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

The case was a zoning dispute in which plaintiffs purchased undeveloped land in Wilton, Iowa, that was partially zoned for multi-family residential use to develop a federally subsidized housing project. After plaintiffs incurred planning expenses and obtained financing, the city council, following a planning commission recommendation citing infrastructure limits, enacted an ordinance rezoning the area to single-family residential, which blocked the project and led to denial of a building permit. Plaintiffs sued for a declaratory judgment invalidating the ordinance, injunctive relief, and damages including lost profits. The court affirmed the dismissal, holding that the rezoning was a valid legislative act that was at least fairly debatable and reasonably related to health, safety, and welfare, and that plaintiffs lacked vested rights necessary to pursue lost-profits damages.

property

The case involved Skyline Harvestore Systems seeking a declaratory judgment on whether its comprehensive general liability insurance policy with Centennial Insurance Company covered potential punitive damages awards in personal injury lawsuits arising from equipment sold by Skyline. The trial court ruled that the policy did not provide such coverage. The Iowa Supreme Court reversed, holding that the policy's language requiring payment of "all sums" the insured is legally obligated to pay as damages for bodily injury includes punitive damages. The court reasoned that the broad policy terms should be given their ordinary meaning without specific exclusions, consistent with prior precedent, and that freedom of contract for insurance outweighs public policy concerns about punitive damages' deterrent effect.

business & regulatorytorts & liability

The case involved William G. Opperman challenging a district court's contempt order and 30-day jail sentence for failing to comply with child support obligations from his dissolution decree after he moved to Illinois. The Iowa Supreme Court upheld the district court's jurisdiction and sentencing authority, annulling the writ of certiorari. The court reasoned that the contempt proceeding was supplementary to the original dissolution action, over which the court had personal jurisdiction, allowing continued enforcement jurisdiction even after Opperman became a nonresident, and that personal service of the rule to show cause in Illinois satisfied due process requirements. Additionally, under Iowa Code section 665.7, the court could impose the sentence without Opperman's personal presence since he had been served with the rule to show cause.

family lawprocedure

The case involved defendant Carmen Boelman, who was charged with false use of a financial instrument (FUFI) and moved to dismiss the trial information under Iowa R.Crim.P. 27(2)(a) on the ground that she was not indicted within forty-five days of her arrest. The trial court overruled the motion, Boelman was convicted, and she appealed, with the sole issue being whether her arrest occurred on August 10 or August 18, 1981. The Iowa Supreme Court affirmed, holding that substantial evidence supported the trial court's implicit finding that she was arrested on August 18 when the warrant was served, rather than on August 10, and therefore the October 1 filing of the trial information was timely. The court reasoned that conflicting testimony existed about when she was taken into custody on the new charge, the trial court was not required to credit her account of an earlier arrest, and the case was not controlled by precedent deeming an arrest to occur upon filing a new charge against someone already in custody. Because the filing occurred within forty-five days of the arrest date found by the court, dismissal was not required.

criminal lawprocedure

This case concerned Polk County's 1981-82 budget, which was protested by taxpayers under Iowa's Local Budget Law (ch. 24) for issues including over-budgeting of employee benefits and fund transfers; the State Appeal Board reduced the budget by about $880,000 after a hearing, and the county plus intervenors sought judicial review under the Iowa Administrative Procedure Act (ch. 17A). The district court dismissed most claims for lack of standing and upheld the reductions. On appeal, the Iowa Supreme Court reversed in part on standing—granting Polk County standing for certain issues like agency authority and procedure but limiting others—and addressed mootness, statutory harmonization, and delegation questions, but ultimately affirmed the result by upholding the Board's decision. The core reasoning involved interpreting the interplay between chapters 17A and 24, applying standing rules based on the type of challenge raised, and concluding that the protest process and final Board action were valid without requiring full IAPA contested-case procedures.

proceduretaxes

The case involved a child custody dispute between parents Jack and Cindy O'Neal over their daughter Michelle, who had lived in over twenty-five homes across multiple states due to repeated moves and parental conflicts. Jack obtained a default Arizona divorce decree awarding him custody, then filed a habeas corpus action in Iowa after Cindy brought Michelle there, seeking enforcement of the Arizona order. The trial court ruled it lacked jurisdiction under the Uniform Child Custody Jurisdiction Act (UCCJA) and declined to exercise any. The Iowa Supreme Court reversed, holding that the Arizona decree did not meet UCCJA standards for recognition because Arizona was not the child's home state and lacked significant connections, but Iowa had jurisdiction under UCCJA section 598A.3(1)(b) due to the parties' and child's connections to the state and should exercise it to protect the child's welfare rather than apply the clean hands doctrine to decline based on Cindy's conduct.

family law

The case involved a dispute over whether a 1879 warranty deed conveying a railroad right of way transferred an easement that could revert upon abandonment or a determinable fee. Plaintiffs sought a declaratory judgment that it was an easement, and the trial court ruled on this as a matter of law under Iowa Rule of Civil Procedure 105. The Iowa Supreme Court reversed, holding that such a ruling was inappropriate because the pleadings showed disputed material facts without any stipulation by the parties, and construction of the deed requires evidence of the grantors' intent based on surrounding circumstances. The court remanded for further proceedings to allow presentation of evidence before construing the deed.

