Justia Injury Law Opinion Summaries

The Supreme Court affirmed the decision of the district court granting summary judgment to Defendants as to some of Plaintiff's claims and the judgment entered on the defense verdicts on Plaintiff's remaining defamation claims, holding that Plaintiff had not shown grounds for reversal.Plaintiff, the former principal at St. Joseph's Catholic School, brought this action against Father Josephs Pins, St. Joseph's Church, and the Diocese of Des Moines after her employment was terminated, alleging fraud and defamation by all defendants and breach of contract against Father Pins. The district court granted summary judgment in favor of Defendants as to Plaintiff's fraud, breach of contract, and defamation claims, and then a jury returned defense verdicts on the remaining defamation claims. The Supreme Court affirmed, holding that Plaintiff was not entitled to reversal on his allegations of error. View "Konchar v. Pins" on Justia Law

The Supreme Court affirmed the rulings of the district court and court of appeals that the workers' compensation commissioner erred in granting Employer's motion for summary judgment and dismissing Employee's review-reopening petition, holding that Employee was permitted to pursue a claim for a permanent injury in a review-reopening proceeding despite an earlier adjudication that her injury was not permanent.Employee was injured during the course and work of her employment. Employee filed a petition seeking workers' compensation for a permanent disability, but the deputy commissioner refused to order additional benefits beyond those that Employer had already paid. Employee filed a petition for review-reopening with the workers' compensation commission. The commission determined that Employee's claim for permanent disability benefits was barred by principles of res judicata. The district court reversed, and the court of appeals affirmed. The Supreme Court affirmed, holding that the agency erred in dismissing Employer's review-reopening petition. View "Green v. North Central Iowa Regional Solid Waste Authority" on Justia Law

The Supreme Court affirmed the judgment of the district court reversing the decision of the workers' compensation commissioner denying the claim filed by the husband of a deceased employee for burial expenses and death benefits as the surviving spouse, holding that the district court did not err.Approximately two and a half years into her marriage Wife left her marital home with Husband, accepted a job in a different city, and moved in with a family friend. Husband and Wife never divorced. Wife was subsequently permanently and totally disabled as a result of a work injury and was awarded workers' compensation benefits. Four years later, Wife died from an overdose. Husband filed a claim for burial expenses and death benefits as the surviving spouse. Employer/Insurer denied the claim. The commissioner upheld the denial, concluding that Husband had willfully deserted Wife without any fault by her and thus was not entitled to benefits under Iowa Code 85.42(1)(a). The district court reversed. The Supreme Court affirmed, holding that there was not substantial evidence to support the commissioner's finding that Husband deserted Wife without fault by her under section 85.42(1)(a). View "Blasdell v. Linnhaven, Inc." on Justia Law

In this interlocutory appeal in a case involving claims for injuries resulting from a high-speed chase, the Supreme Court reversed the decision of the district court denying the State's motion for summary judgment, holding that the State was entitled to summary judgment under Iowa Code 321.231.Law enforcement officer Brett Tjepkes was chasing Scott Grimes, the perpetrator of a multi-state crime spree, when Grimes crashed head-on with another vehicle. Amber Martinez, the sole occupant of the car he hit, suffered serious injuries. Martinez brought suit, alleging that the Officer Tjepkes acted negligently, causing her injuries. The State moved for summary judgment, arguing that Tjepkes could not be held legally liable as the cause of the crash. The district court denied the motion, finding that a disputed issue of fact existed as to whether Tjepkes's actions were reckless. The State brought this interlocutory appeal. The Supreme Court reversed, holding that no reasonable jury could find that Tjepkes's decision to pursue Grimes was reckless. View "Martinez v. State" on Justia Law

The Supreme Court reversed the order of the district court dismissing with prejudice Plaintiff's petition asserting claims arising under the Iowa Municipal Tort Claims Act (IMTCA), holding that the district court erred in dismissing the case with prejudice after Plaintiff had already voluntarily dismissed his case without prejudice.Iowa Code 670.4A sets forth a qualified immunity defense to and heightened pleading requirements for claims arising under the IMTCA. Plaintiff sued the City of Waterloo and one of its police officers, alleging that the officer shot him without justification. Defendants moved to dismiss the petition pursuant to section 670.4A. The day before a scheduled hearing on the motion Plaintiff dismissed his petition without prejudice. The district court granted Defendants' motion to set aside the dismissal with prejudice based on Plaintiff's alleged failure to meet the statutory pleading requirement. The Supreme Court reversed, holding that nothing in the language of section 670.4A required dismissal with prejudice. View "Alvarez-Victoriano v. City of Waterloo" on Justia Law

