Justia Injury Law Opinion Summaries

The Supreme Court remanded this case for a new trial, holding that the district court misapplied changes to the Iowa Rules of Civil Procedure when it excluded certain evidence in this case, and the ruling may have affected the outcome of trial.In 2014, the amendments to the Iowa Rules of Civil Procedure were adopted, inspired by prior changes to the federal rules. In the instant case, the district court excluded certain expert opinions of Plaintiff's treating chiropractor on the grounds that the chiropractor had not formed those opinions during treatment and Plaintiff had not submitted a timely expert report required under Iowa R. Civ. P. 1.500(2)(b). The Supreme Court reversed, holding that because the 2014 rule changes allow parties to submit more limited rule 1.500(2)(c) disclosures for experts who have not been retained for purposes of litigation the district court abused its discretion in its evidentiary ruling. View "Mengwasser v. Comito" on Justia Law

The Supreme Court affirmed the order of the district court granting Employer's motion to dismiss a petition for judicial review as untimely, holding that the district court correctly dismissed Claimant's petition for judicial review.Claimant sustained a work injury and pursued workers' compensation benefits. The workers' compensation benefits ordered Employer to pay temporary total disability benefits related to Claimant's right extremity injury but rejected Claimant's claim that she had also sustained a right shoulder occupational injury. According to Iowa Code 17A.19(3), Claimant had thirty day to file a petition for judicial review. Claimant's attorney failed to file the petition by the deadline. When the attorney realized his oversight, Claimant filed a petition for judicial review. The district court dismissed the petition as untimely. The Supreme Court affirmed, holding that the district court did not err. View "Askvig v. Snap-On Logistics Co." on Justia Law

The Supreme Court reversed the ruling of the district court granting summary judgment in favor of the owner of a zip line in this personal injury action, holding that exculpatory clauses purporting to negate liability for acts that are wantonly or recklessly committed generally violate public policy.Mt. Crescent Ski Area contracted with Challenge Quest, LLC to build and install a zip line. When Plaintiff took the zip line an employee had failed to reset the zip line's braking system after the previous rider existed. Consequently, Plaintiff slammed into a wood pole at the base of the zip line and fractured his neck. Plaintiff sued Challenge Quest and Mt. Crescent. The district court granted summary judgment in favor of Challenge Quest, concluding that it owed no duty to Plaintiff because it didn't install the allegedly defective braking system in place when Plaintiff was injured. The district court also granted summary judgment for Mt. Crescent based on a liability waiver that Plaintiff signed before riding. The Supreme Court reversed the summary judgment ruling as to Mt. Crescent, holding that the contractual waiver limiting Mt. Crescent's liability was unenforceable to the extent it purported to eliminate liability for the willful, wanton, or reckless conduct that Plaintiff alleged. View "Lukken v. Century, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment to Defendants and dismissing Plaintiff's breach of fiduciary and defamation claims, holding that summary judgment was proper.Ryan Koster, a former member of Harvest Bible Chapel (HBC), a nondenominational Christian church, filed suit against HBC and three of its pastors, alleging breach of fiduciary duty, invasion of privacy, defamation, vicarious liability, and conspiracy. The district court granted summary judgment to Defendants as to all counts. Koster appealed, challenging the dismissal of the breach of fiduciary duty and defamation claims. The Supreme Court affirmed, holding that defamation was warranted on these claims. View "Koster v. Harvest Bible Chapel–Quad Cities" on Justia Law

