This case concerned whether a worker injured by a coworker's truck during an on-the-job interaction involving "wiggling his butt" and alleged horseplay was entitled to workers' compensation benefits from his employer, Xenia Rural Water District. The Iowa Supreme Court determined that the employee has the burden to show his actions did not substantially deviate from employment, remanding the case to the industrial commissioner for that assessment under the existing record. It further held that the statutory affirmative defense for willful injury by a third party for personal reasons did not apply here, as the incident stemmed from the work environment rather than external personal motives.
The case involved a dispute over an equipment lease agreement for beverage carts between C & J Vantage Leasing Co. and Outlook Farm Golf Club, where Royal Links arranged for Outlook to lease carts from C & J with offsetting advertising payments that Royal Links later stopped making, leading Outlook to cease its lease payments. C & J sued for breach of contract, and Outlook raised an affirmative defense and counterclaim of fraudulent misrepresentation based on an alleged agency relationship with Royal Links. The district court granted summary judgment to C & J, but the Iowa Supreme Court reversed, holding that genuine issues of material fact existed regarding fraud in the inducement that precluded summary judgment, while also clarifying that the transaction was a finance lease rather than a secured transaction and overruling contrary precedent on that point.
The case involved Rory Reilly challenging the Iowa Department of Corrections' revocation of his earned time credits after his removal from a sex offender treatment program due to a failed polygraph test, which extended his sentence. The Iowa Supreme Court ruled that while the application of the relevant statute did not violate ex post facto or retroactivity principles, the procedures used to remove Reilly from the program violated his due process rights under the Iowa and U.S. Constitutions. The court reasoned that inmates have a liberty interest in earned time that requires procedural protections before deprivation, although polygraph examinations can be used as one factor in removal decisions, and it sustained the writ of certiorari while remanding for remedy.
In this case, inmate John Dykstra challenged the Iowa Department of Corrections' revocation of his earned time credits after he refused to participate in a sex offender treatment program (SOTP), which was required based on unadmitted factual allegations from his prior simple assault plea and other history. The Iowa Supreme Court held that IDOC's classification requiring SOTP participation implicates a protected liberty interest, entitling inmates to due process protections under Wolff v. McDonnell. The court found that Dykstra was denied due process because IDOC relied on unproven allegations from minutes of testimony without adequate procedural safeguards, such as notice or an opportunity to contest the facts. The court sustained the writ of certiorari and remanded for consideration of the appropriate remedy.
The case involved Kenneth Waters, convicted of operating while intoxicated (third offense) and assault with intent to commit sexual abuse, who was serving only the OWI sentence after discharging the assault sentence when the Iowa Department of Corrections required him to participate in a sex offender treatment program. When Waters refused, the department halted his accrual of earned time under Iowa Code section 903A.2, extending his tentative discharge date, and he sought postconviction relief challenging the action on ex post facto, retroactivity, and statutory authority grounds. The Iowa Supreme Court held that the department acted within its authority, ruling that the 2005 amendment to section 903A.2 was a clarification of prior law that did not violate the Ex Post Facto Clause and that the statute allows denial of earned time on any sentence being served if an inmate refuses required treatment. The court annulled the writ after finding no constitutional or statutory violation.
Michael Anderson was convicted of sexual exploitation of a minor in Marshall County and received a two-year prison sentence along with a ten-year special sentence under Iowa Code section 903B.2 requiring supervision as if on parole. He was also serving longer consecutive sentences from a separate Story County conviction that ran concurrently. Anderson sought to begin the special sentence after discharging only the Marshall County term, but the district court ruled it would start only after all sentences ended. The Iowa Supreme Court reversed, holding that the statute's plain language requires the special sentence to commence upon completion of the sentence imposed for the underlying criminal offense, irrespective of any concurrent sentences.