Iowa Supreme Court Decisions 2018

Justia Opinion Summary: The Supreme Court vacated the decision of the court of appeals reversing Defendant’s sentence and affirmed the judgment of the district court, holding that Defendant failed to preserve error on his due process claim and…

Justia Opinion Summary: The Supreme Court vacated the decision of the court of appeals finding that there is no legislative authority supporting the use of the Iowa Risk Revised risk assessment tool (IRR) at sentencing and affirmed the decision…

Justia Opinion Summary: The Supreme Court affirmed the judgment of the district court sentencing Defendant to prison for a maximum of ten years for theft in the first degree, to be served consecutively with five years for theft in the second…

Justia Opinion Summary: The Supreme Court upheld the Iowa Department of Revenue’s sales tax assessment on labor installing building components sold by Lowe’s Home Centers, LLC, except as to those transactions in which the predominant service or…

Justia Opinion Summary: The Supreme Court affirmed the decision of the district court ordering Defendant to pay restitution to the City of Davenport for damage to patrol vehicles after Defendant pleaded guilty to criminal mischief and eluding…

Justia Opinion Summary: The Supreme Court affirmed the judgment of the district court affirming the position of the Iowa Department of Human Services (DHS) determining that transfers made by Petitioners, nursing home residents, to a pooled…

Justia Opinion Summary: The Supreme Court reversed the decision of the juvenile court permitting Mother to participate from prison by telephone in a hearing to terminate parental rights, but only to give testimony, holding that an incarcerated…

Justia Opinion Summary: The Supreme Court affirmed the decision of the district court denying Appellant’s application for postconviction relief (PCR), holding that Appellant’s requested remand for a new hearing was not available and that…

Justia Opinion Summary: The Supreme Court reversed a $1900 fine-based restitution award ordered by the district court after Defendant pleaded guilty to theft of a student backpack as punitive and unsupported by substantial evidence, holding…

Justia Opinion Summary: The Supreme Court reversed the judgment of the district court affirming the decision of the workers’ compensation commissioner declining to award benefits to a fast-food employee who suffered serious head injuries when…

Justia Opinion Summary: The Supreme Court reversed in part the decision of the court of appeals denying Defendant’s ineffective assistance of counsel claim on appeal, holding that the court erred in finding that Defendant waived his ineffective…

Justia Opinion Summary: The Supreme Court affirmed in part and reversed in part the judgment of the district court dismissing Plaintiff’s unjust enrichment, quantum meruit, and promissory estoppel claims, holding that the district court erred…

Justia Opinion Summary: The Supreme Court reversed Defendant’s convictions for assault causing bodily injury and child endangerment and remanded for a new trial, holding that the jury instructions were prejudicially erroneous. On appeal,…

Justia Opinion Summary: The Supreme Court vacated Richard Eugene Noll’s sentence as a habitual offender for operating while intoxicated (OWI), third offense, holding that the habitual offender provisions in Iowa Code 902.8 and 902.9 do not…

Justia Opinion Summary: The Supreme Court reversed the decision of the district court denying Defendant’s motion to suppress evidence resulting from a stop by an Iowa Department of Transportation (IDOT) Motor Vehicle Enforcement (MVE) officer,…

Justia Opinion Summary: The Supreme Court held tha before May 11, 2017, Iowa Department of Transportation (IDOT) Motor Vehicle Enforcement (MVE) officers lacked authority to stop vehicles and issue speeding tickets or other traffic citations…

Justia Opinion Summary: The Supreme Court reversed the judgment of the trial court convicting Defendant of operating while intoxicated (OWI), holding that the stop of the van in which Defendant was a passenger violated Iowa Const. art. I,…

Justia Opinion Summary: The Supreme Court affirmed the judgment of the district court affirming the decision of the Iowa Department of Inspections and Appeals denying the petition filed by a manufacturer and seller of electronic game devices…

Justia Opinion Summary: Mathahs has practiced law in Iowa since 2001. In October 2001, he contracted with the Iowa State Public Defender (SPD) to provide legal services to indigent adults and juveniles in certain Iowa counties. The contract was…

Justia Opinion Summary: The Supreme Court affirmed the judgment of the district court and the decision of the court of appeals concluding that Appellant violated the ordinance established by City of Cedar Rapids regarding the operation of an…

Justia Opinion Summary: The Supreme Court affirmed in part and reversed in part the judgment of the district court granting summary judgment in favor of Defendants on Plaintiffs’ class-action petition claiming that an automated traffic…

Justia Opinion Summary: In this case challenging an automated traffic enforcement (ATE) program implemented by the City of Des Moines and its private contractor, Gatso USA, Inc., the Supreme Court reversed in part and affirmed in part the…

