Charles Robert Wolle

Three retirees of Deere & Company filed a class action under ERISA claiming that changes to medical benefits effective January 1, 2008, breached promises of vested lifetime benefits made through company policies, oral representations, and plan documents. After a bifurcated bench trial on liability, the court entered judgment for the defendants. The decision rested on findings that the controlling written plan documents, including the Salaried Health Plan and SPDs, unambiguously reserved to Deere the right to amend or terminate benefits, and that extrinsic evidence did not establish any contrary vested rights.

labor & employmenthealthcare

This case involves a personal injury lawsuit filed in Iowa state court arising from a collision between a pickup truck and a train. The railroad defendant removed the action to federal court, and the plaintiff moved to remand, joined by the other defendant. The court denied the motion to remand, concluding that the Federal Railroad Safety Act and associated regulations completely preempt state-law claims concerning the adequacy of warning devices at the crossing, negligent train operation, and use of audible warnings. The court retained supplemental jurisdiction over any remaining claims to permit a single trial. It followed the reasoning of a similar Eastern District of Missouri decision while noting contrary authority from the same district.

procedurefederal power

In this case, plaintiff Edmund Biggs, proceeding pro se, sued his former employer Deere & Co. and the union representing him, alleging violations of rights under Deere’s employee benefit plans, collective bargaining agreements, and Iowa workers’ compensation laws stemming from a 1987 injury and his 1990 termination. The defendants moved for summary judgment, pointing to a 1991 settlement agreement under which Biggs had received and retained workers’ compensation and disability retirement benefits. The court granted summary judgment for the defendants and dismissed the case, finding that Biggs presented no probative evidence to disavow the settlement or show underpayment, that Deere was not a fiduciary under ERISA, and that the claims lacked merit or were untimely. The ruling relied on the standards for summary judgment under Federal Rule of Civil Procedure 56 and precedents such as Celotex Corp. v. Catrett. A subsequent motion for reconsideration was also denied.

labor & employmentprocedurebusiness & regulatory

In Skarin Ex Rel. Skarin v. Woodbine Community School District, non-Christian high school choir students and their parents sued the public school district and board, alleging that the board's decision to include a performance of 'The Lord's Prayer' at graduation infringed their First Amendment rights by requiring participation or alternative activities. The court permanently enjoined the school from rehearsing or performing the piece at graduations for as long as the plaintiffs remained students. The ruling was based on the conclusion that the board's action had no secular purpose, primarily advanced Christianity, and violated the Establishment Clause under precedents such as Santa Fe Independent School District v. Doe and Lee v. Weisman, as well as the Lemon test.

religious libertycivil rights

The case involved plaintiff William Logan, a compulsive gambler and alcoholic, who sued defendant Ameristar Casino for allowing him to continue gambling and serving him alcohol despite knowledge of his addictions, citing Iowa Admin. Code § 491-5.4 on gambling treatment programs, along with claims for breach of implied covenant of good faith, misrepresentation, and loss of consortium by his wife. The court granted the casino's Fed. R. Civ. P. 12(b)(6) motion to dismiss all claims for failure to state a claim. The core reasoning was that the cited regulation does not create an implied private right of action or duty of care under Iowa law, no enforceable gambling contract existed due to heavy state regulation precluding mutuality, Logan failed to allege any false material representation, and thus the consortium claim also failed.

torts & liabilitybusiness & regulatory

In this case, plaintiff Don Sutter filed a class-action lawsuit in Iowa state court against defendant Aventis CropScience, alleging that its StarLink genetically engineered corn seed damaged the U.S. corn export market and caused economic losses to non-StarLink corn growers, seeking actual and punitive damages plus injunctive relief. Aventis removed the action to federal court under diversity jurisdiction, prompting Sutter's motion to remand on grounds that the amount in controversy per class member fell below the $75,000 threshold. The court denied the motion to remand, holding that the jurisdictional amount was satisfied when punitive damages and the value of injunctive relief were included in the calculation. The court reasoned that, although the complaint alleged damages under $75,000, the pleaded facts and comparable cases demonstrated to a legal certainty or by a preponderance of the evidence that the total relief sought exceeded the requirement, precluding remand.

proceduretorts & liabilitybusiness & regulatory

Jack Holbrook sued the Internal Revenue Service under the Freedom of Information Act seeking portions of handwritten notes and a follow-up memorandum from an interview conducted by an IRS special agent during a criminal tax investigation. The IRS withheld some information, claiming exemptions under FOIA provisions tied to 26 U.S.C. § 6103 because release would impair federal tax administration or interfere with enforcement proceedings. After a bench trial, the court credited the IRS disclosure officer's testimony that she and the agent had reviewed the documents line by line, applied the proper standards, and released additional material once the field investigation ended. The court concluded the IRS had carried its burden to prove the exemptions and entered judgment for the defendant.

