David Wiggins

In State v. Marin, the defendant was charged with two counts of first-degree murder after confessing to killing two people and raised a defense based on involuntary intoxication from drugs and alcohol. The district court refused to give the defendant's proposed jury instruction distinguishing involuntary intoxication as a complete defense and instead used a standard intoxication instruction that did not differentiate between voluntary and involuntary intoxication, while also providing a diminished responsibility instruction. The court of appeals addressed the involuntary intoxication issue on the merits, but the Iowa Supreme Court held that the defendant failed to preserve error on whether involuntary intoxication constitutes a complete defense to criminal liability. The court affirmed the district court's judgment, concluding that the given instructions, read together, fairly informed the jury that intoxication could negate the specific intent, premeditation, and deliberation required for first-degree murder. The decision vacated the portion of the court of appeals ruling addressing the unpreserved claim but otherwise upheld the outcome.

criminal lawprocedure

The case involved Jane Doe challenging the Iowa Department of Human Services' decision to place her on the central child abuse registry after finding she committed child abuse by failing to properly supervise her child through repeated exposure to the child's domestically abusive father in 2001 and 2002. The district court had affirmed the agency's final decision. The Iowa Supreme Court reversed and remanded, holding that Iowa Code section 232.71D does not authorize placement on the registry for the specific form of child abuse defined as failure to provide proper supervision under section 232.68(2)(d) and rule 441-175.21, because the legislature omitted that category from the enumerated grounds for registry placement in section 232.71D(3)(f).

family law

The case involved the Iowa Supreme Court Attorney Disciplinary Board charging attorney Mark A. Templeton with violations of the Iowa Rules of Professional Conduct after he was caught repeatedly looking into the windows of a residence occupied by young women, admitting to a long-standing problem with such behavior for sexual gratification. On de novo review, the court found that Templeton violated one ethical rule related to his misconduct. The court decided to suspend his law license indefinitely with no possibility of reinstatement for three months, requiring a professional fitness evaluation before any reinstatement, rather than the two-year suspension recommended by the commission. The reasoning centered on the nature of the violation, protection of the public, deterrence, Templeton's fitness to practice, and comparisons to sanctions in similar cases involving criminal conduct or sexual misconduct.

criminal lawprocedure

The case concerned whether Iowa’s Public Employment Relations Act (PERA) protected a public employee, James Sikora, from discipline after he negotiated higher wages for himself and fellow crew members with the private Clay County Fair Board while also working part-time there. The Public Employment Relations Board found the activity protected and ruled the county committed a prohibited practice by terminating Sikora; the district court affirmed. The Iowa Supreme Court reversed, holding that PERA’s protections apply only to concerted activities directed at a public employer, not a private one, because the statute’s text and purpose are narrower than the National Labor Relations Act and are limited to fostering harmonious relations between the government and its own employees. The court therefore remanded with instructions to dismiss the complaint.

labor & employment

The case involved Bank of the West suing to collect on a defaulted loan and related guaranties from Acme Land Company and several individual and corporate guarantors, including spouses Christine Walters and Phyllis Kline. The spouses asserted that the bank violated the Equal Credit Opportunity Act by requiring their guaranties solely due to their marital status rather than insufficient creditworthiness of other parties. The district court allowed the ECOA violations to be raised as affirmative defenses despite the counterclaims being time-barred, rendering the guaranties unenforceable, and granted summary judgment to the spouses. On appeal, the Iowa Supreme Court affirmed, holding that guarantors qualify as applicants under the ECOA and can use violations as affirmative defenses, with no genuine issue of material fact on creditworthiness because the bank failed to present timely supporting evidence.

business & regulatorycivil rightsprocedure

The case involved the Iowa Supreme Court Attorney Disciplinary Board charging attorney Ross G. Hauser with multiple violations of ethical rules for neglecting a client's dissolution-of-marriage case. Hauser failed to attend the trial, resulting in a default judgment against the client, did not communicate properly, and ignored requests for information from the board. The court reviewed the matter de novo and, considering Hauser's extensive prior disciplinary record for similar issues, decided to suspend his law license indefinitely with no possibility of reinstatement for six months, requiring proof of fitness to practice and accounting for client fees before reinstatement. The reasoning centered on the need to protect the public from unfit lawyers based on the pattern of neglect and non-compliance.

procedurefamily law

The case involved a dispute between NevadaCare, a Medicaid HMO, and the Iowa Department of Human Services over a series of risk-based contracts from 1998 to 2005 under which DHS paid NevadaCare monthly capitation rates for providing managed care services to Medicaid enrollees. NevadaCare claimed DHS breached the contracts by using improper actuarial methods to set the rates, seeking damages for alleged underpayments. The Iowa Supreme Court held that DHS did not breach any contracts because the rates were calculated in compliance with federal and state regulations using appropriate methodologies, and NevadaCare had reviewed and accepted the rates before signing. On attorney fees, the court found that only the explicit fee-shifting clause in the 2004-2005 contract authorized recovery, while indemnity provisions in prior contracts did not clearly intend to shift fees, leading to reversal of the district court's broad fee award and remand for recalculation limited to that one contract.

