Justia Civil Procedure Opinion Summaries

Minor Doe, Father Doe, and Mother Doe filed a lawsuit against the Western Dubuque Community School District and several school officials after Minor Doe was assaulted by another student during class. The plaintiffs claimed negligence, breach of fiduciary duty, and loss of consortium. The school did not contact medical personnel or the parents after the incident, and Minor Doe was later diagnosed with a concussion.The Iowa District Court for Dubuque County dismissed the case on four grounds: failure to meet the heightened pleading requirements of the Iowa Municipal Tort Claims Act (IMTCA), improper use of pseudonyms, failure of the breach of fiduciary duty claim as a matter of law, and the consortium claim failing without the underlying causes of action. The plaintiffs appealed the dismissal.The Iowa Supreme Court reviewed the case and concluded that the district court erred in dismissing the case based on the IMTCA’s qualified immunity provision and the use of pseudonyms. The court held that the IMTCA’s qualified immunity provision does not apply to common law claims and that pseudonymous petitions are generally disfavored but may be allowed in certain circumstances. The court found that the plaintiffs should have been given an opportunity to amend their petition to use their real names. However, the court affirmed the dismissal of the breach of fiduciary duty claim, stating that schools and their officials do not generally have fiduciary relationships with students.The Iowa Supreme Court reversed the district court’s dismissal of the negligence and consortium claims and remanded the case for further proceedings, while affirming the dismissal of the breach of fiduciary duty claim. View "Doe v. Western Dubuque Community School District" on Justia Law

In February 2014, Clint Shalla entered into a debt settlement agreement with Greg and Heather Koch to prevent a foreclosure on his farm. The Kochs agreed to purchase the farm and give Clint an exclusive option to repurchase it by August 15, 2015, with written notice and financing commitment. Clint's wife, Michelle, was not a party to the agreement but conveyed her marital interest in the property. Clint sought financing from Christopher Goerdt, then president of Peoples Trust and Savings Bank, who allegedly agreed to secure financing. Clint missed the option deadline, and the Kochs later agreed to sell the farm for a higher price. Goerdt, who had moved to County Bank, secured financing for the Shallas, but was later found to be involved in fraudulent activities.The Iowa District Court for Washington County granted partial summary judgment in favor of Peoples Bank, dismissing Michelle's fraudulent misrepresentation claim. The court later reconsidered and dismissed the Shallas' negligence and fraudulent misrepresentation claims, citing Iowa Code section 535.17. The court ruled in favor of County Bank in the foreclosure action and found Goerdt liable for conversion. The Shallas appealed, and the Iowa Court of Appeals affirmed the district court's judgment, with a dissent on the application of the statute of frauds.The Iowa Supreme Court reviewed the case and affirmed the lower courts' decisions. The court held that Iowa Code section 535.17, the credit agreement statute of frauds, barred the Shallas' claims for negligence and fraudulent misrepresentation. The court concluded that the statute applies to all actions related to unwritten credit agreements, regardless of whether the claims are framed in contract or tort. The case was remanded to the district court for a determination of County Bank's attorney fees, including appellate attorney fees. View "County Bank v. Shalla" on Justia Law

A railroad worker, Phillip Morgan, committed suicide after experiencing months of alleged harassment by his supervisor at Union Pacific Railroad Company. His wife, Kera Morgan, acting as the administrator of his estate, filed a lawsuit under the Federal Employers’ Liability Act (FELA), seeking wrongful death damages. She claimed that the harassment and stress from his job led to Phillip's emotional distress and eventual suicide.The Iowa District Court for Polk County granted summary judgment in favor of Union Pacific, concluding that Phillip's injuries were emotional and not tied to a physical impact or near physical harm, thus falling outside the scope of FELA. The court held that FELA did not cover emotional injuries unless there was a physical impact or the worker was in imminent danger of physical harm.The Iowa Supreme Court reviewed the case and affirmed the district court's decision. The court held that under the precedent set by the United States Supreme Court in Consolidated Rail v. Gottshall, FELA incorporates common law limits on compensable injuries. The court concluded that Phillip's emotional injuries, which led to his suicide, did not meet the "zone of danger" test established in Gottshall. This test requires that the worker must have been in immediate risk of physical impact or harm to recover for emotional injuries under FELA. Since Phillip's injuries were purely emotional and not tied to any physical impact or imminent threat of physical harm, the court ruled that FELA did not provide coverage for his case. View "Estate of Morgan v. Union Pacific Railroad Company" on Justia Law

