Justia Civil Procedure Opinion Summaries

Regena Strable, a marketing director at Altoona Nursing and Rehabilitation Center, injured her left ankle at work, leading to permanent partial disability. This injury caused further physical injuries to her hip and lower back, as well as mental injuries such as post-traumatic stress disorder and anxiety. Strable had previously suffered carpal tunnel injuries to both wrists a decade earlier. After settling with her employer for the ankle injury and the sequela injuries, Strable sought benefits from the Second Injury Fund of Iowa based on her prior carpal tunnel injuries.The deputy commissioner denied Strable’s request for benefits from the Fund, concluding that Iowa Code section 85.64 imposes liability on the Fund only when the second injury is limited to a scheduled injury. The Iowa Workers’ Compensation Commissioner disagreed and granted benefits. On judicial review, the Iowa District Court for Polk County reversed the Commissioner’s decision, agreeing with the deputy commissioner that awarding benefits from the Fund would result in double recovery for Strable.The Iowa Supreme Court reviewed the case and reversed the district court’s order. The court held that the Fund is liable under Iowa Code section 85.64 if the first and second qualifying injuries caused a compensable injury to an enumerated member, regardless of whether the injuries caused other non-enumerated or unscheduled injuries. The court found that the Commissioner erred in calculating the Fund’s liability by not including the employer’s liability for the sequela injuries. The case was remanded to the Commissioner for a determination of the amount and timing of the Fund’s liability, consistent with the court’s opinion. View "Second Injury Fund of Iowa v. Strable" on Justia Law

Silvia Cianzio, a retired professor from Iowa State University, filed a lawsuit against the university, the Iowa Board of Regents, and the State of Iowa, alleging wage discrimination in violation of Iowa Code section 216.6A. She claimed that male professors in her department were paid significantly more than female professors, including herself. After conducting a survey on departmental salaries, she discovered that her annual pay was substantially less than that of her male counterparts. She reported these findings to university officials, who dismissed her concerns. Cianzio retired in December 2020 and subsequently filed a complaint with the Iowa Civil Rights Commission (ICRC) in August 2021, followed by a lawsuit in January 2022.The Iowa District Court for Polk County partially granted the university's motion to dismiss, ruling that Cianzio could only seek damages for wage discrimination occurring within the two-year statute of limitations for wage claims, as set forth in Iowa Code section 614.1(8). The court rejected the university's argument that damages should be limited to the 300-day period preceding the filing of her ICRC complaint.The Iowa Supreme Court reviewed the case and reversed the district court's decision. The court held that Iowa Code section 216.15(9)(a)(9) allows a claimant to recover damages for the entire period of wage discrimination, not limited to the two-year statute of limitations or the 300-day period before filing the ICRC complaint. The court emphasized that the statute's language permits recovery for the entire period of discrimination, as long as the complaint is filed within the statutory time frame. The case was remanded for further proceedings consistent with this interpretation. View "Cianzio v. Iowa State University" on Justia Law

An employee, Ashley Koester, worked as a mobile crisis counselor for Eyerly-Ball Community Health Services. She believed she was entitled to overtime compensation for her on-call hours and filled out timesheets accordingly, which were approved by her supervisor. Later, her employer objected to the overtime payments and terminated her employment. Koester sued her employer under Iowa Code chapter 91A and for wrongful discharge in violation of public policy, claiming she was terminated for asserting her right to overtime pay.The Iowa District Court for Polk County dismissed Koester's claims, ruling that she did not have a claim under chapter 91A because she had been paid in full, including for the overtime hours she claimed. The court also found her statutory claim time-barred. Koester appealed, and the Iowa Court of Appeals reversed the dismissal of her public policy claim but affirmed the dismissal of her statutory claim.The Iowa Supreme Court reviewed the case and concluded that Koester did not state a claim for relief under chapter 91A or the common law tort of wrongful discharge in violation of public policy. The court held that chapter 91A is a wage collection law, not a generalized fair practices law, and since Koester did not have a claim for unpaid wages, she was not entitled to relief. The court also determined that Koester's public policy claim failed because she was not engaged in protected activity under the statute, as she did not file a complaint or claim unpaid wages before her termination. The Iowa Supreme Court vacated the decision of the Court of Appeals and affirmed the District Court's judgment dismissing Koester's claims. View "Koester v. Eyerly-Ball Community Mental Health Services" on Justia Law

