Justia Government & Administrative Law Opinion Summaries

Articles Posted in Iowa Supreme Court
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The Supreme Court affirmed the ruling of the district court dismissing an employee's gross negligence claim against a coemployee, holding that settlement documents submitted to and approved by the workers' compensation commissioner extinguished the employee's gross negligence claim.Plaintiff, an employee of Lutheran Services in Iowa (LSI) was attacked by one of LSI's clients, causing injuries. Plaintiff filed a workers' compensation claim against LSI and its workers' compensation carrier. The parties settled, and the two settlement documents were approved by the Iowa Workers' Compensation Commissioner. Plaintiff subsequently filed a petition in district court seeking to recover damages from Defendant, Plaintiff's supervisor when he worked at LSI, on a theory of gross negligence. Defendant moved to dismiss the action, relying on release language in the settlement documents. The district court granted summary judgment for Defendant on both contract and statutory grounds. The court of appeals reversed, concluding that a settlement with the commissioner did not release a common law claim of gross negligence against a coemployee. The Supreme Court vacated the court of appeals' judgment and affirmed the district court's summary judgment, holding that the district court properly ruled that, as a matter of contract, the language in the terms of settlement extinguished Plaintiff's gross negligence claim. View "Terry v. Dorothy" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the district court reversing the decision of the Iowa Department of Human Services (DHS) that a child-care provider must pay back benefits the provider received during agency review of her cancelled provider agreement, holding that DHS erred in refusing to consider the provider's unjust enrichment defense to the recoupment proceeding.At issue was whether the provider was given constitutionally sufficient notice of DHS's intent to recoup payments. DHS sent the provider a notice cancelling the provider agreement and noted that any benefits the provider got while her appeal was being decided "may have to be paid back if the Department's action is correct." DHS affirmed its decision to cancel the provider's agreement but did not find, until years later, that the provider had to pay back the $16,000. The district court reversed DHS's decision on recoupment and denied attorney fees under Iowa Code 625.29(1)(b). The Supreme Court reversed in part, holding (1) DHS's notice met procedural due process requirements, but the DHS should have been allowed an opportunity to raise unjust enrichment as an offset to DHS's effort to recoup overpayments; and (2) where DHS's role was primarily adjudicative, DHS was not liable for attorney fees. View "Endress v. Iowa Department of Human Services" on Justia Law

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The Supreme Court affirmed in part and vacated in part the court of appeals' decision and affirmed in part and reversed in part the judgment of the district court, holding that a child-care provider whose provider agreement and registration was cancelled should be allowed to raise unjust enrichment as an offset to the Iowa Department of Human Services' (DHS) effort to recoup $31,815 for child-care services the provider rendered during agency review.This appeal was a companion case to Endress v. Iowa Department of Human Services, __ N.W.2d __ (Iowa 2020), also decided today. DHS attempted to recoup child-care service payments during agency review of the provider's cancelled provider agreement and registration. On appeal, the court of appeals held that DHS's notice concerning recoupment of overpayments was constitutionally deficient. The Supreme Court (1) vacated the court of appeals' decision on the constitutional issue, holding that DHS's notice of recoupment met procedural due process requirements; and (2) remanded the case to the district court to remand to DHS for consideration of the provider's equitable relief, holding that the provider should have been allowed to pursue her claim for unjust enrichment. View "Pfaltzgraff v. Iowa Department of Human Services" on Justia Law

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The Supreme Court reversed the judgment of the district court dismissing Appellant's petition for judicial review, holding that timely faxing a petition for judicial review to the opposing party's counsel, where the petition is actually received and no prejudice results, constitutes substantial compliance under Iowa Code 17A.19(2).Appellant filed four petitions with the Iowa Workers' Compensation Commission against Respondents, her employer and its workers' compensation insurance carrier, alleging that she received several workplace injuries. The commissioner largely denied the petitions. Appellant then filed a pro se petition with the district court seeking judicial review. The petition was electronically filed, and Appellant faxed copies the same day to Respondents and the workers' compensation commission. The district court granted Respondents' motion to dismiss, concluding that Appellant's sending of a fax of her petition was not substantial compliance with the requirements of section 17A.19(2). The Supreme Court reversed, holding that Appellant substantially complied with the service requirements in section 17A.19(2). View "Logan v. Bon Ton Stores, Inc." on Justia Law

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The Supreme Court affirmed the order of the district court denying Claimant's petition for judicial review challenging the decision of the workers' compensation commissioner concluding that Claimant, who was receiving disability benefits for a traumatic injury, could not later recover disability benefits on a separate cumulative injury claim where the cumulative injury was based solely on aggravation of the earlier traumatic injury.Because the three-year statute of limitations for review-reopening had passed Claimant instead brought a separate cumulative injury claim. The commissioner declined to award benefits for the asserted cumulative injury. The district court upheld the commissioner's ruling. The court of appeals reversed, concluding that because Claimant was precluded by the statute of limitations from bringing an original proceeding or review-reopening she could recover by way of a cumulative-injury claim. The Supreme Court reversed, holding that sufficient record evidence sustained the commissioner's finding that Claimant's difficulties were merely the aggravation over time of her original injury and that Claimant did not suffer a distinct and discrete cumulative injury to support additional benefits. View "Gumm v. Easter Seal Society of Iowa, Inc." on Justia Law

