Justia Injury Law Opinion Summaries

While she was a business guest at the Courtyard by Marriott, Plaintiff slipped and fell on its icy sidewalk, breaking her ankle. After a trial, the jury found Marriott ninety-eight percent at fault and awarded Plaintiff damages. The Supreme Court reversed and ordered a new trial, holding that the district court erred by (1) submitting a negligent-training theory without testimony on the standard of care for training employees on deicing or breach of that standard, and (2) instructing the jury that an icy walkway violated a private safety code governing slip-resistant construction materials. View "Alcala v. Marriott Int’l, Inc." on Justia Law

In this appeal, the issue this case presented for the Iowa Supreme Court's review was whether an employer’s matching contributions to an employee’s 401k plan should be considered part of weekly earnings for purposes of calculating workers’ compensation weekly benefits. The Court had to also decide whether the district court erred in affirming the workers’ compensation commissioner’s decision on the amount of healing period benefits owed, the extent of permanent disability, and the penalty to be awarded. After review of the specific facts of this case, the Court concluded that an employer’s matching contributions to an employee’s 401k plan were not weekly earnings for purposes of calculating workers’ compensation weekly benefits. The Court also concluded the district court did not err in affirming the decision of the commissioner with respect to the extent of permanent disability. However, the district court erred in affirming the date when healing period benefits commenced, the date when the healing period benefits ended, and the date when permanent partial disability (PPD) benefits commenced. The case was remanded to the district court: (1) to affirm the commissioner’s findings as to the weekly benefit rate and the extent of permanent partial disability; and (2) for a redetermination of the date when healing period benefits commenced, of the date when healing period benefits ended and PPD benefits commenced, and for a recalculation of penalty and interest benefits. View "Evenson v. Winnebago Insudtries, Inc." on Justia Law

Paul Gray’s surviving spouse, Brenna, and daughter, O.D.G., filed suit against Dr. Daniel Baldi and several Iowa healthcare providers, alleging that Defendants negligently treated Paul during his struggle with substance abuse. Paul’s estate asserted a claim for wrongful death, Brenna asserted a loss of spousal consortium, and O.D.G., who was born several months after Paul’s death, asserted a loss of parental consortium. The district court granted summary judgment in favor of Defendants, concluding that Plaintiffs brought suit after the applicable statutes of limitations expired. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) erred in granting summary judgment on O.D.G.’s parental consortium claim, as a child conceived but not yet born at the time of their parent’s death can bring a parental consortium claim after the child is born; but (2) did not err in granting summary judgment on the wrongful-death and spousal consortiums claims, as, even if the discovery rule can extend the time to file wrongful-death claims under Iowa Code 614.1(9)(a), the wrongful-death and spousal consortium claims were untimely under the circumstances of this case. Remanded. View "Estate of Gray v. Baldi" on Justia Law

Appellant pleaded guilty to one count of criminal transmission of HIV. Appellant later filed an application for postconviction relief alleging that his trial counsel provided ineffective assistance by allowing Appellant to plead guilty to a charge for which there was no factual basis. The lower courts denied relief, but the Supreme Court reversed and remanded the case. On remand, the State dismissed the charges against Appellant. Appellant then filed an action under Iowa Code 663A claiming that he was wrongfully imprisoned by the State and was entitled to compensation. The district court granted the State’s motion to dismiss, concluding that Appellant was not entitled to relief because he had pled guilty in a criminal case that provided the basis for the imprisonment. The Supreme Court affirmed, holding that section 663A.1(1)(b) categorically excludes all persons who plead guilty from Iowa’s wrongful imprisonment statute, and therefore, Appellant was not entitled to pursue a claim for wrongful imprisonment under section 663A. View "Rhoades v. State" on Justia Law

An SUV was being driven in the wrong direction on a highway when it collided with a semi-tractor-trailer. The SUV was totaled, and the SUV’s driver was killed. Second later, a motorcyclist ran into the SUV that was still in the middle of the highway. The drivers of both the semi and the motorcycle suffered injuries. The drivers jointly filed a petition for declaratory judgment against the insurer of the SUV asking the district court to declare that there had been two accidents for purposes of the insurance policy’s per-accident limit on bodily injury liability. The district court granted summary judgment for the insurer, concluding that the injuries suffered by the plaintiffs arose from one accident. The Supreme Court affirmed, holding that, under the terms of the SUV driver’s insurance policy, there was only one accident. View "Hughes v. Farmers Auto. Ins. Ass’n" on Justia Law

An SUV was being driven in the wrong direction on a highway when it collided with a semi-tractor-trailer. The SUV was totaled, and the SUV’s driver was killed. Second later, a motorcyclist ran into the SUV that was still in the middle of the highway. The drivers of both the semi and the motorcycle suffered injuries. The drivers jointly filed a petition for declaratory judgment against the insurer of the SUV asking the district court to declare that there had been two accidents for purposes of the insurance policy’s per-accident limit on bodily injury liability. The district court granted summary judgment for the insurer, concluding that the injuries suffered by the plaintiffs arose from one accident. The Supreme Court affirmed, holding that, under the terms of the SUV driver’s insurance policy, there was only one accident. View "Hughes v. Farmers Auto. Ins. Ass’n" on Justia Law

Plaintiff, an agricultural supply company, was delivering its own products in a semi-trailer when the semi-trailer wrecked and spilled fertilizers and chemicals, contaminating several hundred cubic yards of soil. Plaintiff suffered a loss of almost $1 million due to the environmental remediation and for the value of the trailer and its contents. Plaintiff had been leasing the semi-tractor and its driver from another source at the time of the accident. Plaintiff, on behalf of itself and its insurer, filed suit against the lessors and their driver, alleging negligence and breach of contract. The district court granted summary judgment in favor of Defendants, concluding that the terms of the lease and Iowa Code 325B.1 barred any recovery by Plaintiff. The Supreme Court reversed, holding (1) section 325B.1 governs relations between authorized motor carriers and shippers and does not apply to the lease in this dispute because Plaintiff is a private carrier rather than a motor carrier; (2) the indemnification provisions in the lease are valid and enforceable; and (3) the anti-subrogation rule limits potential recovery in this case. View "United Suppliers, Inc. v. Hanson" on Justia Law

Plaintiff filed a tort claim with the state appeal board for wrongful death, alleging that the Iowa Department of Transportation’s negligent maintenance of a highway caused her husband’s death. The appeal board took no action on the claim for more than six months. Plaintiff finally withdrew the claim and filed suit in the district court, both individually and as administrator of her deceased husband’s estate. The district court dismissed the suit, concluding that Plaintiff had failed to exhaust administrative remedies before filing suit as administrator of the estate. The Supreme Court reversed, holding that Plaintiff exhausted her administrative remedies and properly presented her claim to the appeal board. View "McFadden v. Dep’t of Transp." on Justia Law

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