business & regulatoryhealthcare

This case involved a dispute in a divorce modification proceeding over whether payments for health and dental insurance required by the original dissolution decree were modifiable spousal support or an unmodifiable property settlement. The Iowa Supreme Court held that the payments constituted spousal support and were therefore modifiable upon a showing of changed circumstances, such as the recipient's remarriage and new insurance coverage. The court reasoned that the payments' purpose was to provide ongoing medical support rather than to divide assets, and it reversed the district court and court of appeals rulings that had treated the obligation as a fixed property division. The decision terminated the ex-husband's payment obligation effective August 1, 2008, required repayment of amounts paid after that date, and affirmed the denial of attorney fees to the ex-wife.

family law

In Zimmer v. Vander Waal, the plaintiffs sought to hold the owners of a trailer vicariously liable under Iowa’s owner consent statute for injuries caused in a collision between a motor vehicle and a farm tractor pulling the trailer. The Iowa Supreme Court affirmed the lower courts’ dismissal of the claims against the trailer owners. The court reasoned that the statute imposes liability only on owners of “motor vehicles” driven with consent, and a trailer does not meet the statutory definition of a motor vehicle whether attached or unattached, as it is instead classified as a “combination of vehicles” or trailer. The decision was based on the plain language of the statute and rules of statutory construction, without expanding its scope beyond the terms used by the legislature.

torts & liability

The case concerned the allocation of workers' compensation death benefits following the work-related death of employee Raul Perez Rojas, with claims by his U.S. spouse and child as well as five children in Mexico and their mother, raising issues over the validity of a Mexican marriage, paternity, and the application of a statutory 50% reduction in benefits for nonresident aliens under Iowa Code section 85.31(5). The workers' compensation commissioner had awarded and equitably divided benefits among all claimed dependents while accounting for the reduction, a decision affirmed by the district court and court of appeals. The Iowa Supreme Court ruled that the reduction statute is constitutional and does not conflict with other provisions, that the commissioner erred by allocating benefits to the Mexican children's mother and by considering the reduction during allocation, and that benefits must instead be allocated equitably among qualifying dependents without regard to the reduction. The court based its holdings on statutory interpretation distinguishing the determination of payable amounts from the separate process of allocation under sections 85.31 and 85.43, and it remanded for reallocation consistent with those principles.

labor & employmentimmigrationfamily lawprocedure

This case concerns whether a juvenile court properly terminated a father's parental rights under Iowa Code section 232.116. The Iowa Supreme Court conducted a de novo review and affirmed the juvenile court's termination order, vacating the court of appeals' reversal. The court applied a statutory three-part framework, first determining that the State proved an enumerated ground for termination, then finding that termination was in the child's best interests, and finally concluding that no exception applied under section 232.116(3)(c) because the father and child lacked a close relationship.

family law

June Lyman was convicted of second-degree murder for fatally shooting her husband Leo in 2006 after a history of marital discord and prior allegations against him. On appeal, she challenged the district court's finding that she was competent to stand trial, the lack of a specific-intent jury instruction for second-degree murder, and her trial counsel's failure to object to evidence and arguments referencing her repeated invocations of the right to remain silent after Miranda warnings. The Iowa Supreme Court affirmed the conviction, holding that the competency determination was correct, that second-degree murder does not require a specific-intent instruction, and that the record was inadequate to resolve the ineffective-assistance claim on direct appeal.

criminal lawcivil rightsprocedure

The case involved Rasheem Bogan, a fourteen-year-old convicted of first-degree murder in a drive-by shooting. The Iowa Supreme Court granted further review to address whether Bogan should have received Miranda warnings before police questioned him at school. The court found that Bogan was in custody during the interrogation based on objective circumstances, so Miranda warnings were required beforehand. Because the warnings were not given, the court reversed the district court's judgment and remanded for a new trial, while vacating the court of appeals' decision on joinder.

criminal lawprocedure

This case involved a taxpayer's lawsuit against the Knoxville Community School District and its superintendent challenging the award of a contract for stadium lighting replacement to a bidder using Musco products, alleging violations of public bidding laws under Iowa Code and fraud; the plaintiff later amended to pursue only certiorari and fraud claims against Musco alone after dismissing the government defendants. The district court dismissed the action, finding no proper basis for certiorari against a private supplier without a government tribunal or officer, and imposed sanctions on the plaintiff's attorney; the court of appeals affirmed. The Iowa Supreme Court affirmed the dismissal, reasoning that certiorari under Iowa Rule of Civil Procedure 1.1401 requires an inferior tribunal, board, or officer and cannot proceed solely against a non-governmental entity like a supplier, but vacated the sanctions award and remanded for the district court to reassess sanctions limited to the attorney's continuation of the case after the government parties were dismissed.