propertyprocedure

In State v. Nelson, the defendant appealed his conviction for false imprisonment under Iowa Code section 710.7, raising three claims: that admitting his codefendant's written confession violated his Sixth Amendment confrontation right, that the trial court should have instructed the jury on the justification defense of defense of property, and that his ineffective assistance of counsel claim should be decided on direct appeal. The Iowa Supreme Court affirmed the conviction, holding that the confrontation issue was not preserved because trial counsel objected only on hearsay grounds, that the facts did not support a defense-of-property instruction since the theft occurred outside the defendant's presence and the property was not being taken in his presence, and that ineffective-assistance claims require a postconviction record and thus could not be resolved on direct appeal. The court therefore affirmed without reaching the merits of the unpreserved or undeveloped claims.

criminal lawprocedureproperty

The case involved Colonial Baking Company suing Frederick Dowie personally after he signed a corporate check for hotdog buns that was later dishonored, with Dowie arguing he signed only in a representative capacity for his corporation. The district court denied Colonial's motion for summary judgment against Dowie, allowed the corporation to be joined, and entered a jury verdict against both defendants for half the check amount. On appeal, the Iowa Supreme Court held that a signer of a corporate check who does not indicate representative capacity is personally liable under the Uniform Commercial Code unless the drawer specially pleads and proves an agreement to the contrary, and that summary judgment should have been granted to Colonial because Dowie's resistance raised no genuine issue of material fact. The court reversed the denial of summary judgment as to Dowie and remanded for entry of judgment in the full amount of the check while upholding the judgment against the non-appealing corporation.

business & regulatoryprocedure

In State v. Schertz, the defendant appealed his convictions for first-degree murder, first-degree kidnapping, and second-degree theft, arguing insufficient evidence to support the kidnapping conviction based on torture, improper amendment of the trial information to add torture as an alternative basis for the charge, and denial of effective assistance of counsel. The Iowa Supreme Court affirmed the convictions and sentence. It held that the evidence issue was controlled by a prior companion case, that the amendment did not charge a new offense and caused no prejudice to the defendant because the term "torture" could be given its ordinary meaning without requiring a continuance, and that the ineffective-counsel claim could not be resolved on the existing record and must be raised in postconviction proceedings.

criminal lawprocedure

This case arose from a damages action by a passenger injured in an auto-train collision at a railroad crossing protected only by a crossbuck sign, where the plaintiff alleged the crossing was extra-hazardous and required additional warnings from the railroad. The central issue was whether Iowa Code section 307.26(5)(b), providing that a crossing shall not be found particularly hazardous unless the DOT has so determined, assigns exclusive authority to the DOT and bars judicial or jury determination in tort suits. The Iowa Supreme Court held that the statute does not change the common-law approach under which the fact finder decides whether conditions at a crossing call for extra warnings beyond statutory minima, construing the provision instead as limited to the DOT's internal safety programs and upgrade standards. The court affirmed the outcome allowing jury resolution of the issue while rejecting the district court's conclusion that the statute applied to such actions or was unconstitutional.

torts & liabilityprocedure

The case involved plaintiff Steven Sponsler, who suffered severe electrical burns during a bridge repair job when his supervisor raised a crane boom into a power line owned by defendant Clarke Electric Cooperative. Sponsler sued the cooperative for negligence in the placement and maintenance of the line, but the defendant asserted that the sole proximate cause of the injury was the negligence of the county or the supervisor. The trial court allowed evidence and jury instructions on this sole proximate cause defense, which the jury accepted in returning a verdict for the defendant. On appeal, the Iowa Supreme Court declined to abolish the defense, holding that it has long been recognized in Iowa, that the defendant bears the burden of proof on it, and that a party is entitled to instructions on the defense when supported by substantial evidence. The court also found that the instructions did not unduly emphasize the defense and affirmed the judgment.

torts & liabilityprocedure

This case concerned competing claims by two creditors to proceeds from the sale of recreational vehicles by a bankrupt dealer, Ponderosa R.V. Center. Plaintiff Coachmen Industries, as assignee of a purchase money security interest perfected in late 1977, sought recovery of sale proceeds from two vehicles from defendant Security Trust & Savings Bank, which held an earlier general security interest and exercised a right of setoff against the dealer's account. The trial court awarded plaintiff the proceeds from one sale but denied recovery on the second based on estoppel and refused prejudgment interest. On appeal, the Iowa Supreme Court held that plaintiff's purchase money security interest took priority over the bank's setoff right under UCC section 554.9306 and that estoppel did not apply because there was no misrepresentation or prejudice to the bank; it therefore reversed to award both sets of proceeds to plaintiff along with prejudgment interest calculated under Iowa Code sections 535.2 and 535.3.

business & regulatoryproperty

This case involved a dispute over whether a citizen petition to discontinue and sell a municipal electric utility met the requirements for submission to voters under Iowa Code section 388.2. The plaintiff sought a writ of mandamus to force the Ames city council to place the proposal on the ballot, but the city argued the petition was invalid because it did not specify a buyer or sale price. The district court ruled the proposal valid and ordered it submitted, and the Iowa Supreme Court affirmed. The court reasoned that the statute requires only voter approval of the general proposal to discontinue and sell the utility, with all details of any disposition left to the council's discretion afterward, and that the petition substantially complied with the law by clearly informing voters of the issue. The cross-appeal challenging the district court's statements on the effect of voter approval was rejected as surplusage.

electionsbusiness & regulatoryprocedure