Justia Iowa Supreme Court Opinion Summaries

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

At issue in this case was whether the terms of two five-year leases, which automatically self-renewed for four additional five-year terms unless the tenant unilaterally opted out of the lease, offended Iowa Const. art. I, 24. James Gansen rented land used for agricultural purposes from the Charles Gansen Trust until the trustee unsuccessfully attempted to negotiate a higher rent from James. The trustee filed a petition for declaratory action, alleging, inter alia, that the leases violated Iowa Const. art. I, 24, which provides that no lease of agricultural lands “shall be valid for a longer period than twenty years.” The district court granted summary judgment in favor of the Trust, concluding that the leases violated article I, section 24. The Supreme Court affirmed, holding (1) although prior litigation took place between the parties involving the same agricultural leases, claim preclusion did not apply to bar the Trust’s claim that the leases violated the Iowa Constitution; and (2) the leases at issue violated article I, section 24 to the extent they remained in effect after the passage of twenty years from their inception. View "Gansen v. Gansen" on Justia Law

Plaintiff filed a tort claim with the state appeal board for wrongful death, alleging that the Iowa Department of Transportation’s negligent maintenance of a highway caused her husband’s death. The appeal board took no action on the claim for more than six months. Plaintiff finally withdrew the claim and filed suit in the district court, both individually and as administrator of her deceased husband’s estate. The district court dismissed the suit, concluding that Plaintiff had failed to exhaust administrative remedies before filing suit as administrator of the estate. The Supreme Court reversed, holding that Plaintiff exhausted her administrative remedies and properly presented her claim to the appeal board. View "McFadden v. Dep’t of Transp." on Justia Law

Plaintiffs, former customers of West Bank, filed a multiple-count proposed consumer class action lawsuit against the Bank challenging one-time nonsufficient funds fees the Bank charged when Plaintiffs used their debit cards to create overdrafts in their checking account. Plaintiffs alleged usury claims and sequencing claims. The district court denied the Bank’s motions for summary judgment on the usury and sequencing claims but granted summary judgment on the Bank’s motion for summary judgment on Plaintiffs’ usury claim arising under the Iowa Ongoing Criminal Conduct Act. In a companion case issued today, the Supreme Court concluded that the district court erred in denying the Bank’s motions for summary judgment except as to the good-faith claim involving the sequencing of overdrafts. Likewise, the Court here found that the district court also erred in certifying the class action on all claims except for Plaintiffs' good-faith sequencing claim. View "Legg v. West Bank" on Justia Law

Plaintiffs, former customers of West Bank, filed a multiple-count proposed consumer class action lawsuit against the Bank challenging one-time nonsufficient funds fees the Bank charged when Plaintiffs used their debit cards to create overdrafts in their checking account. Plaintiffs alleged usury claims and sequencing claims. the Bank filed three motions for summary judgment asking the district court to dismiss all of Plaintiffs’ usury and sequencing claims. The district court denied the Bank’s motions for summary judgment on the usury and sequencing claims but granted summary judgment on the Bank’s motion for summary judgment on Plaintiffs’ usury claim arising under the Iowa Ongoing Criminal Conduct Act. The Bank filed this interlocutory appeal on the district court’s denial of its motions for summary judgment. The Supreme Court affirmed in part and reversed in part, holding that the district court erred in denying the Bank’s motions for summary judgment except as to Plaintiffs’ claim based on a potential breach of the express duty of good faith in the sequencing of postings of bank card transactions. Remanded. View "Legg v. West Bank" on Justia Law

Defendant was convicted of second-degree murder for delivering the first, nonlethal blow to the victim in a fatal beating. Defendant’s blow knocked the victim down, and then others kicked and stomped the victim to death. The Supreme Court affirmed in part and reversed in part, holding (1) substantial evidence supported the jury’s guilty verdict on theories of principal liability and accomplice liability; (2) there was not substantial evidence to support the theory of joint criminal conduct that was also submitted to the jury; and (3) because the jury returned a general verdict of guilty and there was the possibility that at least one juror found Defendant guilty only on the basis of the invalid theory of joint criminal conduct, Defendant’s conviction must be reversed. Remanded for a new trial. View "State v. Tyler" on Justia Law

A fire severely damaged a restaurant that was owned by Plaintiffs. Plaintiffs made a claim to Defendant, the insurer of the restaurant, but Defendant denied the majority of the claim. Plaintiffs filed a breach-of-contract action against Defendant to recover under the insurance policy. A jury returned a verdict for Plaintiffs in the amount of $236,902. Defendant paid this amount plus interest and costs. Three months after judgment was entered, Plaintiffs filed this action against Defendant for “bad faith,” alleging that Defendant lacked an objectively reasonable basis for denying the claim. The district court granted Defendant’s motion for summary judgment, finding that the bad-faith action was barred by claim preclusion. The court of appeals reversed. The Supreme Court vacated the judgment of the court of appeals and affirmed the district court’s grant of summary judgment to Defendant, holding that, under the circumstances of this case, the final judgment in the breach-of-contract suit barred the later tort action for bad faith. View "Villarreal v. United Fire & Cas. Co." on Justia Law

Plaintiff, who was employed as an engineer and paramedic for the City of Clinton fire department, requested light-duty assignments when she became pregnant. The fire chief denied Plaintiff’s request, determining that she was not entitled to light duty under the city administrative policy because she did not have a disabling injury that occurred on the job. When Plaintiff’s pregnancy had advanced, she took a leave of absence by using accrued vacation and sick leave time. Once she exhausted the vacation and sick leave, her leave of absence was unpaid. After Plaintiff gave birth, she brought a lawsuit against the City of Clinton and three of its employees, alleging pregnancy discrimination under Iowa Code 216.6(2) and violations of her equal protection and due process rights under the Iowa Constitution. The district court granted summary judgment in favor of Defendants. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) the Court’s test for the evaluation of pregnancy discrimination claims is hereby adapted in this opinion; and (2) the material facts of this case do not support equal protection and due process claims under the Iowa Constitution. Remanded for consideration of the statutory civil rights claim under the new standard. View "McQuistion v. City of Clinton" on Justia Law

Employee strained his back while working for Employer. Two years later, Employer notified Employee that it would no longer pay for his medical care, believing that the two-year statute of limitations for workers’ compensation benefits had expired. Employee sought benefits from the Iowa Workers’ Compensation Commission. The deputy commissioner ruled that the two-year statute of limitations in Iowa Code 85.26 barred Employee’s claim and that, even though Employee filed a workers’ compensation proceeding within thirty days after receiving the notice from Employer, the discovery rule did not apply in this case. The district court reversed. The Supreme Court affirmed, holding that the discovery rule applied under the circumstances presented in this case. View "Baker v. Bridgestone/Firestone" on Justia Law