James Harvey Carter

The case involved a longtime teacher seeking workers’ compensation benefits for severe depression allegedly caused by workplace stresses from conflicts with a new principal and other conditions at his school. The workers’ compensation commissioner found that medical causation had been established but denied the claim for lack of legal causation under the Dunlavey standard applicable to mental injury claims, and the district court upheld that denial. On appeal, the Iowa Supreme Court affirmed, concluding that the claimant had not shown the stresses were of greater magnitude than those experienced by other employees in similar positions. The court also rejected an equal protection challenge to the distinct legal causation requirement, holding that it is rationally related to the legitimate goal of preventing the workers’ compensation system from functioning as general mental health insurance.

labor & employment

The case involved Douglas Grant, convicted after a bench trial of possession with intent to deliver methamphetamine under Iowa Code section 124.401(1)(c)(6), a class C felony. Police officers obtained consent to search his home while looking for other suspects and found eight individually wrapped packages totaling 5.38 grams of methamphetamine, plus a device for inhaling the drug. Grant appealed, challenging the sufficiency of evidence for intent to deliver. The Iowa Supreme Court affirmed the conviction, holding that the officers' testimony about the packaging into dosage units supported an inference of intent to sell, even without scales, cash, or pay/owe sheets. A dissent argued the evidence was equally consistent with personal use and insufficient for conviction.

criminal law

The case involved a car accident in which thirteen-year-old Amanda Le was injured while driving a vehicle entrusted to her by defendant Vaknin; Amanda and her mother sued Vaknin for negligent entrustment and their uninsured-motorist insurer, American Family, for coverage. The jury found Vaknin 60 percent at fault and Amanda 40 percent at fault, awarded damages of about $18,864, determined that Vaknin was not the "operator" of the vehicle, and noted that a third-party insurer had paid nearly $10,000 in medical expenses. The court affirmed judgment for American Family, holding that the statutory definition of "operator" as a person in actual physical control applied to the insurance policy and precluded coverage. It vacated the judgment against Vaknin and remanded for the trial court to determine whether the third-party payer held subrogation rights, to avoid an improper double reduction of damages.

torts & liabilityprocedure

The case involved a challenge by two residents to a Dubuque city council ordinance that rezoned property from commercial recreation to a planned unit development district, passed on a 4-3 vote including the mayor. The district court voided the rezoning on grounds that the mayor had a disqualifying conflict of interest due to potential real estate commissions, but rejected other challenges by the plaintiffs. On appeal, the Iowa Supreme Court reversed, holding that the plaintiffs' claims were barred by the 30-day limitations period under Iowa Rule of Civil Procedure 1.1402(3) because certiorari is the exclusive remedy for reviewing the legality of quasi-judicial rezoning decisions by city councils. The court reasoned that rezoning amendments involve adjudication between proponents and opponents, triggering certiorari review, and strong public policy supports strict time limits to allow officials to rely on enacted zoning without later challenges. The court affirmed the district court's rejection of the plaintiffs' remaining claims on the merits.

propertyprocedurebusiness & regulatory

The case involved two residents challenging a Dubuque city council ordinance that rezoned property from commercial recreation to a planned unit development district, alleging the mayor had a conflict of interest due to potential real estate commissions and raising other procedural and substantive objections. The district court invalidated the ordinance on conflict-of-interest grounds after rejecting the city's timeliness and standing defenses, but the Iowa Supreme Court reversed. It held that rezoning decisions are quasi-judicial in nature because they involve notice, hearings, and adjudication of specific rights, making certiorari the exclusive remedy under Iowa Rule of Civil Procedure 1.1401 with a strict 30-day filing limit. The court applied this limit to bar the declaratory judgment action as untimely, citing policy reasons for prompt resolution of challenges to municipal decisions, while affirming the rejection of the objectors' other claims on the merits.

procedurepropertybusiness & regulatory

The case involved a product-liability suit by plaintiff Douglas Kolarik against importers and wholesalers of Spanish olives, alleging that he fractured a tooth after biting on a pit or pit fragment in a jar of pimento-stuffed green olives sold under the Italica label. Plaintiff asserted claims for negligence (including failure to warn), strict liability, and breach of express and implied warranty. The district court granted summary judgment to defendants on all claims, and the Iowa Supreme Court affirmed as to strict liability and the warranty claims under Iowa Code section 613.18(1)(a) immunity for non-assemblers and non-manufacturers whose repackaging did not contribute to the defect, as well as on negligence theories other than failure to warn. The court reversed summary judgment on the negligence failure-to-warn claim, holding that a genuine issue of material fact existed because evidence showed the pitting process is not 100 percent effective and a reasonable wholesaler might need to warn consumers of possible pits or fragments. The case was remanded for further proceedings on that claim.

