Justia Iowa Supreme Court Opinion Summaries

Petitioners petitioned for judicial review of a decision by the City Development Board approving the annexation of certain land. The district court affirmed. Petitioners filed a notice of appeal and a motion for extension of time to appeal, claiming that the annexation was improper. The Board filed a motion to dismiss the appeal as untimely filed. At issue before the Supreme Court was whether the time to file a notice of appeal in an electronically filed case begins on the day the notice of filing is electronically submitted or on the day the court order from which the appeal is taken has been electronically filed. The Supreme Court dismissed this appeal, holding (1) the notice of appeal from a final judgment or order of the district court must be filed within thirty days of the date the judgment or order was electronically filed, rather than the date of the notice of filing; and (2) the notice of appeal in this case was untimely filed. View "Concerned Citizens of Southeast Polk Sch. Dist. v. City Dev. Bd. of Iowa" on Justia Law

Appellant was a passenger in an out-of-state vehicle that had been pulled over for traffic violations. The state trooper decided to detain the drive and Appellant while a narcotics dog was called in. The narcotics dog alerted on the vehicle. A subsequent search of the car revealed small amounts of marijuana, $33,100 in cash, and evidence of marijuana dealing. In a criminal proceeding, Appellant was ultimately acquitted of marijuana possession. Meanwhile, in the forfeiture proceeding for the $33,100, Appellant alleged he was the owner of the $33,100. Appellant filed a motion to suppress, arguing that the money had been seized in violation of his constitutional rights. The district court denied Appellant’s motion to suppress based on res judicata from Appellant’s criminal proceeding, concluding that the denial of Appellant’s motion to suppress in his criminal case had preclusive effect in the forfeiture case. The court then ordered the money forfeited. The court of appeals affirmed. The Supreme Court reversed, holding (1) res judicata did not apply in this case because Appellant was acquitted in the criminal case; and (2) the trooper prolonged the stop in violation of the Fourth Amendment beyond what was necessary to address the observed traffic violations. Remanded. View "In re Property Seized from Robert Pardee" on Justia Law

Kevin Bryant, a salesperson at an auto dealership, was in the passenger seat of a car when Lori Parr, who was testing driving the car, made an illegal left turn, and the car was struck by a car driven by Robert Rimrodt. Bryant filed this lawsuit against Parr and Rimrodt, alleging that their negligence caused his personal injuries. The jury returned a special verdict finding Parr ninety-five percent at fault and Bryant five percent at fault. The jury initially awarded Bryant nearly $17,000 in past medical expenses but zero for pain and suffering. The parties agreed that the verdict was inconsistent, and the jury was instructed to resume deliberations to resolve the inconsistency. The jury subsequently awarded one dollar for pain and suffering but left the rest of the verdict unchanged. The court of appeals affirmed, concluding that the one dollar award remedied any inconsistency. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the district court, holding that the award of one dollar for pain and suffering was inconsistent with the award of nearly $17,000 for medical expenses incurred for the diagnosis and treatment of pain, and the inconsistency required a new trial. Remanded for a new trial on damages. View "Bryant v. Rimrodt" on Justia Law

Pursuant to a plea agreement, Defendant pled guilty to child endangerment causing bodily injury. The plea agreement recommended a deferred judgment and probation. At the sentencing hearing, however, without objection by defense counsel, the prosecutor offered into evidence two photographs of the child-victim’s injuries and then used them on cross-examination of Defendant’s witnesses. Further, without objection, both the victim’s father and a guardian ad litem (GAL) gave victim-impact statements urging incarceration. The prosecutor never overtly advocated for a tougher sentence or mentioned incarceration as an alternative to probation. The court sentenced Defendant for an indeterminate prison term of up to five years. Defendant appealed, asserting that the prosecutor breached the plea agreement during the sentencing phase. The Supreme Court vacated Defendant’s sentence and remanded for resentencing, holding (1) the prosecutor breached the plea agreement by gratuitously introducing photos not otherwise before the court and using the photos on cross-examination to signal that Defendant deserved incarceration rather than probation; and (2) the district court properly received victim-impact statements from the child-victim’s father and the GAL. View "State v. Lopez" on Justia Law