In this interlocutory appeal, the Supreme Court reversed the decision of the district court ordering certain records produced to Plaintiff in discovery before trial, holding that the district court erred by relying on civil discovery rules to compel production of the records at issue.Plaintiff's daughter was killed in a motorcycle accident. Plaintiff brought a tort action against the driver of the motorcycle and settled without subpoenaing the county sheriff's investigative reports. After a criminal investigation and prosecution of the driver was complete Plaintiff brought this enforcement action under Iowa Code chapter 22 against the county sheriff's department seeking to obtain its complete investigation file. The district court ordered the records produced to Plaintiff in discovery before trial without ruling on their confidentiality. The Supreme Court reversed, holding that the district court erred in compelling disclosure of the sheriff's investigation materials to Plaintiff's counsel. View "Vaccaro v. Polk County" on Justia Law

The Supreme Court affirmed in part and vacated in part the ruling of the court of appeals affirming the jury's verdict on libel-per-se damages and punitive damages, holding that remittitur was appropriate in this case.After a jury trial, Hoffmann Innovations, Inc. and Jerry Hoffmann were awarded $11 million in compensatory and punitive damages against Scott Clark based on defamatory statements that Clark made on social media and in podcasts. During the proceedings, the trial court repeatedly sanctioned Clark for violating a consent order preventing both parties from making disparaging statements about each other. Ultimately, the court struck Clark's answer and affirmative defenses in an attempt to secure compliance with sanctions. Without any defense pleaded to the claims, the trial proceeded on only the amount of damages. The Supreme Court reversed in part, holding that the jury used the wrong measure of damages on the damages awarded and that remittitur was also appropriate for punitive damages. View "Hoffman v. Clark" on Justia Law

The Supreme Court reversed the decision of the district court granting summary judgment in favor of Defendants on Plaintiffs' premises liability claims against Alcoa Inc. and on their products liability claims against Iowa-Illinois Taylor Insulation, Inc. (IITI) for supplying asbestos-containing insulation in the Alcoa plant, holding that the district court erred.At issue was the provision in Iowa Code 686B.7(5) that a "defendant in an asbestos action or silica action shall not be liable for exposures from a product or component part made or sole by a third party." In the instant asbestos case, the district court read the statute to limit liability to manufacturers of the asbestos-containing product at issue. The district court held that section 686B.7(5) granted immunity to Alcoa and IITI because the asbestos-containing insulation was manufactured by third parties. The Supreme Court reversed, holding that the district court failed to appreciate the legal significance of the legislature's use of the phrase "produce or component part made or sold by a third party" to reference a products liability defense known as the component parts defense as described in the specific context of asbestos litigation. View "Beverage v. Alcoa, Inc." on Justia Law

The Supreme Court reversed the judgment of the district court affirming the decision of the workers' compensation commissioner denying Petitioner's petition for benefits for trauma-induced mental injuries she suffered on the job while working as emergency dispatcher, holding that because Petitioner established that her PTSD resulted from a manifest happening of a sudden traumatic nature from an unexpected cause or unusual strain, Petitioner was entitled workers' compensation benefits.Petitioner, a sixteen-year veteran of the county emergency dispatch system, sought benefits for the PTSD she suffered after taking a 911 call from a woman screaming over and over at a high pitch, "Help me, my baby is dead." The workers' compensation commissioner and district court denied benefits, concluding that the mother's call wasn't an "unexpected cause or unusual strain." The Supreme Court reversed, holding that Petitioner was entitled to benefits because she established that her PTSD resulted from a manifest happening of a sudden traumatic nature from an unexpected cause or unusual strain. View "Tripp v. Scott Emergency Communication Center" on Justia Law

The Supreme Court vacated the decision of the court of appeals concluding that the public-duty doctrine barred Plaintiffs' tort claims against the State of Iowa and two municipalities, holding that the district court correctly denied Defendants' motion for judgment on the pleadings.This case arose from an accident in which a driver traveling the wrong way on Interstate 80 collided with another vehicle, killing all of the occupants. Plaintiffs brought this action alleging that Defendants were liable because of their role in negligently constructing and operating a confusing interchange used by the errant driver. Defendants filed a joint motion for judgment on the pleadings under the public-duty doctrine, which the district court denied. The court of appeals reversed, concluding that the public-duty doctrine barred all of Plaintiffs' claims against Defendants. The Supreme Court vacated the decision below and remanded the case for further proceedings, holding that complaint was sufficient to avoid application of the public-duty doctrine for purposes of adjudicating the motion for judgment on the pleadings. View "Estate of Farrell v. State" on Justia Law