The Supreme Court reversed the judgment of the district court granting summary judgment in favor of Mercy Medical Center and dismissing Plaintiffs' suit for the negligent credentialing of Dr. David Segal, holding that the district court erred in dismissing this suit.In its judgment dismissing this suit, the district court concluded that Plaintiffs' negligent credentialing claim was cognizable in Iowa. The Supreme Court reversed, holding that assuming, without deciding, the tort of negligent credentialing is cognizable in the state of Iowa, the district court (1) erred in concluding that Mercy had no duty to exercise reasonable care under the circumstances; and (2) erred in ruling that evidence of prior malpractice suits against Dr. Segal and that expert opinion regarding breach of the standard of care based, in part, on prior lawsuits was inadmissible under Iowa R. Evid. 5.403. View "Rieder v. Segal" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of a strip club and dismissing this common law wrongful-death-negligence action, holding that Defendants owed no continuing legal duty to the decedent in this case.Daulton Holly was ejected from the strip club by the club's security guard and offered a cab ride home. Holly refused the offer and left the establishment on foot. Thirty minutes later, Holly was struck and killed by a drunk driver about one-half mile away from the strip club. Holly's parents and estate brought this action against the strip club. The district court granted a "no-duty" summary judgment against the plaintiffs. The Supreme Court affirmed, holding that the strip club owed no continuing legal duty to Holly after he refused the offer of the cab ride and chose to walk away. View "Morris v. Legends Fieldhouse Bar & Grill, LLC" on Justia Law

In this defamation action, the Supreme Court affirmed the district court's order granting Defendant's motion for summary judgment, holding that the district court did not err in concluding that the statement at issue was a constitutionally protected opinion.Plaintiff, a manager of an apartment building, sued Defendant for defamation in connection with a social media post in which Defendant called Plaintiff a slumlord. In his complaint, Plaintiff argued that Defendant asserted a false statement of fact in alleging that he was an actual unscrupulous landlord of a slum area. The district court granted summary judgment for Defendant. The court of appeals affirmed. The Supreme Court affirmed, holding that any reasonable reader of Defendant's social media post would understand that the use of the term "slumlord" was only rhetorical hyperbole; and (2) therefore, there was insufficient evidence that anyone thought Defendant asserted a factual statement about Plaintiff as a landlord. View "Bauer v. Brinkman" on Justia Law

The Supreme Court affirmed the ruling of the district court granting summary judgment dismissing Kristina Lewis's negligence claims against Howard L. Allen Investments, Inc. (Allen Investments), holding that Allen Investments did not owe a duty to protect Lewis from the harm she suffered.Allen Investments sold a house under a contract of sale that required the buyers to make monthly payments for ten years. Five years into the payment period the buyers leased the house to Lewis and her fiancé. The house subsequently caught fire, causing Lewis to suffer serious injuries. Lewis brought this negligence action against the buyers and Allen Investments. The district court granted summary judgment for Allen Investments, concluding that the company, as a contract seller, owed no duty to Lewis. The Supreme Court affirmed, holding (1) Allen Investments was not the landlord of the property under Iowa's Uniform Residential Landlord and Tenant Act, Iowa Code chapter 562A; and (2) Allen Investments owed no duty of care to Lewis to maintain the property. View "Lewis v. Howard L. Allen Investments, Inc." on Justia Law

The Supreme Court reversed the judgment of the trial court dismissing this lawsuit brought by an injured pedestrian against a city over a defective city sidewalk, holding that the trial court erred in dismissing the case for failure to state a claim based on the public duty doctrine.Plaintiffs sued the City of Urbandale claiming that the City had failed properly to maintain, repair, and warn about a dangerous and uneven sidewalk, causing her injuries. The district court granted the City's motion to dismiss, concluding that the public-duty doctrine barred Plaintiffs' claims. The Supreme Court reversed, holding that the pleading was sufficient to avoid application of the public-duty doctrine for motion-to-dismiss purposes. View "Fulps v. City of Urbandale" on Justia Law

The Supreme Court affirmed the judgment of the district court determining that Jason Carter was civilly liable for the death of his mother, Shirley Carter, holding that the district court did not abuse its discretion.Jason was civilly accused by his father and brother of intentionally shooting his mother. After a jury determined that Jason was civilly liable the State charged Jason with first degree murder. As a result of discovery from that criminal proceeding, Jason was acquitted murder. Jason later filed a second petition to vacate the judgment based on newly discovered evidence. The district court dismissed the petition. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion in denying Jason’s motion for continuance, judgment notwithstanding the verdict, first petition to vacate the judgment, and motion for recusal; (2) properly denied Jason's motion to quash a subpoena to the Iowa Department of Criminal Investigations; and (3) lacked jurisdiction to hear this second petition to vacate the judgment because it was untimely. View "Carter v. Carter" on Justia Law