Justia Iowa Supreme Court Opinion Summaries

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

The Iowa Individual Health Benefit Reinsurance Association (“IIHBRA”), a nonprofit corporation, sued its members (“the universities”) for unpaid assessments it was statutorily obligated to collect. The universities filed a motion to dismiss the petition, arguing that the IIHBRA lacks the capacity to sue based on the 2001 amendment to Iowa Code chapter 513C. Chapter 513C initially included a provision stating that IIHBRA had the power to “sue or be sued,” but the 2001 amendment deleted that provision. Alternatively, the universities argued that the district court lacked subject matter jurisdiction because the IIHBRA is required to arbitrate under Iowa Code 679A.19. The district court granted the motion to dismiss. The Supreme Court reversed, holding (1) the 2001 amendment to chapter 513C left intact the IIHBRA’s capacity to sue under Iowa Code chapter 504A; (2) the IIHBRA is not subject to mandatory arbitration under Iowa Code 679A.19; and (3) therefore, the IIHBRA has the capacity to sue its members in district court for unpaid assessments. View "Iowa Individual Health Benefit Reinsurance Ass’n v. Stat Univ. of Iowa" on Justia Law

R.D., now age fifty-one, was born in Iowa to parents who gave her up for adoption. The adoption records were sealed. R.D.’s adoptive family was loving and supportive, but R.D. struggles with depression, anxiety, and alcohol abuse. R.D. requested that the juvenile court open her adoption records to obtain information about her biological parents for “treatment purposes.” The juvenile court denied R.D.’s petition on the grounds that R.D.’s sole purpose was to learn the identity of her biological parents. The Supreme Court affirmed, holding that R.D. failed to meet her burden to overcome the statutory protection set forth in Iowa Code 600.16A(2)(d) for the confidentiality of the identity of biological parents. View "In re Interest of R.D." on Justia Law

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