torts & liabilityprocedure

This case involved an attorney disciplinary proceeding against Theodore M. Meggers, who was accused of neglecting a client's matter by failing to file a notice of appeal in an operating-while-intoxicated conviction after being instructed to do so by the client. The Iowa Supreme Court Attorney Disciplinary Board also charged Meggers with failing to respond to its inquiries about the complaint, despite multiple attempts at contact by mail. The Grievance Commission found the allegations admitted due to Meggers' lack of response and recommended a three-month suspension. The Iowa Supreme Court upheld the findings of violations under DR 6-101(A)(3) for neglect and DR 1-102(A)(5) for non-cooperation with the Board, imposing an indefinite suspension of his law license with no possibility of reinstatement for three months.

criminal lawprocedure

In McVey v. National Organization Service, Inc., the plaintiff sued her former employer after being fired following a positive random drug test for marijuana, claiming the test violated Iowa Code section 730.5 requirements for employee drug testing and seeking damages including reinstatement. The district court granted summary judgment to the employer, but the Iowa Supreme Court reversed and remanded. The court held that genuine issues of material fact existed as to whether the employer had provided McVey with a written drug-testing policy meeting statutory standards, including uniform rules on disciplinary or rehabilitative actions for positive tests. The opinion emphasized that an employer may only discharge an employee based on such testing if the program fully complies with the detailed statutory mandates, and disputed facts about policy receipt and content precluded summary judgment.

labor & employmentprocedure

The case concerned allegations that attorney James M. Box violated Iowa disciplinary rules by communicating with an elderly client who was represented by another attorney and providing advice to parties with conflicting interests regarding her estate plan involving substantial farmland. The Grievance Commission found a violation of DR 7-104(A)(1) but not (A)(2) and recommended a private admonition. On appeal, the Iowa Supreme Court upheld the violation finding, determined that public discipline was appropriate due to the harm caused and comparisons to similar cases, and issued a public reprimand to Box.

family lawpropertyprocedure

In State v. Matlock, defendant Roosevelt Matlock was convicted of willful injury and going armed with intent after a confrontation outside a bar in which he allegedly inflicted cuts on victim Joel Riley using a sharp object; Matlock claimed self-defense with a broken beer glass. The Iowa Supreme Court reversed both convictions and remanded for a new trial. The court held that the district court abused its discretion by admitting evidence of Matlock's other bad acts to prove the required intent, as this use amounted to improper propensity evidence in violation of Iowa Rule of Evidence 5.404(b) and the limiting instruction did not prevent prejudice to the defendant. The court of appeals decision was vacated.

criminal lawprocedure

In State v. Campbell, defendant Thomas Leonard Campbell was convicted of four counts of burglary and one count of criminal mischief after items stolen in burglaries were found in a room he used at a friend's home, based in part on testimony from his girlfriend Hope Voshel. On appeal, Campbell challenged the denial of his speedy trial right due to multiple continuances and the district court's restriction of his cross-examination of Voshel regarding her credibility and the source of jewelry she produced. The Iowa Supreme Court held that the speedy trial deadline was not violated because the delays stemmed from defense requests, counsel conflicts, and Campbell's own motions. However, it found reversible error in limiting cross-examination of Voshel, whose testimony was central and whose credibility was questionable, requiring reversal of the burglary convictions and remand for a new trial while affirming the criminal mischief conviction. The court also rejected an ineffective assistance claim regarding suppression of evidence seized from the friend's home.

criminal lawprocedure

This case involved vendees under a real estate purchase contract who sued to enjoin the vendor from forfeiting their interest after they missed a monthly payment. The vendor had attempted forfeiture by serving a single copy of the required statutory notice on one vendee at their shared residence, with the process server indicating personal service on her and substituted service on the other. The Iowa Supreme Court held that this service did not comply with Iowa Code sections 656.2 and 656.3, which require proper notice to each vendee, because delivering only one copy created uncertainty about which party was served and reduced the likelihood that both would receive actual notice. The court vacated the court of appeals decision, reversed the district court's upholding of the forfeiture, and remanded for further proceedings.

propertyprocedure

The case involved Isaac Kruse, who pled guilty to the aggravated misdemeanor of assault with intent to commit serious injury after originally being charged with third-degree sexual abuse of a minor. He received a suspended sentence and probation that included conditions for sex offender counseling and registration. After Kruse failed to register or attend the required program, the district court found probation violations based on the facts of his offense qualifying as a criminal offense against a minor under Iowa Code section 692A.1, and it ordered compliance. On certiorari review, the Iowa Supreme Court upheld the district court's decision, holding that registration was properly required after a factual inquiry and that Kruse received due process through a predeprivation hearing.

