court affirmed, holding (1) an entity that acts as a provider’s agent in fulfilling records requests covered by section 622.10(6) cannot charge more for producing the requested records than the provider itself could legally charge; and (2) the well-pleaded facts in the petition indicated that Defendant acted as an agent of the providers by fulfilling the records requests on their behalf, and therefore, the district court was correct in denying Defendant’s motion to dismiss Plaintiffs’ petition. View "Young v. Healthport Technologies, Inc." on Justia Law

Plaintiffs filed a class action alleging that the fees Defendant charged for providing copies of their medical records and billing statements were excessive in violation of Iowa Code 622.10(6). Defendant filed a motion to dismiss for failure to state a claim, alleging that section 622.10(6) did not apply to it because it was not a provider under the statute. The district court denied the motion to dismiss. The Supreme Court affirmed, holding (1) an entity that acts as a provider’s agent in fulfilling records requests covered by section 622.10(6) cannot charge more for producing the requested records than the provider itself could legally charge; and (2) the well-pleaded facts in the petition indicated that Defendant acted as an agent of the providers by fulfilling the records requests on their behalf, and therefore, the district court was correct in denying Defendant’s motion to dismiss Plaintiffs’ petition. View "Young v. Healthport Technologies, Inc." on Justia Law

Former employees of Warren County sued the County and its Board of Supervisors, alleging a violation of the open meetings law contained in Iowa Code chapter 21. The district court dismissed the action, concluding that the board members’ activities did not constitute a “meeting” as defined in Iowa Code 21.2(2). The Supreme Court reversed, holding (1) the open meetings law prohibits a majority of a governmental body gathering in person through the use of agents or proxies to deliberate any matter within the scope of its policy-making duties outside the public view; and (2) the district court in this case incorrectly interpreted section 21.2(2) in applying the open meetings law. Remanded. View "Hutchison v. Shull" on Justia Law