Justia Injury Law Opinion Summaries

Articles Posted in Iowa Supreme Court

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In this civil action filed against the police investigator, the prosecutors, and the municipalities that investigated and prosecuted a criminal case in which Plaintiff was eventually acquitted the Supreme Court affirmed in part and reversed in part the judgment of the district court denying Defendants' motions to dismiss, holding that the district court erred in concluding that Baldwin v. City of Estherville, 951 N.W.2d 259 (Iowa 2018), displaced the judicial process immunity. Specifically, the Court held (1) the district court erred in part in denying the prosecutor defendants' motion to dismiss because the judicial process immunity barred all claims in the petition against the prosecutors and the county except for a claim relating to an ethics complaint; and (2) the district court correctly denied the motion to dismiss with respect to the police defendants' argument regarding the judicial process immunity but erred in denying the police defendants' motion to dismiss Plaintiff's defamation claim. View "Venckus v. City of Iowa City" on Justia Law

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The Supreme Court affirmed in part and reversed in part the order of the district court granting summary judgment to Defendants on all claims in this employment case, holding (1) Plaintiff's direct civil action under Iowa Code 70A.28(5), the whistleblower statute, is not precluded by the availability of an administrative remedy; and (2) the district court correctly granted summary judgment on Plaintiff's claims of age discrimination and intentional infliction of emotional distress. Specifically, the Court held (1) section 70A.28(5) expressly creates an independent cause of action in the alternative to administrative remedies under Iowa Code chapter 17A, and therefore, the district court erred when it determined that judicial review following the administrative process was the exclusive means to seek redress for alleged retaliation against a whistleblower; (2) the district court did not err in determining that Plaintiff failed to present sufficient evidence from which a reasonable jury could infer age discrimination was the real reason for Plaintiff's termination; and (3) the district court did not err in granting summary judgment on Plaintiff's intentional infliction of emotional distress claim because none of Defendants' conduct was sufficiently egregious to satisfy the "outrageousness" prong. View "Hedlund v. State" on Justia Law

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The Supreme Court answered questions certified to it by the United States District Court for the Northern District of Iowa, holding, among other things, that a municipality can assert qualified immunity to a claim for damages for violation of the Iowa Constitution based on its officers' exercise of "all due care." Specifically, the Supreme Court held (1) the due care exemption under Iowa Code 670.4(1)(c) could provide the City immunity; (2) section 670.4(1)(e) precludes an award of punitive damages against the municipality that employed the constitutional tortfeasor; (3) in a Godfrey v. State, 898 N.W.2d (Iowa 2017), action a court cannot award attorney fees against the municipal employer of the constitutional tortfeasor unless there is a statute expressly allowing such an award; and (4) it is appropriate to retroactively apply this Court's conclusion that in a Godfrey action, common law attorney fees may be available against the municipal employer of the constitutional tortfeasor. View "Baldwin v. City of Estherville, Iowa" on Justia Law

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The Supreme Court affirmed in part and vacated in part the decision of the court of appeals affirming the judgment of the district court modifying a judgment for civil conspiracy following a jury trial, holding that the district court did not abuse its discretion in granting the motion to amend the judgment. Jeffrey Anderson commenced an action against Dean and Carol Anderson and Anderson Tooling, Inc. (ATI) alleging, among other claims, tortious discharge. Dean, Carol, and ATI filed several counterclaims. ATI sued Lori and brought a claim against Lori and Fabrication & Construction Services Inc. (FabCon) for, among other claims, conspiracy. Damages against Jeff totaled $772,297.72. The district court subsequently granted ATI's motion to modify the judgment to make Lori and FabCon jointly and severally liable for the $772,297.72 judgment. As relevant to this appeal, the court of appeals reversed the district court's order imposing joint and several liability on Lori and FabCon, determining that a conspiracy did not exist for Lori and FabCon to join. The Supreme Court vacated the court of appeals's judgment in part, holding that the district court did not abuse its discretion in granting the motion to amend the judgment. View "Anderson v. Anderson Tooling, Inc." on Justia Law

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The Supreme Court affirmed the judgment of the district court granting an employer's workers' compensation insurance carrier's motion to dismiss Plaintiffs' common law tort claim and ruling that Iowa Code 517.5 was constitutional, holding that the statute is not violative of equal protection, inalienable rights, or due process under article I, sections 1, 6, and 9 of the Iowa Constitution. Plaintiffs, employees and former employees of an Iowa manufacturing company, brought this action alleging that the insurance carrier failed to conduct or negligently conducted an insurance inspection at their employer's manufacturing facility, causing serious health problems for Plaintiffs. The insurance carried moved to dismiss the petition under section 517.5, which provides that "no inspection of any place of employment made by insurance company inspectors...shall be the basis for the imposition of civil liability upon the inspector or upon the insurance company..." The district court dismissed the actions after determining that the provision was constitutional. The Supreme Court affirmed, holding that there is no claim for negligent inspection against a workers' compensation carrier. View "Clark v. Insurance Co. State of Pennsylvania" on Justia Law

