Articles Posted in Iowa Supreme Court

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At issue was whether property owners’ state-law damage claims against the railroad bridge owners alleging that the design and operation of the railroad bridges resulted in flood damage to other properties were preempted by the Federal Interstate Commerce Commission Termination Act (ICCTA), 49 U.S.C. 10501(b). Plaintiffs, property owners in Cedar Rapids, sued the owners of certain railroad bridges across the Cedar River alleging that their efforts to protect the bridges from washing out exacerbated the effects of the 2008 flooding for other property owners. The district court granted Defendants’ motion for judgment on the pleadings, concluding that the ICCTA expressly preempted Plaintiffs’ state law claims. The Supreme Court affirmed, holding that the ICCTA did indeed preempt Plaintiffs’ action. View "Griffioen v. Cedar Rapids" on Justia Law

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The Supreme Court reversed and remanded the case to the district court for further proceedings, holding that because the district court did not make specific findings of fact relative to any plaintiff when concluding that Iowa Code 657.11(2), as applied to Plaintiffs, violated Iowa Const. art. I, 1, the issue could not be resolved on this record. Plaintiffs, the owners and/or residents of real estate located near the confined animal feeding operations (CAFOs), brought this action claiming that Defendants were negligent in their operation of the CAFOs and that the CAFOs constituted a nuisance, entitling Plaintiffs to damages. Defendants filed a motion for summary judgment on the nuisance claims, asserting that section 657.11(2) barred the claims because Plaintiffs could not meet the requirements under the statute to recover the requested special damages against the CAFOs. The district court denied the motion, finding that section 657.11(2) was unconstitutional as applied to Plaintiffs because it denied Plaintiffs access to a remedy for their alleged injuries. The Supreme Court reversed and remanded with directions that the district court engage in a fact-based analysis by applying the three-prong test set forth Gacke v. Pork Xtra, LLC, 684 N.W.2d 168 (Iowa 2004). View "Honomichl v. Valley View Swine, LLC" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the district court granting summary judgment in favor of Defendants on Plaintiff’s claims challenging his termination. Plaintiff, a former chief administrative law judge of the Unemployment Insurance Appeals Bureau in Iowa Workforce Development (IWD), alleged retaliation under the whistleblower protection provisions of Iowa Code 70A.28 and that Defendants continued to retaliate against him when he sought other positions in state government. Plaintiff further alleged wrongful termination in violation of public policy based upon the same conduct. The district court granted summary judgment for Defendants, concluding that Plaintiff could not bring his claims because he failed to exhaust his administrative remedies available to merit employees. The Supreme Court reversed in part, holding (1) Plaintiff’s ability to bring a direct claim under section 71A.28 is not precluded by the availability of an administrative remedy under Iowa Code 8A.415; and (2) the district court correctly granted summary judgment on Plaintiff’s wrongful termination claim. View "Walsh v. Wahlert" on Justia Law

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Retaliatory discharge claims are not categorically reserved for at-will employees. A state administrative law judge (ALJ) brought suit alleging wrongful termination in violation of public policy after she was terminated for giving unfavorable testimony about the director of her division to the Iowa Senate Government Oversight Committee. The ALJ’s employment was covered by a collective bargaining agreement (CBA). The State filed a motion to dismiss, asserting that the common law claim of wrongful discharge is reserved for at-will employees. The district court agreed and dismissed the case. The court of appeals reversed, concluding that the ALJ’s status as a CBA-covered employee did not preclude her wrongful-discharge claim. The Supreme Court affirmed, holding that the common law tort of retaliatory discharge against public policy is generally available to contract employees. View "Ackerman v. State" on Justia Law

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The district court correctly granted summary judgment in favor Humboldt County on Plaintiff’s claim that the county was liable for the injuries she received when her vehicle went off the county road and into a ditch then struck a concrete embankment in the ditch based on the public-duty doctrine. The embankment in this case had been constructed by a private landowner and was on the private landowner’s land, but the county had a right-of-way easement where part of the embankment was located. In her complaint, Plaintiff alleged that the county should have caused the removal of the concrete embankment from the ditch. The Supreme Court affirmed the district court’s grant of summary judgment, holding that the public-duty doctrine is “alive and well in Iowa” and applies to the facts of this case. View "Johnson v. Humboldt County" on Justia Law