federal powerproceduretaxescriminal law

This case is a trademark dispute in which plaintiff First Bank, an Iowa-chartered bank operating in West Des Moines, sought a permanent injunction to bar defendants First Bank System, Inc. and its subsidiary from using the names “First Bank” or “First Bank Iowa” at branch offices in Polk, Dallas, and Warren counties. Following a bench trial, the court denied the injunction. The court found that plaintiff had not established all required elements for injunctive relief under common-law trademark principles, noting some evidence of confusion that remained manageable and had not been fully tested in the marketplace. Equitable considerations also weighed against relief because plaintiff had deliberately adopted its name in late 1993 knowing defendants were expanding into the area and held prior rights in similar marks.

business & regulatory

The case concerned a plaintiff's motion to remand her lawsuit against Amoco Oil Co. to Iowa state court, where she alleged employment discrimination and wrongful discharge seeking compensatory damages, punitive damages, attorney fees, and other relief but without specifying a dollar amount as required by state procedural rules. The defendant had removed the action to federal court under diversity jurisdiction, asserting that the amount in controversy exceeded $50,000. The court denied the motion to remand, concluding that the defendant met its burden to show by a preponderance of the evidence that the jurisdictional amount was satisfied, based on the potential size of punitive damages against a large company combined with claims for lost wages and mental anguish. The court further reasoned that events after removal, such as the defendant's denial of a request to admit the damages exceeded $50,000, could not divest jurisdiction that attached at the time of removal.

procedurelabor & employmentcivil rights

In this case, Steven Sommers, acquitted after a lengthy criminal trial on charges including distribution of precursor chemicals for methamphetamine, money laundering, and criminal forfeiture, sought to recover costs such as photocopying and witness fees from the government under 28 U.S.C. § 1920. The court denied the application, holding that sovereign immunity bars the assessment of costs against the United States in criminal cases absent an explicit statutory waiver. The court reasoned that the Equal Access to Justice Act, which allows costs in civil actions including civil forfeitures, does not extend to criminal proceedings, and no other statute provides the necessary waiver.

criminal lawprocedure

The case involved plaintiffs who filed a personal injury lawsuit in Iowa state court asserting state-law claims of negligence, strict liability, and implied warranty against the defendants. After plaintiffs moved to amend their petition to add a federal claim under the Federal Hazardous Substance Act, defendants removed the action to federal court more than thirty days later, following the state court's grant of the amendment. The court decided that the removal was untimely under 28 U.S.C. § 1446(b) and remanded the case to state court. It reasoned that the thirty-day removal clock began when defendants received the motion to amend, which first alerted them to the federal basis for removal, rather than when the amendment was granted.

procedure

Plaintiff Jerry Wayne Kleiss, an Iowa prison inmate, sued multiple law enforcement officers under 42 U.S.C. § 1983 and Iowa common law for abuse of process, alleging that officers conducted searches, issued an overbroad news release without factual basis, and brought charges in several counties in retaliation for his refusal to cooperate. The court dismissed the section 1983 claim as frivolous under 28 U.S.C. § 1915(d), holding that the plaintiff alleged no constitutional injury because malicious prosecution or abuse of process by itself does not violate federal rights and there is no right to have crimes remain undiscovered. The court declined to exercise supplemental jurisdiction over the state-law abuse of process claim under 28 U.S.C. § 1367(c)(3) and dismissed the entire action.

criminal lawcivil rightsproceduretorts & liability

This case concerned plaintiffs' motion to reopen a diversity action seeking contribution from defendants for a settlement paid in connection with a 1979 fatal sailboat accident involving alleged defects in the boat's mast. The court denied the motion to reopen the case, which had been voluntarily dismissed without prejudice in 1988 after being filed in 1987. The court concluded that Iowa Code section 668.6(3)(b) imposed a one-year limitations period on contribution actions under the comparative fault statute, that this period applied to both negligence and strict liability claims, and that the period had expired because the tolling effect of section 668.8 ended upon the prior dismissal. The court further held that defendants had not waived the limitations defense and that a pre-statute decision like Speck v. Unit Handling Div. did not exempt the claims from chapter 668.

