Justia Injury Law Opinion Summaries

While an inmate at a correctional facility, Kevin Walker was assaulted by another inmate and was seriously injured. Walker brought a tort claim against the State, a correctional officer, and two activity specialists, claiming they negligently failed to ensure his safety. The State sought summary judgment based upon the discretionary function and intentional tort exceptions to the Iowa Tort Claims Act (ITCA). The district court denied the motion, concluding a genuine issue of material fact existed as to whether the prison staff involved had knowledge of a history of prior trouble involving Walker. The Supreme Court granted the State's application for interlocutory appeal and affirmed the decision of the district court, holding that the district court did not err in denying the State's motion for summary judgment where (1) because the decisions made by the correctional staff in the supervision of the inmates, in this instance, did not involve the evaluation of broad public policy factors, the State was not entitled to the discretionary function exception; and (2) as long as a claimant can show the State is negligent in performing a duty to protect a person from an assault, the intentional tort exception to the ITCA is not applicable.

Bill Ernst gave Johnny Vajgrt permission to enter his property to remove a fallen tree. Vajgrt subsequently uprooted approximately forty live trees on Ernst's property. After Vajgrt died, Ernst filed a claim seeking compensatory damages and exemplary damages for the diminution of value of property, value of trees, and expenses for restoration of property. In addition, Ernst sought punitive damages. The district court awarded Ernst compensatory damages but declined to award any punitive damages, stating that it was well settled in Iowa that punitive damages may not be recovered from the estate of a deceased tortfeasor. On appeal, the Supreme Court affirmed, concluding that it would defer to the legislature's prior decisions and the Court's established precedents as it was not persuaded that it should reconsider those precedents.

Plaintiff Mark Peak broke his leg while helping Ellis and Rachel Adams move furniture using a rented U-Haul truck. The liability insurer for U-Haul paid its policy limits of $20,000 to Peak in exchange for a release that specifically named Ellis and arguably covered Rachel. When Peak sought additional compensation from another of insurer for the Adamses, the insurer denied coverage based on the release. Peak filed a negligence action against Adamses, alleging they were liable for negligence in their operation of the rental truck and their failure to remove snow from their driveway. The district court granted defendants' motion for summary judgment, concluding the release barred Peak's claims against both Ellis and Rachel. The court of appeals reversed. At issue was whether the release covered Ellis and Rachel as well as U-Haul and its insurer. On further review, the Supreme Court held that the district court correctly granted summary judgment for Ellis based on the release, while fact questions precluded summary judgment for Rachel. The Court vacated the decision of the court of appeals and affirmed in part and reversed in part the district court judgment.

Elizabeth Von Linden took her life three weeks after she was discharged as an inpatient from defendant Mercy Hospital's psychiatric ward and six days after her outpatient office visit with Mercy's psychiatrist. Von Linden's husband brought a wrongful death action against Mercy, alleging negligent care. Mercy raised defenses, including Von Linden's comparative negligence. The jury found both Mercy and Von Linden negligent and allocated ninety percent of the total fault to Von Linden and ten percent to Mercy, resulting in a defense verdict. At issue on appeal was whether the state's comparative fault act, Iowa Code chapter 668, permits a jury to compare the fault of a noncustodial suicide victim with the negligence of the mental health professionals treating her. The Supreme Court held that Von Linden owed a duty of self-care as an outpatient, and the district court committed no reversible error in allowing the jury to compare her fault. The Court therefore affirmed the judgment for Mercy.