Justia Civil Procedure Opinion Summaries

In this case, Scott Olson, an employee of BNSF Railway Company, sued the company under the Federal Employers' Liability Act, seeking damages for injuries he sustained in a workplace accident. A jury found in favor of Olson and awarded him significant damages. The railway company appealed, alleging three specific instances of error by the district court. The Supreme Court of Iowa vacated the decision of the court of appeals, which had granted a new trial, and affirmed the district court's judgment. The court held that the railway company did not properly preserve its challenge to the verdict form for appeal, as the company had failed to object to the form until after the jury returned its verdict. The court also ruled that the district court did not err by allowing Olson to present new negligence claims during the trial that were not alleged in the pleadings or identified during discovery, as the company was clearly on notice that Olson alleged that the company failed to reasonably train all employees as one of the specific allegations of negligence at trial. Lastly, the court found that the company was not prejudiced by Olson's counsel's alleged misconduct during his rebuttal closing argument. View "Olson v. BNSF Railway Company" on Justia Law

In the Supreme Court of Iowa, the appellants, the estate and family of Deanna Dee Fahrmann, had filed a wrongful-death action against ABCM Corporation and two of its employees, alleging nursing home malpractice. The appellants failed to serve a certificate of merit affidavit, required under Iowa Code section 147.140, signed by a qualified expert within sixty days of the defendants’ response to the claim. Instead, they served initial disclosures, signed only by their counsel, that named their expert within the statutory sixty-day deadline. After the deadline, the defendants moved to dismiss the case for noncompliance, and the appellants served a certificate signed by their expert and argued that they substantially complied with the statute. The district court dismissed the case based on the mandatory language of the statute.On appeal, the Supreme Court of Iowa affirmed the lower court's decision to dismiss the case. The court held that the plaintiffs' initial disclosure, signed only by their counsel, did not comply with or substantially comply with the certificate of merit requirement under section 147.140 of the Iowa Code. The law unambiguously required the plaintiffs to timely serve a certificate of merit affidavit signed under oath by a qualified expert stating the expert’s familiarity with the applicable standard of care and its breach by the defendants unless the parties extend the deadline by agreement or the plaintiffs show good cause to move for an extension within the sixty-day deadline. The plaintiffs' untimely service of a certificate signed by their expert did not constitute substantial compliance with the statute. Therefore, dismissal was mandatory under the plain language of the statute. View "The Estate of Deanna Dee Fahrmann v. ABCM Corporation" on Justia Law

The case involves an Iowa attorney, Marc Harding, who hired an Indiana-based doctor, Rick Sasso, to provide expert witness services in a potential medical malpractice suit in Iowa. After things did not go as planned, Harding sued Sasso in Iowa to recover a portion of the $10,000 retainer he had paid, plus additional damages. Sasso moved to dismiss the suit, arguing that the Iowa court did not have personal jurisdiction over him. The district court denied the motion, and Sasso appealed. The court of appeals reversed the district court's decision and ordered the case to be dismissed, but the Supreme Court of Iowa granted Harding's application for further review.The Supreme Court of Iowa held that the Iowa court could exercise personal jurisdiction over Sasso. The court found that Sasso had sufficient minimum contacts with Iowa to support the exercise of personal jurisdiction over him with respect to the contract dispute. Sasso had entered into a contractual relationship with Harding, who is an Iowa lawyer, and agreed to evaluate a medical malpractice claim involving Iowa residents and to provide expert testimony at any trial in the medical malpractice case, which would have been venued in Iowa. The court also found that the exercise of jurisdiction would not be unreasonable or offend traditional notions of fair play and substantial justice. Therefore, the Supreme Court of Iowa vacated the decision of the court of appeals, affirmed the district court's order denying Sasso's motion to dismiss, and remanded the case for further proceedings. View "Harding v. Sasso" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court denying three plaintiffs' motion for summary judgment in this suit brought to challenge the City of Des Moines' use of the state's income offset program to collect automated traffic citation penalties and granting summary judgment in favor of the City, holding that the district court erred in granting summary judgment as to a preemption claim and a claim for unjust enrichment.Specifically, the Supreme Court held that the district court properly dismissed Plaintiffs' claims that, among other things, the City's use of the income offset program amounted to an unconstitutional taking and that their right to procedural due process was violated. As to Plaintiffs' contention that the City's use of the program was preempted by state law, however, the district court reversed in part, holding that the district court erred in dismissing one plaintiff's preemption claim with respect to his requests for declaratory and injunctive relief and in dismissing two plaintiffs' claim for unjust enrichment. The Court remanded this case for further proceedings. View "Livingood v. City of Des Moines" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Exile Brewing Company's attempt to intervene in the underlying probate matter and striking Exile's motion to vacate, dismiss, and close two estates seeking to pursue certain claims, holding that the probate court did not err in denying the request to intervene and close the estates.During the 1950s and '60s, Ruth Bisignano owned and operated a popular bar in Des Moines. In 2012, Exile named one of its craft beers "Ruthie" and used Ruth's image. Ruthie died in 1993, and her estate was closed that year. Her husband Frank Bisignano died three years later, and his estate was closed in 1999. In 2020, Plaintiff successfully filed petitions to reopen both estates. Subsequently, as administrator of Frank's estate, Plaintiff sued Exile alleging common law appropriation and other claims. Exile filed a motion to vacate, dismiss, and close both estates, arguing that the probate court lacked statutory jurisdiction to reopen the estates. The probate court denied the motion, concluding that Exile had no right to intervene in the probate proceedings. The Supreme Court affirmed, holding that the probate court correctly determined that Exile was an interloper with no ability to challenge the estates' reopening. View "In re Estate of Bisignano" on Justia Law