Justia Opinion Summary: The Supreme Court held that a premarital agreement provision waiving an award of attorney fees related to issues of child or spousal support is categorically prohibited by Iowa Code 596.5(2), and Iowa Code 596.5(1)(g)…

Justia Opinion Summary: The Supreme Court adopted a tighter legal framework for warrantless inventory searches and seizures of automobiles under Iowa Const. art. I, 8 than provided under the recent precedents of the United States Supreme…

Justia Opinion Summary: At issue was whether the three-year statute of limitations in Iowa Code 822.3 applies where a postconviction relief (PCR) petitioner files an untimely second petition for PCR alleging that counsel for his timely filed…

Justia Opinion Summary: The conduct of an attorney who was removed by order of the district court from his elected position as Van Buren County Attorney, while deserving of disapproval, did not rise to the level of misconduct that would warrant…

Justia Opinion Summary: The Supreme Court held that Division I of Senate File 471 (the Act), which creates new prerequisites for physicians performing an abortion, violates both the due process and equal protection clauses of the Iowa…

Justia Opinion Summary: The Supreme Court answered a question asked by the federal district court as to whether a defendant can raise a defense of qualified immunity to an individual’s claim for damages in violation of Iowa Const. art. I, 1 and…

Justia Opinion Summary: Defendant was entitled to a new trial after the State limited his access to his personal funds by freezing his assets prior to trial. Defendant was convicted of attempted murder and willful injury causing serious…

Justia Opinion Summary: The Supreme Court reversed and remanded the case to the district court for further proceedings, holding that because the district court did not make specific findings of fact relative to any plaintiff when concluding…

Justia Opinion Summary: At issue was whether property owners’ state-law damage claims against the railroad bridge owners alleging that the design and operation of the railroad bridges resulted in flood damage to other properties were preempted…

Justia Opinion Summary: Plaintiff could not prove the City discriminated against him because of his multiple sclerosis (MS) when the City was unaware he had MS. Plaintiff applied for a full-time job as a firefighter with the City of Marion.…

Justia Opinion Summary: Under the Iowa Constitution, a community caretaking seizure of a vehicle must be undertaken for genuine community caretaking purposes. In this case, a law enforcement officer was justified under the “community caretaking…

Justia Opinion Summary: The Supreme Court declined to hold that the felony-murder rule violates due process under the Iowa or United States Constitution when it is applied to juvenile offenders pursuant to a theory of aiding and…

Justia Opinion Summary: In this medical malpractice action, the Supreme Court affirmed in part and reversed and remanded in part the judgment of the district court removing Plaintiffs’ informed consent claims from this case and entering…

Justia Opinion Summary: The Supreme Court affirmed the decision of the court of appeals finding substantial evidence that the juvenile in this case committed a sex offense by force and that the sex offender registry requirements imposed upon…

Justia Opinion Summary: Retaliatory discharge claims are not categorically reserved for at-will employees. A state administrative law judge (ALJ) brought suit alleging wrongful termination in violation of public policy after she was terminated…

Justia Opinion Summary: The equitable tolling doctrines of the discovery rule and equitable estoppel are available with respect to the 300-day filing limitation in the Iowa Civil Rights Act (ICRA). Plaintiff, an applicant for the position of…

Justia Opinion Summary: The Supreme Court affirmed in part and reversed in part the judgment of the district court granting summary judgment in favor of Defendants on Plaintiff’s claims challenging his termination. Plaintiff, a former chief…

Justia Opinion Summary: The Supreme Court affirmed the decision of the district court affirmed the decision of the workers’ compensation commissioner that Claimant was not entitled to healing period benefits under Iowa Code 85.34(1). Claimant…

Justia Opinion Summary: The district court correctly granted summary judgment in favor Humboldt County on Plaintiff’s claim that the county was liable for the injuries she received when her vehicle went off the county road and into a ditch then…

Justia Opinion Summary: The Supreme Court remanded this case alleging negligence and products liability for a new trial, holding that statements made by Plaintiff’s counsel during closing arguments were prejudicial. On appeal, the Supreme…

Justia Opinion Summary: The Supreme Court reversed the judgment of the district court in favor of the Board of Adjustment in this action brought of developers seeking the right to build apartments on adjoining properties they owned in Iowa City…

Justia Opinion Summary: Appraisers may determine the factual cause of damage to insured property to ascertain the amount of the loss, but coverage questions are to be resolved by the court. In the instant case, the district court rejected an…

Justia Opinion Summary: At issue was negligence and defamation claims brought by two female parishioners and their spouses against a church based on sexual abuse and exploitation perpetrated on the women by the church pastor and the subsequent…

