This case involved the estate of Fred Duhme, who died testate with a will and codicils that specifically devised farms and other property to his son Raymond while providing smaller general legacies to his three daughters and dividing the residue among his six sons. The executor sought and the trial court granted proportional abatement of all beneficiaries' shares to cover federal estate taxes and other expenses, but the Iowa Supreme Court reversed that order. The court held that abatement must follow the default statutory sequence in Iowa Code § 633.436, which prioritizes non-specific and residuary devises over specific ones. It reasoned that § 633.437's exception for defeating the testator's plan did not apply because there was no clear and convincing evidence that Fred intended to equalize shares in the event of tax shortfalls, even though the will favored Raymond.
The case involved a drainage district in Clay County seeking declaratory relief to require the City of Spencer and the Iowa DOT to pay assessments for the construction of culverts under highways and roads within city limits, as well as related area assessments. The trial court granted summary judgment to both defendants, dismissing the district's petition. On appeal, the Iowa Supreme Court affirmed the dismissal as to the DOT, finding no statutory authority for assessments against it because the DOT lacked jurisdiction over the relevant highways at the time. The court reversed in part as to the City, holding that the district could pursue an area benefit assessment claim at one location where statutory authority existed, and remanded for further proceedings on that issue.
In Berger v. General United Group, Inc., stockholders of an Iowa insurance holding company filed a derivative action alleging that Wheelabrator-Frye acquired control of GUG by paying a premium to two officers for their stock that amounted to a commercial bribe violating Iowa Code § 741.1, along with breaches of fiduciary duty, and sought damages and restitution after the company was merged into successor entities. The trial court dismissed the petition for failure to make a demand on the board as required by rule 44 and because, under Iowa Code § 496A.74(2)(c) and Delaware law, the cause of action passed to the surviving corporation. The Iowa Supreme Court affirmed, ruling that the plaintiffs lacked standing since derivative rights transferred to the successor under the applicable merger statutes and the petition contained no allegations challenging the mergers or establishing plaintiffs' status in the surviving entity.
In Knauss v. Kemin Industries, Inc., an employee sued his former employer for unpaid sales bonuses under an employment agreement, while the employer separately sought to enforce a non-compete covenant against the employee after he joined a competitor. The trial court ruled that the employer failed to prove modification of the agreement to eliminate the bonuses and that the new employer was not a competitor, denying the injunction. On appeal, the Iowa Supreme Court dismissed the non-compete claim as moot because the three-year restriction period had expired and affirmed the trial court's findings on the employment contract, holding that substantial evidence supported the conclusion of no contract modification and that the burden of proof was properly applied.
The case was a false arrest damages action brought by Terry Young against the City of Des Moines under Iowa's Governmental Subdivision Tort Claims Act after police arrested him without a warrant for public intoxication and the charges were later dismissed when officers failed to appear. The Iowa Supreme Court reversed the judgment entered on the jury verdict for Young and also reversed on his cross-appeal. The court held that the trial court's jury instruction on lawful arrest was erroneous for failing to properly address the requirements of Iowa Code § 755.4(1) that an offense must actually have been committed or attempted in the officers' presence, and further held that punitive damages are not recoverable from a municipality.
This case involved a challenge by Linn County officials and some taxpayers to the constitutionality of Iowa's amended procedures under Chapter 441 for implementing property tax equalization orders issued by the Department of Revenue. The plaintiffs claimed the new process, which shifted notice to county auditors and limited protests, violated due process and improper delegation of legislative power. The Iowa Supreme Court affirmed the lower court's dismissal, holding that the equalization function is legislative in nature, requiring only general notice rather than individualized hearings, and that adequate judicial review was available under the Administrative Procedure Act.