Jerry L. Larson

In Horak Prairie Farm, L.P. v. City of Cedar Rapids, property owners challenged special assessments imposed by the city for paving, storm sewers, traffic signals, and turn lanes on an abutting roadway, claiming that RISE grant funds should have been applied to the total project costs rather than only the public portion and that the assessments exceeded the special benefits to their properties. The Iowa Supreme Court reviewed the RISE allocation issue for legal error and the assessments de novo. It held that Iowa Code chapter 315 permits RISE funds to cover only the public share of costs, as applying them to private assessments would contradict the program's purpose and the special-assessment statute's goal of making benefited landowners pay their fair share. The court affirmed the assessments for pavement, signals, and turn lanes as reasonable and proportionate to benefits but reversed on the grading and drainage work, which should have reflected a 50% public benefit, and remanded for a corresponding reduction.

propertyprocedure

Cemen Tech sued Three D Industries, its principals, and several former employees for breach of contract, misappropriation of trade secrets, unfair competition, and breach of fiduciary duty after the defendants, who had negotiated to purchase parts of CTI using confidentiality agreements, started a competing mobile concrete mixer business and exhibited a similar product. The district court granted summary judgment to the defendants on most of the claims. The Iowa Supreme Court affirmed summary judgment on the contract claims and on certain trade-secret and fiduciary-duty claims but reversed on the trade-secret claims against most defendants, the unfair-competition claim, and the fiduciary-duty claims against the former-employee defendants, holding that genuine issues of material fact existed as to whether the information qualified as trade secrets and whether confidentiality agreements created fiduciary relationships.

business & regulatoryproceduretorts & liability

The case involved Floyd Wright, who was convicted of statutory rape in 1977 but never required to register as a sex offender, challenging the application of Iowa Code section 692A.2A's residency restrictions that prohibit certain sex offenders from living within 2,000 feet of schools or child care facilities. Wright argued the statute applied only to registered offenders and, if applied to him, violated equal protection and substantive due process rights while constituting an invalid bill of attainder. The Iowa Supreme Court affirmed the district court's rejection of these claims, holding that the statute's definition of "person" unambiguously covers all individuals convicted of relevant offenses against minors, not merely those on the registry, and that the restrictions were not punitive or unconstitutional under precedents like State v. Seering. The court noted the legislature had deliberately broadened the original bill's language to apply beyond registered offenders and found no violation in the law's operation based on a prior conviction.

criminal lawcivil rights

This case involved a challenge by the state public defender to a district court order that awarded attorney fees to Scott Bandstra exceeding the $1500 limit set in his contract for representing an indigent client in an appeal from a postconviction-relief proceeding. The district court had granted the additional fees based on its plenary powers to do justice between the parties, despite the existence of the contract and the public defender's denial of the excess claim. The Iowa Supreme Court sustained the writ of certiorari, holding that the district court exceeded its authority because the contract terms were binding and the attorney had not followed the required administrative procedures under Iowa Code chapters 13B and 815 and related administrative rules to seek an increase for an unusually complex case. Those rules required initial approval from the public defender rather than direct court authorization, and the separate procedure for exceeding fee limits did not apply to appellate contracts. The court therefore concluded the public defender was not obligated to pay the excess amount.

criminal lawprocedure

Thomas Millam was convicted of two counts of second-degree sexual abuse and later sought postconviction relief claiming ineffective assistance of counsel. The district court granted relief, the court of appeals reversed, and the Iowa Supreme Court vacated the appellate decision, affirmed the district court, and remanded for a new trial. The court held that counsel failed to perform an essential duty by not offering evidence of the victim's prior false claims of sexual abuse, which was not clearly excluded by the rape-shield law, and that this omission prejudiced the defense by undermining confidence in the outcome given the central role of the victim's credibility.

criminal lawprocedure

This case involved the Ames Community School District board terminating the coaching contract of Dennis Cullinan based on repeated complaints from students and parents about his threatening and intimidating conduct, use of profanity, and creation of a negative environment for athletes, despite prior warnings and a probationary extension. An adjudicator reversed the termination under Iowa Code sections 279.15-.19A, the district court affirmed that reversal, and a divided court of appeals also affirmed. On further review, the Iowa Supreme Court vacated the court of appeals decision, reversed the district court, and remanded for an order upholding the board's termination. The court held that the superintendent had established just cause for termination by a preponderance of the competent evidence in the record, including ongoing behavioral issues from 1998 onward that affected student well-being and were not related to playing time or win-loss records. It further concluded that the board's action was neither unreasonable nor an abuse of discretion.

labor & employmentprocedure