Todd Halbur was terminated from his position as comptroller of the Iowa Alcoholic Beverages Division (ABD). Halbur claimed he was fired in retaliation for reporting to his supervisor, Stephen Larson, that ABD was violating Iowa law by exceeding the 50% markup on liquor sales and for refusing to engage in illegal acts related to a service contract with Beverage Merchandising, Inc. (BMI). Halbur filed a lawsuit against Larson, asserting a statutory claim for wrongful discharge under Iowa Code section 70A.28 and a common law claim for wrongful discharge in violation of public policy. The district court submitted the statutory claim to a jury but dismissed the common law claim, ruling that the statutory claim was the exclusive remedy. The jury awarded Halbur $1 million, which was reduced due to a statutory cap on damages.The Iowa District Court for Polk County dismissed Halbur’s common law wrongful discharge claim, reasoning that the statutory claim under section 70A.28 provided a comprehensive remedy. The court also dismissed the statutory claims against the State of Iowa and ABD, allowing the claim to proceed only against Larson in his official capacity. Larson’s motion for summary judgment was initially granted in part but later reconsidered, allowing the case to proceed to trial. The jury found in favor of Halbur, awarding him damages.The Iowa Supreme Court reviewed the case. Larson argued that Halbur’s internal complaints did not constitute protected disclosures under section 70A.28. However, the court found that Larson failed to preserve this issue for appeal by not raising it during trial through a motion for directed verdict or judgment notwithstanding the verdict. On cross-appeal, Halbur argued that his common law claim should not have been dismissed. The court affirmed the district court’s decision, holding that the statutory remedy under section 70A.28 was exclusive and comprehensive, precluding the need for a common law claim. The court affirmed the judgment of the district court. View "Halbur v. Larson" on Justia Law

Several landowners owned a tract of land near the intersection of a highway and Interstate 35. The Iowa Department of Transportation (DOT) planned to modernize the interchange and condemned a strip of the landowners' property. The landowners anticipated being able to install a commercial entrance to the highway based on prior discussions with the DOT. However, the DOT's formal notice of condemnation indicated that all rights of direct access to the highway would be taken. The landowners filed actions challenging the condemnation after being informed that commercial access would not be allowed.The Iowa District Court for Story County dismissed the landowners' actions as untimely, citing the thirty-day deadline for challenging the exercise of eminent domain authority under Iowa Code section 6A.24(1). The landowners also delayed filing their notice of appeal in the district court, which was filed fifty-seven days after the dismissal order, although it was served on the DOT within twenty-two days.The Iowa Supreme Court reviewed the case and concluded that the delay in filing the notice of appeal was not fatal, as the thirty-five days from service to actual filing was deemed a reasonable time under Iowa Rule of Appellate Procedure 6.101(4). However, the court found that the landowners' challenge to the condemnation was untimely under Iowa Code section 6A.24(1), which requires actions to be commenced within thirty days after service of notice of assessment. The court held that this statute is the exclusive method for challenging the exercise of eminent domain authority and does not allow for exceptions or the application of a discovery rule. Consequently, the Iowa Supreme Court affirmed the district court's dismissal of the landowners' case. View "Brendeland v. Iowa Department of Transportation" on Justia Law

A landowner in Hardin County, Iowa, refused to allow a surveyor for a pipeline developer to enter his private property. The developer, Summit Carbon Solutions, LLC, sought access under Iowa Code section 479B.15, which governs hazardous liquid pipelines. The district court ordered the landowner to allow the surveyor temporary access, rejecting the landowner’s claims that the statute was unconstitutional under the “takings” clauses of the U.S. and Iowa Constitutions and that carbon dioxide in a supercritical state is not a “hazardous liquid.”The Iowa District Court for Hardin County ruled that the statute was facially constitutional and that Summit was a “pipeline company” with access rights under section 479B.15. The court found that Summit had provided proper statutory notice to the landowner and that the landowner’s claim of having a tenant who did not receive notice was not credible. The court granted Summit’s request for injunctive relief to compel access for surveying.The Iowa Supreme Court reviewed the case and affirmed the district court’s judgment. The court held that section 479B.15 is a lawful pre-existing limitation on the landowner’s title, consistent with longstanding background restrictions on property rights, and does not constitute a taking under the Federal or Iowa Constitutions. The court also held that supercritical carbon dioxide is a “hazardous liquid” within the meaning of section 479B.2, making Summit a pipeline company with access rights under the statute. The court found that Summit had complied with the statutory notice requirements and that no additional showing of irreparable harm was required for the injunction. The judgment and injunctive relief granted by the district court were affirmed. View "Summit Carbon Solutions, LLC v. Kasischke" on Justia Law

A baby, S.K., was injured during labor and delivery, allegedly due to the negligence of the delivering doctor, Dr. Goodman, who used a Mityvac obstetrical vacuum delivery system. The plaintiff, S.K.'s conservator, claimed that the use of the vacuum caused brain damage to S.K. and sought damages from Dr. Goodman’s employer, Obstetric & Gynecologic Associates of Iowa City and Coralville, P.C. (the clinic).A jury in the Iowa District Court for Johnson County found in favor of the plaintiff, awarding substantial damages. The clinic appealed, arguing that the district court erred in admitting a package insert from the vacuum, which contained hearsay statements about when the vacuum should not be used and potential harms from its use. The clinic contended that the insert's admission violated Iowa’s hearsay rule and prejudiced the trial's outcome.The Iowa Supreme Court reviewed the case and agreed with the clinic. The court found that the package insert contained hearsay and did not fit within any recognized exceptions, including the residual exception and the market reports exception. The court noted that the insert's admission was prejudicial, as it directly addressed a central dispute in the case and was emphasized in the plaintiff's closing argument. The court concluded that the erroneous admission of the insert deprived the clinic of a fair trial.The Iowa Supreme Court reversed the district court's judgment and remanded the case for a new trial. The court also addressed a procedural issue raised by the clinic regarding the plaintiff's certificate of merit affidavit, ultimately denying the clinic's motion to reverse on those grounds. View "S.K. v. Obstetric & Gynecologic Associates of Iowa City and Coralville, P.C." on Justia Law

