Justia Iowa Supreme Court Opinion Summaries

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

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