After an investigation, the Iowa Department of Natural Resources (DNR) determined that the release of sweet corn silage runoff from Appellant’s farming operation caused fish kill on the Winnebago River. The DNR submitted a restitution assessment to Appellant, which included a restitution amount of $61,794. After a contested hearing, an administrative law judge issued a proposed decision that affirmed the restitution assessment. The Natural Resource Commission affirmed. The district court reversed and struck the restitution assessment. On remand, the Commission reduced the restitution assessment to Appellant as a result of the fish kill to $5298. Appellant then applied for an award of attorney fees pursuant to Iowa Code 625.29. The district court denied the motion, finding that three exceptions to the requirement to award attorney fees applied. The court of appeals reversed, concluding that none of the exceptions found in section 625.29(1) applied to Appellant’s case to preclude an award of attorney fees and that the district court should have found Appellant was the prevailing party under the statute. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding that the State’s role in this case was primarily adjudicative, precluding an award of attorney fees. View "Brandstad v. State ex rel. Nat. Res. Comm’n" on Justia Law

Plaintiff was injured when he crashed his moped at a work site. Plaintiff sued Defendant, a contractor, alleging that his injuries were caused by the contractor’s negligence at the site. After a trial, the jury returned a verdict for Defendant, finding that Defendant was negligent but that his negligence was not the cause of Plaintiff’s damages. The court of appeals reversed and ordered a new trial, concluding that substantial evidence did not support the verdict. The Supreme Court vacated the judgment of the court of appeals and affirmed the judgment of the district court, holding (1) substantial evidence supported the jury verdict; (2) the jury’s answers to the verdict interrogatories were consistent with each other, and the jury’s verdict was consistent; (3) assuming the district court should have granted a directed verdict finding Plaintiff negligent, any such error was harmless; and (4) the district court did not abuse its discretion when it refused to grant Plaintiff’s motion for a new trial on the grounds that the verdict failed to administer substantial justice. View "Crow v. Simpson" on Justia Law

After Defendant, who had been released from custody on an unsecured appearance bond, made threatening remarks about Assistant Dubuque County Attorney Brigit Barnes, the district court revoked Defendant’s bond and set the matter for trial. Defendant subsequently filed a motion for recusal or disqualification of both Barnes individually and the entire Dubuque County Attorney’s Office. The district court granted the motion to recuse, concluding that, in light of the alleged threats Defendant made against Barnes, the county attorney’s office could not proceed with an unbiased prosecution of the allegations against Defendant. The Supreme Court reversed the disqualification order, holding that the district court’s decision was untenable because it was not supported by substantial evidence and was based on an erroneous application of the law. View "State v. Iowa Dist. Court for Dubuque County" on Justia Law

A teenage girl reported that Defendant had molested her eight years earlier. Defendant was subsequently charged with two counts of sexual abuse of a minor, indecent contact with a minor, and kidnapping with intent to commit sexual abuse. Defendant filed a motion to dismiss the kidnapping charge as time-barred under Iowa Code 802.3, the general three-year statute of limitations for felonies. The district court denied the motion to dismiss. The Supreme Court reversed the district court’s denial of Defendant’s motion to dismiss after noting that the legislature did not include kidnapping among the four exceptions to the three-year limitations provision, holding that, under the plain meaning of the statutory text, the kidnapping charge is time-barred. Remanded to proceed under the remaining charges. View "State v. Walden" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to voluntary manslaughter, attempted murder, and willful injury causing serious injury. Defendant appealed, arguing that attempted murder and willful injury convictions are both included offenses of voluntary manslaughter and, therefore, must merge with the voluntary manslaughter conviction. The court of appeals affirmed, holding that because voluntary manslaughter can be committed without a specific intent to kill, attempted murder and willful injury resulting in serious injury, which must be committed with a specific intent to kill, are not included offenses of voluntary manslaughter. The Supreme Court vacated the decision of the court of appeals and judgment of the district court, holding that, under the circumstances of this case, the voluntary manslaughter and attempted murder convictions are mutually exclusive because a defendant cannot be convicted of both an attempted homicide and a completed homicide when the convictions are based on the same acts directed against the same victim. View "State v. Ceretti" on Justia Law

Plaintiff was hired by Employer as a probationary employee for a six-month period but was terminated within the probationary period. Plaintiff filed a wrongful discharge suit against Employer. The jury returned a verdict for Employer. Plaintiff appealed, arguing that the district court submitted instructions to the jury that were legally erroneous and that the district court should have granted her motion for a new trial. The Supreme Court affirmed, holding that Plaintiff was not entitled to a new trial because, in light of the totality of the instructions, the jury was not misled or confused by the instructions. View "Rivera v. Woodward Res. Ctr." on Justia Law