Justia Opinion Summary: Assertion of the Fifth Amendment privilege against self-incrimination excuses compliance with forfeiture threshold pleading requirements in Iowa Code 809A.13(4)(d), such as identifying the source of cash. Claimants’…

Justia Opinion Summary: The Supreme Court reversed the district court’s decision granting postconviction relief to Defendant on his claim that he had received ineffective assistance of counsel from an immigration attorney when he tried to get a…

Justia Opinion Summary: At issue was Mother’s and Father’s parental responsibility for postsecondary education for their daughter following the dissolution of their marriage. On Mother’s motion, the district court entered an order requiring…

Justia Opinion Summary: The thirty-day period set forth in Iowa Code 414.15, which requires a petition for writ of certiorari seeking review of a decision of a city zoning board of adjustment to be filed in district court “within thirty days…

Justia Opinion Summary: The Supreme Court reversed the decision of the district court denying Employer’s motion for summary judgment on Employee’s lawsuit filed under the Iowa Civil Rights Act (ICRA) alleging that Employer discriminated against…

Justia Opinion Summary: The Supreme Court reversed the rulings of the district court in this appeal from the denial of Defendant’s application for postconviction relief and remanded for further proceedings. As part of his application,…

Justia Opinion Summary: The Supreme Court vacated the decision of the court of appeals reversing the judgment of the district court that granted summary judgment in favor of Defendants - Plaintiff’s attorney and the attorney’s law firm - in…

Justia Opinion Summary: One person’s consent to engage in a sexual encounter with another, obtained through the other actor’s fraudulent misrepresentations that he is someone else, does not constitute a valid consent to engage in the sexual…

Justia Opinion Summary: In this private action filed by Mother under Iowa Code chapter 600A, the Supreme Court concluded that Father’s parental rights to his children should not be terminated. Mother filed petitions to terminate the parental…

Justia Opinion Summary: The Supreme Court reversed the ruling of the district court denying Defendant’s motion for credit for time served based on the time he spent in the Bridges of Iowa (Bridges) program, holding that Bridges qualified as a…

Justia Opinion Summary: The Supreme Court remanded this case involving the resentencing of Defendant, who was convicted of a murder he committed as a juvenile in 1976, holding that the resentencing failed to meet the standards established in…

Justia Opinion Summary: At issue was whether the district court erred in not ordering a competency examination and in excluding evidence when Defendant’s lawyer moved midtrial for the examination of Defendant, who, among other things, stated…

Justia Opinion Summary: The Iowa Department of Transportation (IDOT) did not have the statutory authority from the legislature to promulgate administrative rules regulating automated traffic enforcement (ATE) systems located along primary…

Justia Opinion Summary: Practicing massage therapy without a license is not a serious misdemeanor, and therefore, the district court properly dismissed the forfeiture action in this case and ordered the cash returned to the…

Justia Opinion Summary: The Supreme Court affirmed the judgment of the district court summarily dismissing Appellant’s application for postconviction relief, holding that the statute of limitations did not bar Appellant’s claims but that…

Justia Opinion Summary: In this appeal, Appellant, who at age thirteen shot and killed his mother, raised challenges to Iowa’s youthful offender laws. Specifically, he argued (1) Iowa Code 232.45(7)(a) does not provide statutory authority to…

Justia Opinion Summary: The Supreme Court reversed the decision of the district court denying Appellant’s motion to dismiss the State’s petition for his civil commitment as a sexually violent predator (SVP) under Iowa Code Ch. 229A, holding…

Justia Opinion Summary: The Supreme Court reversed the decision of the district court denying Appellant’s motion to dismiss the State’s petition for his civil commitment as a sexually violent predator (SVP) under Iowa Code Ch. 229A, holding…

Justia Opinion Summary: A law enforcement officer in this case had probable cause to stop a motorist’s vehicle when it was on a county access road after hours. The district court denied the motorist’s motion to suppress the evidence and…

Justia Opinion Summary: Under Iowa Code 321.561, the State must prove as the essential elements of the offense of driving while barred as a habitual offender that the defendant operated a motor vehicle during the time period his or her license…

Justia Opinion Summary: The Supreme Court reversed the judgment of the district court granting summary judgment for Defendant, a bar, which was sued under Iowa’s dramshop statute after an alleged intoxicated person’s (AIP) vehicle struck the…

Justia Opinion Summary: At issue was whether the evidence was sufficient to support Defendant’s conviction on one count of sexual exploitation by a school employee under Iowa Code 709.15(3)(a)(1) and 709.15(5)(a) where Defendant hugged a…

Justia Opinion Summary: The Supreme Court overruled its cases holding that defendants may attack the voluntary and intelligent character of their pleas, holding that the Iowa Constitution allows freestanding claims of actual innocence, and…

