Justia Iowa Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of forgery and falsifying a public document. Defendant filed a motion for new trial, arguing that the evidence of his efforts to avoid apprehension was improperly admitted. The court denied the motion. The court of appeals affirmed the convictions. The Supreme Court affirmed in part and vacated in part the decision of the court of appeals, holding that the court of appeals (1) did not err in affirming the district court’s admission of evidence of Defendant’s flight from law enforcement on August 11, 2011 because it was evidence of his consciousness of guilt for the charged crimes; and (2) erred in affirming the district court’s admission of evidence of Defendant’s attempt to evade detection by law enforcement on September 20, 2011 because its probative value as circumstantial evidence of his consciousness of guilt for the charged crimes was marginal at best, but the improper admission of this evidence was harmless error. View "State v. Wilson" on Justia Law

Tina Lee filed suit against the State, alleging a violation of her rights under the self-care provision of the Family Medical Leave Act (FMLA). In October 2007, the district court entered judgment in favor of Lee and awarded her money damages and attorney fees and costs. In March 2008, the district court ordered the State to pay Lee attorney fees and costs she incurred between October 2007 and February 2008. The Supreme Court reversed. On remand, the district court ordered the State to reinstate Lee and pay her lost wages and benefits from the date of the October 2007 judgment. The district court then ordered the State to pay Lee the attorney fees and costs she was entitled to in its October 2007 and March 2008 orders and to cover the attorney fees and costs Lee incurred between February 2008 and June 2014. The Supreme Court reversed, holding (1) sovereign immunity bars awards of attorney fees and costs incurred in seeking retroactive monetary relief in actions brought against state officials under Ex parte Young to remedy violations of the self-care provision of the FMLA; but (2) state sovereign immunity does not bar awards of attorney fees and costs incurred in seeking prospective relief in such actions. View "Lee v. State" on Justia Law

Defendant was approached by law enforcement officers while walking on the side of the road at 1:10 a.m. The officers asked Defendant if he would consent to a search of his person, and Defendant consented to a search. Defendant was subsequently charged with possessing methamphetamine. Defendant moved to suppress the evidence, arguing that the warrantless search violated the Federal and State Constitutions. The district court denied the motion, concluding that Defendant voluntarily consented to the search. On appeal, Defendant argued that the search violated Iowa Const. art. I, section 8, which requires police to “advise an individual of his or her right to decline to consent to a search.” The Supreme Court affirmed, holding (1) Defendant’s article I, section 8 argument was not preserved for appellate review; and (2) because the totality of the circumstances indicated that Defendant voluntarily consented to the search, the search was valid under the Fourth Amendment. View "State v. Prusha" on Justia Law

The Polk County assessor set the 2011 valuation of Wellmark, Inc.’s corporate headquarters located in Des Moines at $99 million. Wellmark protested. The Polk County Board of Review denied the protest. On appeal, the district court found the value of the property on January 1, 2011 was $78 million. At issue in this case was whether the property should have been valued as if it were a multi-tenant office building, which would likely be the result if the property were sold, or whether the property should have been valued according to its current use as a single-tenant headquarters building. The Supreme Court reversed, holding that while there had been a showing of no active market for a single-tenant office building such as the Wellmark property, value should be based on the presumed existence of a hypothetical buyer at the property’s current use. View "Wellmark, Inc. v. Polk County Bd. of Review" on Justia Law

Plaintiff sued his former criminal defense attorneys for legal malpractice, alleging that they allowed him to plead guilty to a crime that lacked a factual basis. The district court granted summary judgment in favor of the attorneys on the basis that Plaintiff could not show he was actually innocent of any offense that formed the basis for the underlying criminal case. The Supreme Court reversed, holding that a criminal defendant’s showing of actual innocence is not a prerequisite to bringing a legal malpractice against his or her former criminal defense attorney. Instead, innocence or guilt should be taken into account when determining whether the traditional elements of a legal malpractice claim have been established. Remanded. View "Barker v. Capotosto" on Justia Law

The Regional Utility Service Systems Commission (RUSS) brought a breach of contract action against the City of Mount Union. The district court entered judgment in favor of RUSS. The clerk of court subsequently issued a writ of general execution commanding the county sheriff to levy on all bank accounts held by the City at Iowa State Bank in Mount Union. The City filed a motion to quash the garnishment on the grounds that the bank account was exempt from execution under Iowa Code 627.18. The district court denied the motion to quash and claim of exemption. The Supreme Court reversed, holding that the bank account was exempt under section 627.18 because the general funds in the account were “necessary and proper for carrying out the general purpose” for which the City was organized. View "Reg’l Util. Serv. Sys. v. City of Mount Union" on Justia Law

Bank was the holder of a promissory note executed by Mortgagors and the mortgage that secured the note. After Mortgagors defaulted on the note Bank brought a foreclosure action and obtained an in rem judgment and decree of foreclosure against Mortgagors. More than two years after the entry of the original judgment, the property had not been sold, and Bank filed a notice of rescission of the foreclosure. Bank subsequently filed this foreclosure action and moved for summary judgment. Mortgagor counterclaimed for quiet title and wrongful foreclosure, arguing that she was entitled to own the property because the house was not sold within two years of the foreclosure decree. The district court granted summary judgment in favor of Bank. The Supreme Court affirmed, holding that the two-year special statute of limitations in Iowa Code 615.1(1) does not limit the period of time for a mortgagee to rescind a prior foreclosure judgment. View "U.S. Bank Nat’l Ass’n v. Callen" on Justia Law

After a trial, the district court entered judgment in this divorce case distributing the parties’ assets, ordering Husband to pay spousal support, awarding primary physical custody of the parties’ two children to Wife, and ordering Husband to pay child support. The court of appeals affirmed the property valuations and distribution in the decree, affirmed the child support determination, but modified the spousal support award. Both parties appealed. The Supreme Court affirmed in part and vacated in part the decision of the court of appeals, holding (1) the spousal support award by the district court was too low, and the spousal support award as modified by the court of appeals was too high; and (2) the court of appeals did not err in its judgment with respect to the property distribution, child support, life insurance, and appellate attorney fees. View "In re Marriage of Mauer" on Justia Law

At issue in this quiet title action was whether the two-year special statute of limitations in Iowa Code 615.1(1) applies only to judgment liens or whether the underlying debt is also extinguished after the end of the two-year period. The district court granted summary judgment in favor of Bank. The court of appeals affirmed. The Supreme Court affirmed, holding (1) in accordance with U.S. Bank Nat’l Ass’n v. Callen, the two-year special statute of limitations in section 615.1(1) does not apply to rescission; and (2) Mortgagor’s unclean hands defense to foreclosure has been waived. View "Kobal v. Wells Fargo Bank, N.A." on Justia Law

Defendant was charged with first-degree burglary, third-degree burglary, and domestic abuse. The district court found Defendant to be indigent and appointed private counsel to represent him. Defendant pled not guilty and filed an application for appointment of a private investigator at state expense. After the district court hired a hearing on the application, Defendant filed a motion requesting the portion of hearing concerning the merits of his application to be conducted ex parte. The district court denied the motion for an ex parte hearing, concluding that the State had a right to participate in the hearing on the merits of the application. The Supreme Court reversed, holding that Defendant was entitled to an ex parte hearing on the merits of his application for appointment of a private investigator at state expense. Remanded. View "State v. Dahl" on Justia Law