Clay LeGrand

This case involved a dispute over real estate installment contracts in Iowa, where seller R.B. Gray sold multiple properties to buyers Edwin and Wava Bowers under two contracts without down payments, along with a simultaneous $30,000 promissory note and mortgage on other property as additional security. After the buyers defaulted and the seller forfeited their interests in the properties, the seller sought to enforce payment on the note. The trial court ruled for the buyers on multiple grounds, including lack of consideration and that forfeiture extinguished any further liability for the purchase price. The Iowa Supreme Court affirmed, holding that the note was tied to the contracts as consideration and that the seller's forfeiture of the contracts terminated any right to recover the unpaid amounts, consistent with prior precedent like Abodeely v. Cavras. The court did not reach other issues such as election of remedies.

property

This workers' compensation case involved a worker who suffered a permanent partial injury to his leg and sought benefits based on his resulting loss of earning capacity after his employer refused to rehire him under a full-release policy. The industrial commissioner and district court limited benefits to the statutory schedule for a 20 percent physical impairment of the leg. The Iowa Supreme Court affirmed, holding that for scheduled injuries the compensation statute fixes benefits according to the percentage of physical impairment without regard to industrial disability factors such as reduced earning capacity, which apply only to nonscheduled injuries. The court reasoned that the legislature's schedule conclusively presumes the relationship between functional loss and earning capacity for such injuries, and the statutory language controls the outcome.

labor & employment

The case involved Iowa inmates with prior forcible felony convictions who were denied parole consideration under Iowa Code § 906.5, which bars parole until at least half the maximum sentence is served; they brought a facial constitutional challenge claiming the statute violated due process and equal protection by restricting parole without a full judicial evidentiary hearing to prove identity, the nature of the prior offense, and its constitutional validity, with facts established beyond a reasonable doubt. The Iowa Supreme Court affirmed the trial court's rejection of the challenge, holding that the statute is a valid limitation on the parole board's authority rather than an enhanced penalty or minimum sentence. The court reasoned that precedents such as State v. Wilson and Greenholtz v. Nebraska Penal Inmates establish that parole eligibility decisions need not occur in court with full criminal trial protections, that board rules provide notice, review by a liaison officer, parole board review, and judicial appeal under chapter 17A, and that analogous federal parole guidelines considering prior records have been upheld as constitutional.

criminal lawcivil rightsprocedure

The case involved the State of Iowa seeking to enjoin Jerry Miner from operating a used car brokerage service called "Wheels" without a license as a used motor vehicle dealer under Iowa Code chapter 322. The district court granted the injunction, and the Iowa Supreme Court affirmed. The court reasoned that the broad language of section 322.3(2) and related regulations explicitly require licensing for those engaged in the business of selling used motor vehicles at retail, which includes brokering as defined by the DOT rules. Defendant's constitutional challenges, including under the Commerce Clause, were rejected because the requirements regulate the method of sale rather than burdening interstate commerce itself. The injunction was deemed appropriate to allow regulation protecting consumers.

business & regulatory

This case concerns whether police could lawfully make a warrantless arrest inside a home without consent in State v. Gregory. The court held that exigent circumstances justified the arrest, supplementing its prior opinion and affirming the trial court's judgment while denying rehearing. It applied six non-dispositive guidelines from precedent: involvement of a grave offense, reasonable belief the suspect is armed, probable cause the suspect committed the crime, strong likelihood of escape, strong reason to believe the suspect is on the premises, and peaceable entry. All factors were met to some degree because the defendant was suspected of a shooting with the weapon unrecovered, a witness provided probable cause, police saw him inside, he had fled once already, and entry was peaceful. The court rejected the argument that surrounding the house eliminated any escape risk.

criminal lawprocedure

The case concerned the Marshalltown Community School District's 1981 decision to close the Albion elementary school, which was affirmed by the Iowa Department of Public Instruction (DPI) after an appeal by local residents. Petitioners sought judicial review, alleging an open meetings law violation in the notice for the board meeting, use of improper criteria under statutes like section 297.1, and that the decision lacked substantial evidence or was arbitrary. The Iowa Supreme Court affirmed the district court's ruling upholding the DPI decision, reasoning that alleged open meetings violations by a local board cannot be raised in judicial review of the DPI but require a separate original action, that school boards have broad discretion in closure decisions with geographic factors not being controlling, and that the record supported the DPI's affirmation under substantial evidence standards without arbitrariness.

procedure