procedurebusiness & regulatory

In GE Money Bank v. Morales, a credit card issuer sued a debtor in small claims court for an unpaid balance of $2,084.76 on a store credit card, which the debtor denied owing. The small claims court admitted the bank's faxed billing statements over hearsay and foundation objections, treated the verified account as the plaintiff's appearance, and entered judgment for the bank; the district court affirmed. On discretionary review, the Iowa Supreme Court affirmed, holding that a verified account filing satisfies the plaintiff's appearance requirement under Iowa Code section 631.10 and that the billing statements were properly considered because they were reliable evidence of the type prudent persons rely on for serious affairs. The court reasoned that small claims proceedings are designed to be simple and informal, so technical evidence rules should not exclude reliable proof when the defendant offers no rebuttal.

procedurebusiness & regulatory

In State v. Canal, an eighteen-year-old defendant was convicted under Iowa Code section 728.2 of knowingly disseminating obscene material to a minor after sending an email containing a photograph of his erect penis to a fourteen-year-old classmate. The Iowa Supreme Court affirmed the conviction and rejected the claim of ineffective assistance of counsel. The court held that the evidence was sufficient to support the jury's finding of obscenity based on the instructions defining the term, which incorporated contemporary community standards for material suitable for minors, appeal to prurient interest, and lack of serious value. It further reasoned that the given instructions adequately informed the jury that mere nudity is not obscene, so counsel had no duty to request additional language on that point.

criminal law

This case concerns whether Hills Bank could enforce a limited continuing guaranty signed by Cynthia Converse for a promissory note originally executed by Daverse, Inc., Lew Converse, and David E. Moore, and whether Converse, if liable as a secondary obligor, could seek reimbursement from the principal obligor or contribution from a coguarantor after the bank released other parties. The district court granted summary judgment enforcing the guaranty against Converse and denying her reimbursement and contribution claims. The court of appeals found genuine issues of material fact on enforceability of the guaranty but affirmed the denial of reimbursement and contribution. On further review, the Iowa Supreme Court held that genuine issues of material fact existed both as to whether the bank could enforce the guaranty against Converse and as to her rights of reimbursement and contribution, because common liability among the guarantors existed at the time of the borrower's default even if later releases affected that status; the court therefore reversed the district court and remanded for further proceedings.

business & regulatoryprocedure

The case involved an attorney who applied for a waiver of the statutory title plant requirement to become a participating abstractor in Iowa's Title Guaranty Program administered by the Iowa Title Guaranty Division of the Iowa Finance Authority. The Iowa Land Title Association intervened in opposition, but the agency granted the waiver after a hearing. On judicial review, the district court affirmed the agency decision, and the Iowa Supreme Court affirmed as well. The court held that the agency correctly interpreted the terms 'hardship' and 'public interest' in Iowa Code section 16.91(5) without deference to the agency's construction, and that the incomplete agency record prevented review of the decision for substantial evidence, requiring affirmance on that issue.

propertybusiness & regulatory

U.S. Bank sued Alisa Barbour to recover an alleged $13,707.60 credit card balance plus interest, attaching a statement and later an amended bill of particulars consisting of several years of account statements. After the district court denied Barbour's motion to dismiss, a second judge granted her pre-answer motion to recast the petition with a consecutively numbered bill of particulars starting from a zero balance; when the bank did not comply, a third judge dismissed the action as a sanction. The Iowa Supreme Court reversed and remanded, holding that the first ruling was correct because the amended bill substantially complied with Iowa Rule of Civil Procedure 1.420 by providing sufficient identifying information for each transaction and that the failure to start from a zero balance did not warrant dismissal before discovery and answer.

procedure

The case involved a workers' compensation claim by Angela Davis against her employer Drake University for benefits related to three separate back injuries sustained during her employment from 2001 to 2004. The workers’ compensation commissioner awarded benefits for the injuries, which the district court largely affirmed, including on issues of procedural due process and evidence sufficiency, while also addressing a credit for group plan benefits. On appeal, the Iowa Supreme Court affirmed the agency's decision that permanent total disability benefits were not subject to apportionment under the workers’ compensation statutes and that substantial evidence supported the awards, but reversed the apportionment applied to the 2001 and 2002 injuries and vacated the district court's ruling on the credit issue. The court held that the agency had not considered the credit question at the administrative level, so the district court should not have addressed it, and remanded for further proceedings.

labor & employmentprocedure