A mother sought to modify an existing child custody order to change the school district her daughter attends after moving to a new residence. The father objected, arguing that changing schools would be disruptive and limit his time with the daughter. Unable to reach an agreement through mediation, the mother petitioned the court to modify the custody decree.The Iowa District Court for Worth County denied the mother's request, determining that changing school districts was not in the daughter's best interests. The mother appealed, and while the appeal was pending, the Iowa Supreme Court decided In re Marriage of Frazier. The Court of Appeals, interpreting Frazier, concluded that the district court lacked authority to hear the mother's petition because she was not seeking to alter the parents' status as joint legal custodians. The Court of Appeals affirmed the district court's ruling without considering the merits of the mother's petition.The Iowa Supreme Court reviewed the case and disagreed with the Court of Appeals' interpretation of Frazier. The Supreme Court held that a court that entered a custody decree has the authority to modify it when requested, even if the modification does not relate to who has legal custody. The Supreme Court found that the district court had the authority to rule on the mother's petition since the decree specified the daughter's school district, and the mother sought to modify that based on a change of circumstances.On de novo review, the Iowa Supreme Court agreed with the district court's determination that changing school districts was not in the daughter's best interests. Therefore, the Supreme Court vacated the Court of Appeals decision and affirmed the district court's order denying the modification petition. View "Venechuk v. Landherr" on Justia Law

Scott Hampe was employed by Charles Gabus Motors, Inc. (Gabus) from 2008 until December 2019. Gabus conducted an unannounced drug test on December 5, 2019, assisted by Mid-Iowa Occupational Testing (Mid-Iowa). Hampe was selected as an alternate for testing and was ultimately tested. During the test, Hampe provided two insufficient urine samples and decided to leave the testing area to care for his sick child, despite being warned by his manager that leaving would result in termination. Hampe was subsequently fired.Hampe filed a lawsuit against Gabus and Mid-Iowa in May 2020, alleging violations of Iowa Code section 730.5, which governs employer drug testing, and asserting common law claims. The Iowa District Court for Polk County granted summary judgment in favor of Gabus and Mid-Iowa, dismissing all of Hampe’s claims. Hampe appealed, and the Iowa Court of Appeals affirmed the dismissal of claims against Mid-Iowa and most claims against Gabus but reversed the dismissal of claims related to testing pool requirements, supervisor training, and uniform disciplinary policy, finding genuine issues of material fact.The Iowa Supreme Court reviewed the case and focused on Hampe’s claim that Gabus violated section 730.5’s requirements for the composition of testing pools. The court concluded that Gabus failed to substantially comply with the statutory requirements for the testing pool, as the pool included employees who were not scheduled to work at the time of testing. The court also found that Hampe was aggrieved by this failure, as his selection for testing and subsequent termination were based on a non-compliant process. The court reversed the district court’s judgment in part, affirmed it in part, and remanded the case for further proceedings to determine the appropriate relief for Hampe. The court also deemed Hampe’s claims concerning supervisor training and uniform disciplinary policy moot in light of the resolution of the pooling claim. View "Hampe v. Charles Gabus Motors, Inc." on Justia Law

A county board of supervisors approved a nonprofit entity’s application to rezone a parcel of land in rural Polk County. Another nonprofit entity and several nearby landowners filed a lawsuit challenging the rezoning decision. The plaintiffs argued that the rezoning violated the county’s comprehensive land use plan, zoning ordinances, and constituted illegal spot zoning. The board of supervisors moved to dismiss the lawsuit, claiming the plaintiffs lacked standing and were subject to heightened pleading requirements under Iowa’s Municipal Tort Claims Act.The Iowa District Court for Polk County granted the motion to dismiss, concluding that the plaintiffs failed to establish standing and were subject to the Act’s heightened pleading requirements. The court found that the individual plaintiffs did not adequately allege their proximity to the rezoned property or their personal concerns, and that the nonprofit organization did not sufficiently allege that its members had a specific and personal interest in the rezoning. The court also ruled that the plaintiffs could not amend their petition due to the Act’s requirements.The Iowa Supreme Court reviewed the case and reversed the district court’s decision. The Supreme Court held that the heightened pleading requirements and penalties under Iowa Code § 670.4A(3) did not apply because the plaintiffs were not seeking monetary damages. The court found that the individual plaintiffs had sufficiently alleged standing based on their proximity to the rezoned property and the nature of the proposed changes. However, the court concluded that the nonprofit organization had not established standing but should be allowed to amend its petition. The case was remanded for further proceedings. View "1000 Friends of Iowa v. Polk County Board of Supervisors" on Justia Law