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In this tort action, the Supreme Court affirmed the judgment of the district court compelling Defendants to produce police investigative reports without a protective order preventing disclosure to the public, holding that the district court properly balanced the competing interests in confidentiality and transparency through its time limit, a carve-out for police internal review records, and directives to handle remaining confidentiality issues by redaction or further proceedings. An African-American motorist was rendered a quadriplegic from being shot at by a Caucasian police officer who had stopped the motorist. The police department released the dash cam video of the incident to the public, and the video went viral on social media. Plaintiffs, the injured motorist and his wife, filed suit against the police officer and City. When Plaintiffs sought discovery of the police investigative reports Defendants refused to produce the documents without a protective order prohibiting disclosure to the media or other nonparties. The district court denied the motion for protective order but limited the order compelling production to reports prepared within ninety-six hours of the incident. The Supreme Court affirmed, holding that the police investigative reports were not exempt from public disclosure under Hawk Eye v. Jackson, 521 N.W.2d 750 (Iowa 1994). View "Mitchell v. City of Cedar Rapids" on Justia Law

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The Supreme Court affirmed the judgment of the district court entering judgment against a commercial general liability (CGL) insurer on a homeowners’ insurer’s lawsuit seeking reimbursement for the amount it paid to settle a death claim, holding that the district court correctly interpreted the CGL insurance contract, and substantial evidence supported the court’s factual findings on potential liability and the reasonableness of the settlement. A dentist and his wife formed a limited liability company (LLC) that held title to investment properties, including a farmhouse. An accidental shooting at the farmhouse resulted in a death, and a death claim followed. The dentist had purchased homeowners liability insurance and CGL insurance from separate insurers. The CGL insurer denied coverage. The homeowners’ insurer settled the death claim for $900,000. Thereafter, the homeowners’ insurer filed this action seeking subrogation from the CGL insurer. The district court entered judgment against the CGL insurer for $450,000. The Supreme Court affirmed, holding that the LLC, as owner of the farmhouse, had potential liability under a premises liability theory for a dangerous condition and that the CGL insurer, as coinsurer of the farmhouse property, was obligated to indemnify the homeowners’ insurer for half of the $900,000 settlement. View "Metropolitan Property & Casualty Insurance Co. v. Auto-Owners Mutual Insurance Co." on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the ruling of the district court denying Plaintiff’s motion for a new trial after the jury returned a unanimous verdict finding that Defendant was not negligent, holding that Plaintiff was not prejudiced by the district court’s failure to respond in the affirmative to a certain jury question. Plaintiff suffered a disabling stroke while confined in a halfway house. Plaintiff sued both the halfway house and an attending emergency room physician at a nearby hospital. Plaintiff settled with the halfway house before trial, and the case proceeded to trial against the physician. During deliberations, the jury asked, “If we attribute 25% fault to [the physician] and 75% to [the halfway house] would [the plaintiff] only get 25% since [the halfway house] has been released?” The district court answered by directing the jury back to the original instructions, which did not explain the effect of any fault allocation. The jury returned a verdict finding Defendant not negligent. On appeal, Plaintiff argued that the district court should have answered “yes” to the jury’s question. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court probably should have given an affirmative answer but that there was no prejudice. View "Mumm v. Jennie Edmundson Memorial Hospital" on Justia Law

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The Supreme Court affirmed the decision of the district court ordering Defendant to pay restitution to the City of Davenport for damage to patrol vehicles after Defendant pleaded guilty to criminal mischief and eluding an officer, holding that a government entity may, under the right circumstances, be a victim under the Iowa criminal restitution statute, Iowa Code chapter 910, under this Court’s precedents. On appeal, Defendant conceded that the Davenport police vehicles incurred damage when police officers attempted to stop him during a high-speed chase but argued that damage to police cars from a chase of a fleeing suspect is not recoverable under Iowa’s restitution statute. The Supreme Court affirmed, holding (1) under the causation standard in the Restatement (Third) of Torts, the damage to the police vehicles would be within the scope of liability in a negligence action against Defendant; (2) the firefighter’s rule has no application in this case; and (3) the express legislative adoption of limited restitution for emergency response costs in drunk driving cases under Iowa Code 910.1(4) does prevent a restitution to the City of Davenport in this case. View "State v. Shears" on Justia Law

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The Supreme Court reversed a $1900 fine-based restitution award ordered by the district court after Defendant pleaded guilty to theft of a student backpack as punitive and unsupported by substantial evidence, holding that the scope-of-liability analysis in sections 29 and 33 of the Restatement (Third) of Torts: Liability for Physical and Emotional Harm applies in criminal restitution determinations. The operator of a training course for commercial truck driver imposed a $1900 fine on its student for the loss of a study guide. Defendant stole a backpack from the student’s parked car that contained the study guide. The student did not pay the fine. The district court concluded that $1900 far exceeded the actual cost to print the guide but ordered Defendant to pay that amount in restitution to the victim. The Supreme Court reversed after adopting the scope-of-liability analysis in the Restatement (Third) of Torts for criminal restitution cases, holding that the district court erred by awarding the amount of $1900 without substantial evidentiary support. View "State v. Roache" on Justia Law