The Vagts family, who own and operate a dairy farm in West Union, Iowa, filed a nuisance suit against Northern Natural Gas Company (NNG). NNG operates a natural gas pipeline that runs under the Vagts' property and uses a cathodic protection system, which runs an electrical current through the pipeline to prevent corrosion. The Vagts alleged that stray voltage from the cathodic protection system distressed their dairy herd and caused them damages. The jury awarded the Vagts a total of $4.75 million in damages. NNG appealed, arguing that the district court erred in instructing the jury on nuisance without including negligence as an element of the claim and in denying NNG’s motion for remittitur.The district court held that negligence was not an element of the nuisance claim and instructed the jury accordingly. The jury found that the stray voltage from the cathodic protection system was definitely offensive, seriously annoying, and intolerable, that the stray voltage interfered with the Vagts’ normal use of land in the local community, and that this constituted a nuisance. The jury awarded the Vagts $3 million in economic damages, $1.25 million for personal inconvenience, annoyance, and discomfort, and $500,000 for the loss of use and enjoyment of land.On appeal, the Supreme Court of Iowa affirmed the district court's decision. The court held that under the controlling statute and precedents, negligence is not an element of a nuisance claim. The court also held that the district court did not abuse its discretion in declining to disturb the jury's verdict on damages. The court concluded that the jury's verdict was supported by the record when viewed in the light most favorable to the plaintiffs. View "Vagts v. Northern Natural Gas Company" on Justia Law

The case involves a dispute over the boundary between two parcels of land in Wapello County, Iowa. The northern parcel was owned by the Handlings and the southern parcel by the Sims. Both parties treated a fence line as the boundary between their properties for many years. In the mid-1990s, Scott Hubbell began leasing both properties for farming. In 2004, he built a machine shed south of the fence line, assuming it was on the southern property. In 2014, Hubbell and his wife purchased both properties, becoming the sole owners. In 2017, they sold the southern property to the Remmarks and in 2018, they sold the northern property to Sundance Land Company. A survey commissioned by Sundance revealed that the legal boundary between the properties ran south of the fence line, meaning the machine shed was encroaching onto the northern property. Sundance filed a petition to quiet title according to the survey boundary lines, alleging that the Remmarks were trespassing on the northern property.The district court found that a boundary line by acquiescence had been established at the old fence line during the Handlings’ and Sims’ respective ownership of the properties. The court rejected Sundance’s argument that the Hubbells’ common ownership of both parcels from 2014 to 2017 erased the boundary by acquiescence. The court of appeals affirmed the district court's decision.The Supreme Court of Iowa disagreed with the lower courts' decisions. The court held that when two adjoining parcels come under common ownership, any potential boundary by acquiescence between them is eradicated, and the ten-year clock for calculating boundary by acquiescence restarts when separate ownership resumes. The court vacated the decision of the court of appeals, reversed the district court judgment, and remanded for entry of judgment for Sundance in accordance with this opinion. View "Sundance Land Company, LLC v. Remmark" on Justia Law

In this case, a private citizen, Robert Teig, appealed a summary judgment granted to city officials in his lawsuit alleging violations of the Iowa Open Records Act. Teig had requested job applications and other documents related to the City of Cedar Rapids' hiring processes for a new city clerk and city attorney. The City refused many of Teig's requests, citing attorney-client privilege and the Act's confidentiality provisions as reasons for withholding several documents.The district court granted the City's motion for summary judgment, leading to Teig's appeal. He argued that job applications submitted to governmental bodies are not confidential under chapter 22, municipalities cannot claim attorney-client privilege in the context of an open records request, search and retrieval fees are not authorized by chapter 22, the defendants unreasonably delayed fulfilling certain requests, and the district court should have granted him leave to submit additional interrogatories in the ensuing litigation.The Supreme Court of Iowa affirmed in part and reversed in part the district court's decision. The court held that documents subject to attorney-client privilege are protected from disclosure under chapter 22 and that chapter 22 authorizes municipalities or governmental bodies to charge search and retrieval fees. However, the court found that while job applications are generally protected from disclosure, that protection extends only to persons "outside of government." Therefore, the City was obligated to disclose those applications submitted by current employees of the City, although it properly withheld external applications. The court also found that the district court failed to address Teig’s claims of undue delay related to billing records. The case was remanded for further proceedings. View "Teig v. Chavez" on Justia Law