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The Supreme Court affirmed the decision of the district court affirmed the decision of the workers’ compensation commissioner that Claimant was not entitled to healing period benefits under Iowa Code 85.34(1). Claimant filed a petition seeking workers’ compensation benefits after developing bilateral carpal tunnel injuries allegedly arising out of and in the course of her employment with Employer. Employer admitted liability and authorized Claimant to undergo medical care with its chosen medical providers. Claimant, however, sought medical treatment from an unauthorized physician. The physician performed two surgeries on Claimant, and Employer refused to pay healing period benefits for the time Claimant was recovering from the unauthorized surgeries. The commissioner concluded that Claimant was not entitled to healing period benefits because Employer provided a valid authorization defense. The district court affirmed. The Supreme Court affirmed, concluding that where Claimant received unauthorized medical care she was not entitled to healing benefits. View "Brewer-Strong v. HNI Corp." on Justia Law

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At issue was negligence and defamation claims brought by two female parishioners and their spouses against a church based on sexual abuse and exploitation perpetrated on the women by the church pastor and the subsequent response by the governing body of the church. The district court granted summary judgment for the church on all claims except negligent supervision. The court then found that the negligent supervision claims brought by the female parishioners were barred by the statute of limitations. The Supreme Court affirmed in part and reversed in part, holding (1) the Religion Clauses of the Iowa and United States Constitutions barred two of the negligence claims brought against the church; (2) the First Amendment does not bar negligent supervision claims against religious entities, and while the relevant statute of limitations barred one parishioner’s claim of negligent supervision, it did not bar the other female parishioner’s negligent supervision claim; and (3) the district court properly dismissed the defamation claims. View "Bandstra v. Covenant Reformed Church" on Justia Law

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The Supreme Court remanded this case alleging negligence and products liability for a new trial, holding that statements made by Plaintiff’s counsel during closing arguments were prejudicial. On appeal, the Supreme Court reviewed numerous issues that arose during litigation between the estate of Larry Kinseth, who passed away from mesothelioma, and Weil-McLain, a boiler manufacturer whose products exposed Kinseth to asbestos. The jury awarded Kinseth's Estate compensatory and punitive damages. The Supreme Court remanded the case for a new trial, holding that to the extent the Estate’s counsel made repeated, deliberate references to Weil-McLain’s expenditures in defending this suit and other asbestos actions and issued instructions to use this case to send a message about such expenditures, counsel’s rhetoric prejudiced Weil-McLain. View "Kinseth v. Weil-McLain" on Justia Law

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The Supreme Court reversed the judgment of the district court granting summary judgment for Defendant, a bar, which was sued under Iowa’s dramshop statute after an alleged intoxicated person’s (AIP) vehicle struck the rear end of another vehicle. The driver of the struck vehicle alleged that the bar sold and served alcohol to the AIP when it knew or should have known the AIP was intoxicated or would become intoxicated. In granting summary judgment, the district court concluded that the undisputed evidence of serving three beers over four hours alone cannot create an inference that the bar knew or should have known that the AIP was intoxicated or would become intoxicated. The Supreme Court disagreed, holding that a genuine issue of material fact existed as to whether the bar knew or should have known that the AIP was or would become intoxicated when it served beer to her. View "Banwart v. 50th Street Sports, LLC" on Justia Law

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The City of Albia was statutorily immune from a homeowner’s nuisance claim stemming from reoccurring flooding in the basement of her home due to rainwater discharge from a storm sewer located near the home. The Supreme Court held (1) Iowa Code 670.4(1)(h), which grants immunity to municipalities for tort claims based on claims of negligent design and construction of public improvements and facilities, or failure to upgrade public improvements and facilities, bars those nuisance claims based on conditions created by public improvements and facilities designed and constructed pursuant to generally recognized engineering or safety standards in existence at the time of construction and without evidence that the harmful condition creating the nuisance was inherent in the operation of the improvement or facility itself or evidence of negligent conduct other than the designated conduct immunized under statute; and (2) because the homeowner in this case did not offer any evidence that the City’s storm sewer system was inherently dangerous beyond the dangers associated with failing to upgrade the pipe to accommodate increased water flow, or that the claim was otherwise based on conduct not given immunity, summary judgment on the homeowner’s nuisance claim was properly granted. View "Kellogg v. City of Albia" on Justia Law