Justia Civil Procedure Opinion Summaries

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

Marleny Rivas filed a lawsuit against Derek Brownell and Lindsey Wessel to recover damages for injuries she sustained in a car accident on August 4, 2018. Rivas filed her lawsuit on October 16, 2020, beyond the two-year statute of limitations but within a seventy-six-day tolling period established by a supreme court supervisory order due to the COVID-19 pandemic.The defendants filed motions for summary judgment, arguing that the lawsuit was time-barred as it was filed beyond the two-year statute of limitations and that the supreme court's tolling provision violated the separation of powers and their due process rights. The Iowa District Court for Polk County granted the summary judgment, concluding that the supreme court lacked the authority to toll the statute of limitations, and thus Rivas's lawsuit was untimely. Rivas appealed the decision.The Iowa Supreme Court reviewed the case and addressed whether the supreme court had the emergency powers to toll the statute of limitations during the pandemic. The court held that the tolling provision in the supervisory order was within the court's constitutional authority to exercise supervisory and administrative control over the court system. The court found that the tolling provision was a valid response to the unprecedented public health emergency and did not violate the separation of powers or due process rights of the defendants. Consequently, the court reversed the district court's order of dismissal and remanded the case for further proceedings. View "Rivas v. Brownell" on Justia Law

In 2016, a fourteen-year-old boy was involuntarily committed, disqualifying him from possessing firearms. Eight years later, he petitioned the district court to restore his firearm rights under Iowa Code section 724.31. The district court found that the statutory requirements were met and restored his firearm rights. The State appealed the decision.The Iowa District Court for Monona County initially reviewed the case and granted the petition to restore the petitioner’s firearm rights. The State then appealed the district court’s decision, arguing that the restoration requirements were not met and questioning the State’s right to appeal the decision.The Iowa Supreme Court reviewed the case and first addressed whether the State had the right to appeal the restoration order. The court concluded that the State did have the right to appeal under Iowa Rule of Appellate Procedure 6.103(1). The court then reviewed the merits of the case de novo and found that the petitioner had met the burden of proving by a preponderance of the evidence that he would not likely act in a manner dangerous to public safety and that granting the relief would not be contrary to the public interest. The court affirmed the district court’s order restoring the petitioner’s firearm rights. View "In re N.F." on Justia Law

Jessenia Burton, a student driver, was involved in a car accident during a drivers' education course on April 30, 2017. Burton and her parents sued several defendants, including West Bend Mutual Insurance Company, which provided coverage for the vehicles used in the course. Burton retained neuropsychologist Dr. Daniel Tranel, who conducted an evaluation and diagnosed her with a concussion, postconcussion syndrome, PTSD, and major depressive disorder. Dr. Tranel's report included summaries of psychological and neuropsychological tests administered to Burton.The Iowa District Court for Polk County granted West Bend's motion to compel the production of Dr. Tranel's psychological test material and test data. The court reasoned that since Burton made her mental condition an element of her claim, the information was discoverable under Iowa Code section 228.6(4)(a). The court ordered the information to be produced to West Bend and its attorneys, issuing a protective order to limit further disclosure.The Iowa Supreme Court reviewed the case and reversed the district court's decision. The court held that Iowa Code section 228.9 explicitly prohibits the disclosure of psychological test material and test data in a judicial proceeding to anyone other than a licensed psychologist designated by the individual. The court emphasized that the statute's language is clear and unambiguous, and the only exception to this prohibition is disclosure to another licensed psychologist. The court concluded that the district court erred in granting the motion to compel and vacated the protective order. The case was remanded for further proceedings consistent with this interpretation. View "Burton v. West Bend Mutual Insurance Company" on Justia Law

A vacancy on the Scott County Board of Supervisors occurred when Tony Knobbe resigned to become the Scott County Treasurer. A committee of county officials decided to fill the vacancy by appointment and kept certain applications confidential during the process. The committee referred to applicants by numbers and only revealed the name of the appointed individual. After the appointment, two individuals submitted open records requests for the confidential names and applications, which Scott County denied, citing Iowa Code section 22.7(18).The individuals filed a petition in the Iowa District Court for Scott County, which granted summary judgment in favor of Scott County, determining that the applications were exempt from disclosure under Iowa Code section 22.7(18). The district court relied on the precedent set in City of Sioux City v. Greater Sioux City Press Club, which held that employment applications could be kept confidential.The Iowa Supreme Court reviewed the case and reversed the district court's decision. The court held that the applications for the vacant county board of supervisors position were not confidential under section 22.7(18). The court reasoned that the applicants were not promised confidentiality beforehand, and the public nature of the appointment process meant it was not reasonable to believe that people would be deterred from applying if their applications were disclosed. The court ordered that the names and applications be disclosed and awarded costs and reasonable attorney fees to the plaintiffs. The case was remanded for further proceedings. View "Diercks v. Scott County, Iowa" on Justia Law

A man passed away, and his wife made a claim on his estate for half of the money he had removed from their joint bank account before his death. The wife argued that the couple owned the account as joint tenants, and her husband had withdrawn funds exceeding his interest. The district court dismissed her claim, concluding that she was making a claim for conversion sounding in tort and had not met the legal standard.The wife appealed, arguing that the district court applied the wrong legal standard and that a standard from caselaw on joint tenancies should apply. The Iowa Court of Appeals agreed with her, reversed the district court's decision, and remanded the case. The estate sought further review from the Iowa Supreme Court.The Iowa Supreme Court affirmed the decision of the Court of Appeals, holding that the district court applied an incorrect legal standard. The correct standard, as established in Anderson v. Iowa Department of Human Services, involves determining the respective rights of joint tenants based on their agreement and the presumption that each joint tenant is entitled to half of the joint account, which can be rebutted. The court remanded the case for a new trial to allow for proper fact-finding regarding whether the husband removed funds in excess of his interest in the joint account. View "In re Estate of Johnston" on Justia Law

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