Jahn Patric Kirlin and Sara Louise Kirlin filed a medical malpractice lawsuit against Dr. Christian William Jones, Dr. Barclay A. Monaster, and Physicians Clinic Inc. d/b/a Methodist Physicians Clinic – Council Bluffs. Jahn Kirlin experienced severe neck pain and headaches, and despite seeking medical help, an MRI was delayed. Dr. Monaster, who had returned from treatment for alcohol abuse, refused to order an MRI, and Kirlin later suffered a stroke after a chiropractic adjustment. The plaintiffs allege that the defendants altered medical records and that Dr. Monaster was intoxicated during treatment.The Pottawattamie County District Court initially dismissed the case due to a defective certificate of merit. The plaintiffs refiled with a new certificate, but the court granted summary judgment for the defendants. The Iowa Supreme Court reversed this decision, allowing the plaintiffs to proceed.Upon remand, the district court did not set new deadlines, leading to confusion about the applicable expert certification deadline. The defendants moved for summary judgment again, arguing the plaintiffs missed the deadline. The district court agreed, finding no good cause to extend the deadline, and granted summary judgment to the defendants.The Iowa Supreme Court reviewed the case and found that the district court abused its discretion by not finding good cause for the plaintiffs' delayed expert certification. The court noted the confusion about deadlines, lack of prejudice to the defendants, the plaintiffs' diligence, and the defendants' actions. The court reversed the summary judgment and remanded the case for further proceedings. View "Kirlin v. Monaster" on Justia Law

In the 1950s, Bert and Donna Miller sought fertility treatment at the University of Iowa Hospitals and Clinics. Dr. John H. Randall, the head of the department, assisted them, resulting in the birth of three children. Decades later, DNA testing revealed that Dr. Randall, not Bert Miller, was the biological father of two of the children. The plaintiffs, Bert Miller and Nancy Duffner, sued the State of Iowa under the Fraud in Assisted Reproduction Act (FARA), alleging that Dr. Randall used his own sperm without their parents' knowledge or consent.The Iowa District Court for Johnson County dismissed the case, ruling that FARA, enacted in 2022, does not apply retroactively to actions taken decades earlier. The court found that FARA lacks any express language indicating legislative intent for retrospective application, and thus, it operates only prospectively. The plaintiffs appealed, arguing that FARA's provision allowing children to sue "at any time" implies retroactive application.The Iowa Supreme Court reviewed the case and affirmed the district court's decision. The court held that FARA does not apply to fertility fraud committed before the statute was enacted. The court emphasized that without an express retroactivity provision, statutes creating new substantive liabilities are presumed to operate only prospectively. The court found no language in FARA that rebuts this presumption and concluded that the statute's provision allowing actions to be brought "at any time" pertains only to future violations. Therefore, the plaintiffs' claims were dismissed with prejudice. View "Miller v. State" on Justia Law

Antoine Smith, a police officer for the City of Cedar Rapids, was ordered to retake his official photo, which he refused. This led to a formal administrative investigation by the Cedar Rapids Police Department. Smith was notified of the investigation and later interviewed, during which he admitted to violating the department's code of conduct. The investigation concluded with a recommendation for a ten-hour suspension without pay and a requirement for Smith to retake his photo. Smith's counsel requested the investigation results and materials, which were denied until after the disciplinary decision was made.The Iowa District Court for Linn County granted summary judgment in favor of the City, concluding that the City did not violate Iowa Code section 80F.1(3) or 80F.1(9) by withholding the investigative materials until after the disciplinary decision. Smith appealed this decision.The Iowa Supreme Court reviewed the case and affirmed the lower court's decision. The court held that under Iowa Code section 80F.1(3), an officer is entitled to the results of an investigation only after the agency has made a final determination, including whether discipline will be imposed. Similarly, under section 80F.1(9), the officer is entitled to investigative materials only after discipline is decided. The court concluded that the City did not violate these provisions by waiting until after the disciplinary decision to provide the requested materials. The court emphasized that the statutory language clearly conditions the rights to these materials on the imposition of discipline. View "Smith v. City of Cedar Rapids" on Justia Law

Marlene Banwart and her husband Richard filed a medical malpractice lawsuit in 2020 against Neurosurgery of North Iowa, P.C., Dr. David Beck, and Dr. Thomas Getta. Marlene had undergone a lumbar laminectomy performed by Dr. Beck in July 2018, followed by severe postoperative pain and complications, including an epidural hematoma that required emergency surgery. The plaintiffs alleged negligence in the surgery and postoperative care by Dr. Beck and Dr. Getta.The Iowa District Court for Cerro Gordo County ruled on cross-motions for summary judgment. The court dismissed the plaintiffs' action as time-barred, concluding that the Iowa Supreme Court's emergency supervisory orders tolling the statute of limitations during the COVID-19 pandemic were invalid. However, the court found that the plaintiffs had substantially complied with Iowa's certificate of merit affidavit statute, despite the certificates not being signed under oath or penalty of perjury. Both parties appealed these rulings.The Iowa Supreme Court reviewed the case and bypassed the statute of limitations issue, focusing on the cross-appeal regarding the certificate of merit. The court held that the plaintiffs' certificates did not substantially comply with Iowa Code section 147.140 because they were not signed under oath or penalty of perjury. The court also rejected the plaintiffs' claims that the statute was void for vagueness and that the defendants had waived their rights by delaying their challenge. Consequently, the court reversed the district court's ruling on the certificates of merit and remanded the case for entry of summary judgment in favor of the defendants. View "Banwart v. Neurosurgery of North Iowa, P.C." on Justia Law