Bruce M. Snell

This case involved former foremen and supervisory employees of Iowa Beef Packers, Inc. (IBP) who sued after the company sold its Perry plant, claiming they were owed a promised bonus for fiscal year 1965 based on oral assurances made when they accepted promotions (to offset reduced weekly pay) and the right to exercise stock options. The Iowa Supreme Court affirmed the trial court's ruling in favor of the plaintiffs on the bonus claims, holding that enforceable agreements existed that had not been waived or terminated by later company policy changes. On the stock option claims, the court reversed the trial court and remanded for entry of judgments awarding damages, finding the options remained valid post-sale with value calculated using market prices at the exercise deadline (adjusted for a stock dividend).

labor & employmentbusiness & regulatory

This case involved a wrongful death claim by the administrator of a construction worker who was electrocuted while working near energized high-voltage lines at an electrical substation owned by defendant Central Iowa Power Cooperative (Cipco) and operated by defendant Iowa Electric Light and Power Company. The jury found both defendants negligent and awarded damages, but the trial court granted judgment notwithstanding the verdict to Cipco while upholding the verdict against Iowa Electric. On appeal, the Iowa Supreme Court affirmed, holding that there was sufficient evidence, including a statutory presumption of negligence for injuries caused by transmission lines, to support liability for Iowa Electric, but no evidence of negligence by Cipco.

torts & liabilitybusiness & regulatory

This case involved a wrongful death action under Iowa's Guest Statute, where the administrator of a passenger killed in a one-car accident sued the driver and owner for recklessness after the vehicle crashed at high speed. The trial court submitted questions of recklessness and assumption of risk to the jury, which returned a verdict for the plaintiff. The Iowa Supreme Court affirmed, ruling that evidence of the driver traveling at a minimum of 75 mph in a 35 mph zone at night, approaching a known curve, and briefly looking away from the road supported a finding of recklessness beyond mere negligence or momentary thoughtlessness. The court further clarified that while a persistent course of conduct can help establish recklessness, it is not an essential element that must always be shown.

torts & liability

This case concerned whether Wesley Acres, a retirement home operated by a nonprofit corporation affiliated with the Methodist Church, qualified for property tax exemption under Iowa Code section 427.1(9) as a charitable, religious, and benevolent institution. The Board of Review had placed the property on the tax rolls in 1967, and the trial court upheld that decision, but the Iowa Supreme Court reversed on de novo review. The court found that the home was organized as a nonprofit, operated under Methodist Church discipline with church financial and governance support, provided care including to residents unable to pay full fees through subsidies and a Good Samaritan Fund, and used its property for appropriate charitable and religious purposes without regard to residents' ability to pay or size of contributions. The court held that charging fees or receiving contributions did not convert the use into a non-exempt commercial activity, distinguishing it from cases involving admission limited to the financially independent.

taxespropertyreligious liberty

The case concerned whether the City of Ottumwa, operating under the commission form of government in chapter 363B of the Iowa Code, could enact ordinances abolishing its Board of Park Commissioners that had been established under chapter 370. The plaintiffs, members of the park board, challenged the council's action via certiorari, and the trial court ruled the council exceeded its authority. The Iowa Supreme Court affirmed, holding that the mandatory provisions of both chapters could coexist without one repealing the other by implication, that chapter 363B lacked any exception authorizing abolition by ordinance (unlike the council-manager provisions in chapter 363C), and that the statutes should be construed to permit cooperative jurisdiction over parks rather than exclusive council control. The decision rested on principles of statutory construction disfavoring implied repeals and limiting judicial alteration of legislative text.

business & regulatoryprocedure

This case involves an appeal from the denial of a motion to correct a divorce decree through a nunc pro tunc order in Headley v. Headley. The divorce decree awarded the wife $60 per week in alimony until the husband remarried or died, but the parties and their attorneys had agreed the alimony would continue until the wife remarried or died. The Iowa Supreme Court reversed the denial and remanded the case, holding that the trial court must determine whether the decree contained an evident mistake by examining the original court's intention, potentially with testimony from the judge who entered the decree. The court reasoned that nunc pro tunc corrections are available to fix evident mistakes even after the term has ended, based on record or non-record evidence showing the discrepancy between intent and the entered order.

family lawprocedure