In State v. McCullah, an inmate at a Polk County jail was charged with four counts of inmate assault under Iowa Code section 708.3B after a fight with officers in which multiple employees came into contact with blood. The Iowa Supreme Court addressed whether the statute requires proof that the blood or other bodily fluids originated from the inmate himself. The court held that a conviction requires only that an employee come into contact with such substances not his or her own, regardless of whether they came from the inmate or another person. It therefore affirmed three convictions where officers contacted blood from an unspecified source other than themselves and reversed the fourth conviction involving an officer whose own blood was involved. The decision rested on the plain language of the statute, which does not limit the source of the fluids to the defendant.
The case arose after a buyer purchased two vehicles at a public auction held by Wachovia following a foreclosure, but faced months-long delays in receiving titles due to issues with prior owners and procedural complications. The buyer sued Wachovia for fraudulent and negligent misrepresentation, securing a jury verdict for compensatory and punitive damages that the trial court upheld. The court of appeals reversed, holding there was insufficient evidence of fraudulent misrepresentation and that the negligent misrepresentation claim was barred by the economic loss doctrine. On further review, the supreme court analyzed the preservation of arguments, the elements of the claims, and the applicability of the economic loss doctrine to negligent misrepresentation cases involving purely economic losses.
In Renda v. Iowa Civil Rights Commission, an inmate at a state correctional facility filed a complaint with the Iowa Civil Rights Commission alleging sexual harassment and retaliation related to her prison job and housing. The Commission dismissed the complaint for lack of jurisdiction, concluding that a prison is not a dwelling and that an inmate is not an employee under the Iowa Civil Rights Act. The district court affirmed the dismissal. On appeal, the Iowa Supreme Court held that a correctional facility does not qualify as a dwelling but that an inmate's work within the prison does not automatically preclude employee status under the Act. The court affirmed in part, reversed in part, and remanded for further proceedings on the employment claim, applying de novo review to the statutory terms without deference to the agency's interpretation.
The case involved Farm Bureau Life Insurance Company seeking reimbursement from its insurers after settling a lawsuit by life insurance applicants who alleged negligence and breach of fiduciary duty for failing to disclose HIV-positive blood test results. Farm Bureau had maintained several liability policies, including claims-made ICPL policies and general liability FI and CU policies, but the insurers denied coverage. The district court granted summary judgment to the insurers, and the Iowa Supreme Court affirmed. The court held that Farm Bureau failed to provide timely notice of the claims under the ICPL policies as required, and that the underlying claims were excluded from coverage under the other policies because they did not result from an "occurrence" and fell within the Insurance and Related Operations Exclusion.
This case involved a workers' compensation claim by a truck driver injured while unloading freight, seeking benefits for permanent total disability. The dispute centered on the calculation of the employee's average weekly earnings under Iowa Code section 85.36(6) for determining the compensation rate, specifically whether to exclude three weeks of unusually low earnings from the thirteen weeks prior to the injury. The Iowa Supreme Court held that the workers' compensation commissioner correctly excluded those three low-earning weeks and substituted earnings from earlier representative weeks, resulting in a higher average weekly wage and compensation rate. The core reasoning was that the statute requires using earnings that fairly represent the employee's customary weekly earnings lost due to the injury, consistent with the purpose of replacing probable lost earnings as established in prior case law.
The case involved Nancy Kratzer, who sustained successive work-related injuries to her legs in 1994 and 2002, and sought additional permanent disability benefits from Iowa's Second Injury Fund after settling with her employer for the later injury. The workers' compensation commissioner awarded benefits, finding both injuries qualified under Iowa Code section 85.64, but the district court and court of appeals reversed, holding that the 2002 left-leg injury did not qualify as a second injury because the same body part had been affected earlier. On further review, the Iowa Supreme Court vacated the court of appeals decision, reversed the district court, and remanded to affirm the commissioner's award. The court reasoned that the 2002 injury caused a new and distinct increase in disability to the left leg, satisfying the statutory requirements for Fund liability, and that chapter 85 should be interpreted in favor of injured employees.