Justia Injury Law Opinion Summaries

A fire severely damaged a restaurant that was owned by Plaintiffs. Plaintiffs made a claim to Defendant, the insurer of the restaurant, but Defendant denied the majority of the claim. Plaintiffs filed a breach-of-contract action against Defendant to recover under the insurance policy. A jury returned a verdict for Plaintiffs in the amount of $236,902. Defendant paid this amount plus interest and costs. Three months after judgment was entered, Plaintiffs filed this action against Defendant for “bad faith,” alleging that Defendant lacked an objectively reasonable basis for denying the claim. The district court granted Defendant’s motion for summary judgment, finding that the bad-faith action was barred by claim preclusion. The court of appeals reversed. The Supreme Court vacated the judgment of the court of appeals and affirmed the district court’s grant of summary judgment to Defendant, holding that, under the circumstances of this case, the final judgment in the breach-of-contract suit barred the later tort action for bad faith. View "Villarreal v. United Fire & Cas. Co." on Justia Law

Kevin Bryant, a salesperson at an auto dealership, was in the passenger seat of a car when Lori Parr, who was testing driving the car, made an illegal left turn, and the car was struck by a car driven by Robert Rimrodt. Bryant filed this lawsuit against Parr and Rimrodt, alleging that their negligence caused his personal injuries. The jury returned a special verdict finding Parr ninety-five percent at fault and Bryant five percent at fault. The jury initially awarded Bryant nearly $17,000 in past medical expenses but zero for pain and suffering. The parties agreed that the verdict was inconsistent, and the jury was instructed to resume deliberations to resolve the inconsistency. The jury subsequently awarded one dollar for pain and suffering but left the rest of the verdict unchanged. The court of appeals affirmed, concluding that the one dollar award remedied any inconsistency. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the district court, holding that the award of one dollar for pain and suffering was inconsistent with the award of nearly $17,000 for medical expenses incurred for the diagnosis and treatment of pain, and the inconsistency required a new trial. Remanded for a new trial on damages. View "Bryant v. Rimrodt" on Justia Law

Plaintiff was injured when he crashed his moped at a work site. Plaintiff sued Defendant, a contractor, alleging that his injuries were caused by the contractor’s negligence at the site. After a trial, the jury returned a verdict for Defendant, finding that Defendant was negligent but that his negligence was not the cause of Plaintiff’s damages. The court of appeals reversed and ordered a new trial, concluding that substantial evidence did not support the verdict. The Supreme Court vacated the judgment of the court of appeals and affirmed the judgment of the district court, holding (1) substantial evidence supported the jury verdict; (2) the jury’s answers to the verdict interrogatories were consistent with each other, and the jury’s verdict was consistent; (3) assuming the district court should have granted a directed verdict finding Plaintiff negligent, any such error was harmless; and (4) the district court did not abuse its discretion when it refused to grant Plaintiff’s motion for a new trial on the grounds that the verdict failed to administer substantial justice. View "Crow v. Simpson" on Justia Law

Dennis Smith was formerly employed by the College of Engineering at Iowa State University (ISU), where he was “subjected to wrongful conduct for an extended period of time in a job he had held for nearly a decade.” Smith filed suit against ISU and the State, alleging, inter alia, that he suffered retaliation for reporting managerial misconduct to ISU’s president. After a jury trial, Smith recovered $500,000 for intentional infliction of emotional distress and $784,027 under a whistleblowing statute. The court of appeals affirmed the intentional infliction of emotional distress award but set aside the statutory whistleblowing award, finding that Smith had failed to prove a causal relationship between his disclosures to the president and any actions of reprisal taken against him. The Supreme Court (1) affirmed the jury’s emotional distress award, holding that Defendants’ conduct toward Smith was outrageous and that the verdict was not excessive; and (2) reduced, but did not set aside, the district court’s award of damages under the whistleblowing statute, where the evidence supported the finding that Smith suffered retaliation for reporting managerial misconduct but where Smith’s loss of his job was not causally linked to his discussion with ISU’s president. View "Smith v. Iowa State Univ. of Sci. & Tech." on Justia Law

Russell Phillips, an employee of the Chicago Central & Pacific Railroad, filed a negligence action against the railroad. The jury returned a general verdict in favor of Phillips, and the district court awarded Phillips damages. The railroad paid Phillips the amount of the judgment but withheld a portion of the award to pay taxes allegedly due under the Railroad Retirement Act (RRTA). Phillips refused to execute a satisfaction of judgment, arguing that the railroad should have withheld any amount for tax purposes. Subsequently, the railroad moved for an order of satisfaction and discharge of judgment. The district court sustained the motion. The Supreme Court affirmed, holding (1) an award for time lost is subject to tax withholding under the RRTA; and (2) the railroad fully satisfied the judgment. View "Phillips v. Chicago Cent. & Pac. R.R. Co." on Justia Law