criminal lawprocedure

The case involved the estate of Mary Serovy, where the Iowa Department of Human Services sought reimbursement for Medicaid benefits provided to her in 1997-1998 from her one-third joint tenancy interest in her home, which passed to her son Allan and daughter-in-law Pearl upon her death. Allan and Pearl appealed a probate court order allowing the claim and authorizing sale of the property, arguing that Iowa Code section 249A.5(2) unconstitutionally impaired their 1988 contract with Mary under which they built an addition and provided care in exchange for joint tenancy. The court rejected the constitutional challenge, reasoning that the contract was fully performed before the 1994 statute's enactment expanding recoverable assets to include joint interests, so there was no impairment. It affirmed allowance of the $28,707 claim but modified the order to limit any sale or buyout to only Mary's one-third interest, as the personal representative could not sell the survivors' shares.

healthcarepropertyprocedurefamily law

This case concerned whether assets held in a revocable inter vivos trust created by Edward Sieh before his marriage should be included in the statutory elective share of his surviving spouse, Mary Jane Sieh, under Iowa Code section 633.238 after she elected against his will. The probate court granted summary judgment to the trust beneficiaries (Edward's children), ruling that the trust assets were not part of the decedent's estate subject to the spouse's share. The Iowa Supreme Court reversed, holding that because Edward retained full control over the trust assets, including the power to revoke the trust, at the time of his death, those assets qualified as property possessed by the decedent during the marriage and thus were includable in Mary Jane's statutory share. The court remanded for recomputation of the share and noted that the spouse's election could be pursued in the estate proceedings without a separate trust action.

family lawproperty

The case involved an appeal by the attorney for the executor of Melba N. Martin's estate from a probate court order that reduced the maximum allowable attorney fees. The district court had revised its initial fee award downward after the Iowa Department of Revenue determined that certain retirement annuities payable to a designated beneficiary were exempt from Iowa inheritance tax under section 450.4(5) and thus should be excluded from the gross estate value used to calculate fees under sections 633.197 and 633.198. The Iowa Supreme Court reversed and remanded, concluding that the statutory phrase 'gross assets of the estate listed in the probate inventory for Iowa inheritance tax purposes' includes the full inventory values of those annuities even if they are not ultimately subject to tax. The court reasoned that the fee schedule is based on the assets reported in the inventory rather than on the taxable portion after exemptions.

taxesprocedure

This case involves the Iowa Supreme Court reviewing the Grievance Commission's findings against attorney Michael G. Reilly for ethical violations. Reilly converted over $99,000 in client settlement funds from his trust account for personal use and engaged in a check-kiting scheme that caused a $96,000 loss to a bank, which was later repaid. The Commission recommended a three-year suspension, but the court revoked his license, reasoning that revocation aligns with prior cases involving client fund misappropriation to ensure consistency and public protection, with the check-kiting as an aggravating factor.

criminal lawprocedure

This case involved a plaintiff injured in a 1997 collision with a self-insured trucking company that later became insolvent in 2002; the plaintiff sought uninsured-motorist benefits from his own insurer, State Farm, but the insurer denied the claim partly because it was filed more than two years after the accident under a policy provision. The district court issued conflicting summary judgment rulings on whether the contractual time limit applied and whether uninsured-motorist coverage extended to self-insured entities that became insolvent. On appeal, the Iowa Supreme Court held that Iowa Code section 516A.1 extends uninsured-motorist protection to self-insured motorists who become insolvent after an accident, that such a claim does not accrue until the insolvency occurs, and that the policy's two-year contractual limitation is unreasonable and unenforceable because it would bar the claim before it accrued, leaving the ten-year statutory limit under Iowa Code section 614.1(5) to apply instead. The court therefore reversed the denial of the plaintiff's summary judgment motion and affirmed the denial of the insurer's motion.

business & regulatorytorts & liabilityprocedure

In State v. Andrews, the defendant was convicted of driving while barred under Iowa Code section 321.561 after an investigatory traffic stop. He appealed, arguing that the stop was illegal because the officer had seen a temporary "in transit" sign on the vehicle, that his trial counsel was ineffective for stipulating to facts and hearsay evidence, and that the stipulated record was insufficient to prove guilt. The Iowa Supreme Court affirmed the conviction, holding that the stop was justified under precedent allowing stops to check registration when no plates are visible, even if a temporary registration is later noticed, as the officer's action was based on an objectively reasonable observation. The court further found that counsel's stipulation was a deliberate tactical choice to avoid waiver issues from a guilty plea and that the agreed-upon evidence in the record, including testimony about the defendant's barred status, was sufficient to support the conviction.

criminal lawprocedure

The case involved defendant Gabriel Rojas Acevedo, who was convicted after using the false name Adrian Alonzo to sign an appearance bond following a traffic arrest and later to apply for a duplicate vehicle title at a county office. He appealed the convictions for forgery, third-degree fraudulent practice, and tampering with records, arguing insufficient evidence. The Iowa Supreme Court affirmed all three convictions, holding that the evidence supported findings of intent to defraud through deliberate use of false identification to gain advantages he could not obtain under his real name. The court also determined that the tampering statute applied broadly to falsified writings like the title application, distinct from statutes covering alterations of completed public records.

criminal law