Justia Opinion Summary: The Supreme Court reversed the judgment of the district court enjoining Mark Ogden from continuing his nonconforming use of his property as a mobile home park, holding that the City of Des Moines failed to prove that…

Justia Opinion Summary: The relief-required rule, which ordinarily requires proof that a criminal client had been exonerated from the underlying conviction, does not apply to a convicted criminal suing one of his defense attorneys for legal…

Justia Opinion Summary: The City of Albia was statutorily immune from a homeowner’s nuisance claim stemming from reoccurring flooding in the basement of her home due to rainwater discharge from a storm sewer located near the home. The Supreme…

Justia Opinion Summary: Iowa Code 902.1(2)(a)(1), which gives the district court the option to sentence a juvenile offender convicted of murder in the first degree to life imprisonment without the possibility of parole, is unconstitutional…

Justia Opinion Summary: A corporation does not have family members and therefore cannot qualify for the family-member exception to the employee-numerosity requirement in the Iowa Civil Rights Act (ICRA). Plaintiff worked for Defendant, a…

Justia Opinion Summary: The Supreme Court reversed Defendant’s conviction for robbery in the first degree and remanded for entry of judgment and sentencing for robbery in the second degree, holding that Defendant’s conviction for robbery in the…

Justia Opinion Summary: A premarital agreement waiver of attorney fees related to child or spousal support adversely affects the right to such support and, therefore, is unenforceable under Iowa Code 596.5(2). Here, Wife and Husband executed a…

Justia Opinion Summary: Under certain circumstances, Plaintiff’s counsel may depose defense counsel and obtain counsel’s prelawsuit work product. Plaintiff filed an administrative complaint charging Defendant, his former employer, with race…

Justia Opinion Summary: The Supreme Court reversed the district court’s dismissal of Appellant’s motion to reinstate its application for postconviction relief (PCR), which the district court dismissed for want of prosecution under Iowa R. Civ.…

Justia Opinion Summary: The court of appeals erred in ruling that a taxpayer avoided in Iowa inheritance tax through a private postmortem family settlement agreement (FSA). Here, the decedent, before his death, signed a beneficiary form…

Justia Opinion Summary: After Defendant’s initial sentence was voided for illegality, the district court resentenced Defendant to a new term of imprisonment. The district court originally suspended Defendant’s prison sentence and instead…

Justia Opinion Summary: The district court order disqualifying an attorney from representing a criminal defendant, based primarily on speculative evidence of a potential conflict, constituted “an untenable ground for the district court to…

Justia Opinion Summary: The gestational surrogacy contract in the instant case was legally enforceable in favor of the intended, biological father against a surrogate mother and her husband who were not the child’s genetic parents. Plaintiffs…

Justia Opinion Summary: The Supreme Court reversed Defendant’s conviction for operating while intoxicated (OWI), second offense, and the sentence imposed on the OWI second offense charge. Defendant was convicted of the charge after he…

Justia Opinion Summary: At issue was whether the magistrate court had subject matter jurisdiction to extend a no-contact order in a simple misdemeanor case under Iowa Code chapter 664A and whether a right to appeal exists from the extension of…

Justia Opinion Summary: At issue was whether a conceded error in the admission of evidence in this criminal case was harmless. Defendant was charged with operating while intoxicated (OWI), third offense. During trial, the district court…

Justia Opinion Summary: The Supreme Court affirmed Defendant’s conviction for failure to comply with the sex offender registry but vacated the district court sentence, which included sentencing enhancements, and remanded for further sentencing…

Justia Opinion Summary: The Supreme Court reversed Defendant’s conviction for indecent exposure due to ineffective assistance of counsel and vacated the portion of the district court’s sentence imposing a surcharge for Defendant’s stalking…

Justia Opinion Summary: The district court abused its discretion by awarding attorney fees beyond those caused by violations of Iowa R. Civ. P. 1.413 or necessary to deter similar misconduct and by relying on a letter the sanctioned party’s…

Justia Opinion Summary: The Supreme Court reversed the decision of the district court reversing the Iowa Department of Economic Development’s (IDED) decision (the 2016 action) to revoke tax credits that had previously been awarded by IDED to…

Justia Opinion Summary: The juvenile court did not err in terminating Mother’s parental rights after Mother’s three-month-old daughter was sexually abused by Father, with whom Mother had left the child knowing he was intoxicated. The juvenile…

Justia Opinion Summary: The Supreme Court reversed the order of the district court awarding Plaintiff her attorney fees and expenses. In this action alleging wrongful discharge and retaliation, the district court entered judgment in favor of…

Justia Opinion Summary: Law enforcement officers executing a search warrant violated Defendant’s rights under Iowa Const. art. I, 8 by searching her purse while she was a visitor present at the premises to be searched but where the search…