Plaintiff, who attended school in the New London Community School District, was fourteen years old when Gina Sisk, a teacher who also served as Plaintiff’s track coach, began to engage in improper sexual conduct toward Plaintiff. The alleged abuse occurred in the early 2000s. In 2012, Plaintiff filed a petition against the District asserting several tort claims. Defendants filed a motion for summary judgment, arguing that Plaintiff’s claims were barred by the statute of limitations in the pre-2007 Iowa Municipal Tort Claims Act (IMTCA). The district court denied Defendants’ motions. At issue before the Supreme Court was whether a discovery rule was available to Plaintiff. The Supreme Court reversed, holding (1) the common law discovery rule does not apply to claims under the pre-2007 IMTCA; (2) the limitations provision in Iowa Code 614.8A does not apply to individuals who were fourteen years or older when the alleged sexual abuse occurred; and (3) the absence of a discovery rule in the pre-2007 IMTCA does not violate the Iowa Constitution’s equal protection clause. View "Doe v. New London Cmty. Sch. Dist." on Justia Law

Grain Processing Corporation (GPC) operated a local corn wet milling facility in Muscatine. Plaintiffs, eight individuals who resided within one and one-half miles of GPC’s facility, filed a lawsuit on behalf of themselves and other similarly situated Muscatine residents, claiming that GPC’s operations caused harmful pollutants and noxious odors to invade their land. Plaintiffs based their claims on common law and statutory nuisance and the common-law torts of trespass and negligence. GPC filed a motion for summary judgment prior to class certification, claiming (1) Plaintiffs’ common law and statutory claims were preempted by the Federal Clean Air Act; (2) alternatively, the common law claims were preempted by the state statutory companion to the CAA; and (3) the issues raised by Plaintiffs were political questions. The district court granted summary judgment for GPC. The Supreme Court reversed, holding that Plaintiffs’ claims (1) were not preempted by the CAA; (2) were not preempted by Iowa Code 455B; and (3) were not subject to dismissal by operation of the political question doctrine. View "Freeman v. Grain Processing Corp." on Justia Law

Plaintiff was injured when she crashed on her bicycle while riding on a sidewalk abutting the grounds of the University of Iowa in Iowa City. Plaintiff filed a negligence action against the City, claiming that an alleged defect in the sidewalk caused the accident. The City filed a motion to add the State as a third-party defendant, citing the City’s ordinance requiring an abutting property owner to maintain the sidewalk in a safe condition. The district court granted the motion. The City then filed a cross-claim against the State seeking contribution. The district denied the State’s motion to dismiss the City’s cross-claim, concluding (1) the City’s contribution claim was not excluded from the Iowa Tort Claims Act (ITCA) and adequately pled a claim under the ITCA; and (2) an ordinance can establish a duty, the breach of which supports a negligence claim. The Supreme Court affirmed, holding (1) the City’s ordinance was not preempted by Iowa Code 364.12(2); (2) the potential imposition of indemnity under the ordinance does not give rise to an unlawful tax; and (3) the City’s claim against the State was within the scope of ITCA for purposes of waiver of sovereign immunity. View "Madden v. City of Iowa City" on Justia Law

Plaintiff, the workers’ compensation commissioner, filed an amended petition against the State and individual defendants named in their official and individual capacities. Plaintiff’s claims stemmed from his refusal to resign upon the Governor-elect’s demand for resignation and Plaintiff's subsequent reduction in salary. The attorney general provided a certification certifying that the individual defendants were acting within the scope of their employment at the time of the allegations contained in the amended petition, and therefore, certain immunities applied to various counts of the petition. The district court dismissed those counts alleging that the individual defendants acted outside the scope of their employment, concluding that the attorney general’s certification was applicable to all of Plaintiff’s claims. The Supreme Court reversed, holding (1) the Iowa Tort Claims Act applies only to torts committed by state employees when acting within the scope of their employment; and (2) therefore, the attorney general’s certification was not applicable to Plaintiff’s common law claims alleging that the individual defendants acted outside the scope of their employment. Remanded. View "Godfrey v. State " on Justia Law

Rick Bertrand, a Republican, and Rick Mullin, a Democrat, were candidates for the Iowa Senate in the 2010 general election. During campaigning, Mullin approved of a television commercial, titled “Secrets,” which stated that Bertrand was a sales agent for a drug company that marketed a dangerous sleep drug to children. After the commercial aired, Bertrand filed a lawsuit against Mullin seeking injunctive relief and monetary damages based on defamation. The jury returned a verdict of $31,000 against Mullin and $200,000 against the Iowa Democratic Party. Mullin appealed, contending that the district court erred by failing to grant his motion for judgment notwithstanding the verdict. The Supreme Court reversed the judgment of the district court and dismissed the case, holding that sufficient evidence did not support a finding of actual malice. View "Bertrand v. Mullin" on Justia Law