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The Supreme Court vacated the court of appeals' decision affirming the district court's dismissal of a physician's petition for judicial review of the Iowa Board of Medicine's decision to use a "confidential letter of warning" to impose conditions on the physician's return to the practice of medicine over his objection, without a finding of probable cause, and without judicial review, holding that the district court erred by ruling that the Board's letter was not judicially reviewable.Before the physician voluntarily ceased practicing medicine the Board had opened an investigation into the physician. The Board closed the investigation without a finding of probable cause that the physician had violated any rule or standard of practice. In its letter, the Board told the physician that if he returned to practicing medicine he must complete a comprehensive clinical competency evaluation. The physician sought judicial review, contending that the Board's letter constituted illegal agency action. The district court dismissed the action, concluding that the letter was not a disciplinary sanction subject to judicial review. The Supreme Court vacated the decision, holding that the Board's letter was subject to judicial review because the physician was aggrieved by the Board's action where he was unable to resume practicing his profession without triggering the competency evaluation. View "Irland v. Iowa Board of Medicine" on Justia Law

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The Supreme Court reversed the judgment of the district court granting Plaintiff's petition for mandamus and ordering the City of Ottumwa to disclose names of all persons who had and had not been issued automated traffic enforcement (ATE) citations by the City after their vehicles were detected as speeding by an ATE camera, holding that the district court erred in ordering the production of records whose disclosure was prohibited by the Driver's Privacy Protection Act of 1994 (DPPA), 18 U.S.C. 2721-2725, and a corresponding Iowa state law, Iowa Code 321.11.In denying the request for names, the City argued that the DPPA and section 321.11 prohibited disclosure of the requested information. The district court disagreed, concluding that the names of speed regulation violators was information on driving violations and therefore was not confidential information under the DPPA or section 321.11. The Supreme Court reversed, holding that where the personal identifying information sought by Petitioner came from a vehicle registration and driver's license database, its public disclosure was presumptively prohibited under the DPPA and section 321.11. View "Milligan v. Ottumwa Police Department" on Justia Law

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The Supreme Court affirmed the judgment of the district court affirming the decision of the O'Brien County Board of Supervisors determining that two newspapers under common ownership and published in the same city could not be combined for purposes of determining circulation because the publications were not offered for sale or delivered "in the same geographic area" under Iowa Code 349.6, holding that the district court did not err.The two newspapers at issue were the Sanborn Pioneer and the O'Brien County's Bell-Times-Courier, both owned by Marcus News, Inc. Marcus News and Iowa Information, Inc. both submitted applications to the Board requesting that their newspapers be selected as official county publications. The Board concluded that the two newspapers of Marcus News should not be considered as one newspaper and, as a result, did not select the publications as official newspapers for O'Brien County. The district court affirmed. The Supreme Court also affirmed, holding that the district court correctly concluded that the two publications should not be combined and considered as one publication in the same geographic area. View "Marcus News, Inc. v. O’Brien County Board of Supervisors" on Justia Law

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The Supreme Court affirmed the district court's judgment upholding the revocation of a Driver's license, holding that this Court declines to overrule precedent and apply the exclusionary rule to driver's license revocation proceedings when an Iowa statute dictates otherwise.Driver in this case was pulled over by an officer with the Iowa Department of Transportation (DOT) after he made an unauthorized use of a median crossover to turn around and head in the other direction. Driver had an open container in his car and smelled of an alcoholic beverage, but Driver was never charged with operating while intoxicated (OWI). Adhering to precedent set in Westendorf v. Iowa Department of Transportation, 400 N.W.2d 553 (Iowa 1987), and Manders v. Iowa Department of Transportation, 454 N.W.2d 364 (Iowa 1990), in which the Court declined to apply the exclusionary rule to driver's license revocation proceedings so long as the enumerated statutory conditions for license revocation were met, the DOT upheld Driver's license suspension. The Supreme Court affirmed, holding that where the only flaw in the stop was the officer's lack of statutory authority, this Court declines to expand the legislature's post-Westendorf statutory exception and apply the exclusionary rule to all driver's license revocation proceedings if there was any problem with the stop. View "Westra v. Iowa Department of Transportation" on Justia Law

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The Supreme Court affirmed the decision of the district court affirming the Carroll County Board of Adjustment's denial of Appellants' application for a variance from Carroll County Airport Zoning Ordinance height restrictions, holding that this Court's opinion rejecting Appellants' preemption defense in a companion case, was fatal to Appellants' appeal of the zoning variance denial.Appellants built a grain leg on their farmland that violated the zoning ordinance's height restrictions. The Federal Aviation Administration (FAA) made a no-hazard determination. The Carroll Airport Commission disagreed with the FAA's determination and filed an equitable action to have the grain leg declared a nuisance. After Appellants unsuccessfully sought a variance, the district court entered judgment for the Commission on its nuisance claim. In both the nuisance action and the zoning appeal Appellants argued that the FAA's no-hazard determination preempted local regulations as a matter of law. The district court rejected that defense in the nuisance action. The court of appeals and Supreme Court affirmed. The district court then affirmed the Board's denial of the variance, again rejecting the preemption defense. Because the nuisance case adjudicated the same federal preemption issue Appellants raised in this preceding, the Supreme Court's opinion rejecting Appellants' preemption defense in the nuisance action was fatal to Appellants' appeal of the zoning appeal. View "Danner v. Carroll County Board of Adjustment" on Justia Law