The Supreme Court reversed the decision of the district court refusing to quash subpoenas that required production of documents and testimony for use in a Louisiana products liability lawsuit, holding that the subpoenas imposed undue burdens on Dethmers Manufacturing Company, an Iowa firm.The plaintiff in the products liability used Iowa's interstate discovery procedures to serve subpoenas on Dethmers, who was not a party to the Louisiana suit. The subpoenas required Dethmers to produce twenty-two categories of documents and testimony that were "extraordinarily broad." After Dethmers unsuccessfully moved to quash the subpoenas Dethmers brought this appeal. The Supreme Court reversed and remanded for entry of an order quashing the subpoenas, holding that the subpoenas were overly burdensome on their face and should be quashed. View "In re Subpoena Issued to Dethmers Manufacturing Co. v. Mittapalli" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the judgment of the district court concluding that Plaintiff's filed petition did not relate back to her previously rejected filing, holding that the district court did not err in granting Defendants' motion to dismiss.Plaintiff filed this personal injury suit against Defendants one day after the two-year statute of limitations set forth in Iowa Code 614.1(2). Defendants filed a motion to dismiss the petition on the grounds that Plaintiffs' claims were time-barred. In response, Plaintiff argued that her untimely petition related back to the date she attempted to file her petition but the clerk of court rejected it due to Plaintiff's failure to include personal identification information with the proposed filing. The district court dismissed the action, concluding that the filed petition did not relate back to the rejected filing. The court of appeals affirmed. The Supreme Court affirmed, holding that Plaintiff's filing did not relate back to her attempted filing. View "Carlson v. Second Succession, LLC" on Justia Law

The Supreme Court reaffirmed its holding in Schilling v. Iowa Department of Transportation, 646 N.W.2d 69 (Iowa 2002), that a deferred judgment counts as a "final conviction" for purposes of mandatory license revocation under Iowa Code 321.209 and noted that its intervening decision in State v. Tong, 805 N.W.2d 599 (Iowa 2011), did nothing to erode the Schilling.At issue was the use of a deferred judgment as one of the underlying convictions counted by the Iowa Department of Transportation to revoke Appellant's status as a habitual offender. Appellant's driver's license was revoked under section 321.209 for Appellant's having garnered three enumerated convictions in a six-year period, making him a habitual offender under Iowa Code 321.555(1). Appellant argued that the deferred judgment he received on the eluding charge was not a "final conviction" and could not be counted as one of the predicate convictions. The district court upheld the agency's decision, and the court of appeals affirmed. The Supreme Court affirmed, holding that the lower courts correctly declined to depart from Schilling. View "Johnston v. Iowa Department of Transportation" on Justia Law

The Supreme Court affirmed the judgment of the district court denying a citizen's quo warranto action asserting that a district judge was holding his office unlawfully, holding that this case presented a nonjusticiable controversy.In 2018, two finalists were sent to the Governor for a district judge position. Iowa law provides that, if the Governor fails to make an appointment within thirty days after a list of nominees has been submitted, the appointment shall be made by the Chief Justice of the Supreme Court. On a Thursday, the thirtieth day, the Governor communicated to her chief of staff the her selected nominee's identity - Jason Besler. The following Monday the Governor told Besler that he had been selected. The Chief Justice accepted the Governor's view that the appointment was timely. Gary Dickey, a private citizen, filed an application for leave to file a petition for writ of quo warranto alleging that Besler was holding the office of district judge unlawfully because the Governor failed to appoint Besler by the deadline for making an appointment. The district court denied the application. The Supreme Court affirmed, holding that because both the Governor and the Chief Justice deferred to and accepted the view that the appointment was timely, this quo warranto action was nonjusticiable. View "State ex rel. Dickey v. Besler" on Justia Law

The Supreme Court upheld the district court's order directing Plaintiff and/or his attorney to pay reasonable expenses associated with one of the defendant's attendance at a court-ordered pretrial settlement conference due to Plaintiff's failure to appear, holding that the district court did not abuse its discretion.Plaintiff failed personally to attend the settlement conference conference, despite pretrial orders and a local rule requiring his attendance. Defendants attended the conference, but Plaintiff did not. The district court refused to hold the conference without Plaintiff present and granted one of the defendant's motions for sanctions. The Supreme Court upheld the district court's order, holding that the district court did not exceed its jurisdiction or otherwise act illegally in finding Plaintiff in violation of the court's trial-setting order when he failed personally to appear for the scheduled settlement conference and in directing the specific sanction in this case. View "Davis v. Iowa District Court for Scott County" on Justia Law