proceduretorts & liability

The case concerns whether a personal injury lawsuit filed in Iowa state court satisfied the amount-in-controversy requirement for removal to federal court on diversity grounds. Plaintiff alleged serious injuries and various categories of damages but did not specify a dollar amount, stating only that it exceeded small-claims jurisdiction; defendant removed the action asserting that the claim exceeded $50,000. Plaintiff moved to remand, contending he did not yet know whether damages would meet that threshold. The court denied remand, holding that defendant had satisfied its initial burden by pointing to the pleaded elements of the claim and that plaintiff, who was in the best position to clarify the amount, had not shown the claim was for $50,000 or less.

procedurefederal power

This case involved Iowa farmers who sued their insurer after their combine harvester suffered damage when its final drive broke, loosening a tire and leaving the machine partially resting on it. The plaintiffs sought coverage under a Farm Master Policy for what they described as a collision or upset/overturn, or alternatively under the doctrine of reasonable expectations. The court granted the insurer's motion for summary judgment, finding no genuine issues of material fact. It held that the incident was a mechanical breakdown excluded from coverage, that the policy language did not extend to a single vehicle damaging itself, and that no circumstances supported a reasonable expectation of coverage.

business & regulatorypropertyprocedure

In Nassif v. National Presto Industries, Inc., a diabetic plaintiff with known reduced heat sensitivity sued the manufacturer of a quartz space heater after falling asleep and sustaining severe burns to his foot, alleging negligence and product defect for failing to warn of burn risks (including special warnings for sensory loss) and for providing inadequate or misleading instructions. The court granted the defendant's motion for summary judgment, answering no to whether the manufacturer acted negligently or produced a defective product by not warning of burns, whether a special duty existed for users with sensory deficits, and whether the instructions were inadequate or misleading. The core reasoning was that the danger of burns from the heater's radiant heat was open and obvious to ordinary users, who would feel the heat and withdraw before injury (unlike the plaintiff's condition), the instructions did not mislead about safe use, and the plaintiff's expert testimony failed to show any subtle hazard or defect under Restatement (Second) of Torts § 402A.

torts & liabilityprocedure

The case concerned the timeliness of a defendant's notice of removal from Iowa state court to federal court under 28 U.S.C. § 1446(b) in a diversity action where the initial pleading did not specify damages. The court remanded the case to the Iowa District Court for Story County, holding that removal was untimely. It reasoned that a pre-suit demand letter estimating damages at $40,000 qualified as an "other paper" that put the defendant on notice of the jurisdictional amount when the suit was filed in December 1988, starting the 30-day removal clock then rather than upon later receipt of interrogatory answers in 1989.

procedure

In United States v. Swenka, the defendant pleaded guilty to violating the National Firearms Act by making a sawed-off shotgun in violation of 26 U.S.C. sections 5822, 5861(f), and 5871, after shortening the barrel and removing the stock of his 20-gauge pump-action shotgun. At sentencing, the court addressed whether Guideline section 2K2.2(b)(3) applied to reduce the offense level by six points because the firearm was obtained or possessed solely for sport or recreation. The court held that the guideline covers the making of a firearm as well as its possession, placing the burden on the defendant to prove by a preponderance of the evidence that the reduction applied. The court concluded that the defendant failed to meet this burden, finding that his use of the weapon—including shooting at beer cans while driving after drinking—showed purposes beyond sport or recreation and violated Iowa law, resulting in an offense level of ten rather than four.

gunscriminal law

This ERISA case concerned two physically impaired employees at a Swift & Co. plant whose requests for transfers to other facilities after the plant's 1979 closure were denied on fitness grounds, leading them to apply for disability pensions under the Esmark pension plan, which the Pension Board rejected because their job loss stemmed from the closure rather than inability to perform available unit jobs. Plaintiffs challenged the denial in federal court, arguing for de novo review and that the Board's interpretation was arbitrary. The court applied a deferential arbitrary-and-capricious standard because the plan expressly granted the Board discretion to determine eligibility and construe terms, then upheld the denial as reasonable given the plan's language limiting disability to unit-specific unavailability of work, its overall purpose, and the governing effect of the plan document over any conflicting summary booklet.

labor & employmentbusiness & regulatoryprocedure

The case involved farmers in bankruptcy reorganization whose plan, approved by the bankruptcy court, did not allow the Farmers Home Administration (FmHA) to receive or offset payments from Agricultural Stabilization and Conservation Service (ASCS) farm programs against the debtors' mortgage debt. The district court reversed this approval on appeal, holding that FmHA could exercise setoff rights under 11 U.S.C. § 553(a). The core reasoning was that federal agencies like FmHA and ASCS are not separate entities but part of the same government, creating mutual obligations that permit setoff, although the program payments were not covered as "rents, issues, and profits" under the mortgage language.

business & regulatoryfederal powerproperty