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July 2026 Iowa Court of Appeals Published Opinions Roundup
The Iowa Court of Appeals selects certain opinions for publication in the Northwestern Reporter. In July, the Court of Appeals selected two opinions for publication. Following are summaries of those opinions.
Iowa Supreme Court Limits Human Trafficking Liability Under 2024 Statute, Requiring an Actual Victim
The Iowa Supreme Court affirmed dismissal of a human trafficking charge and clarified that, under the 2024 statute, a defendant cannot commit human trafficking by attempting to buy sex from a victim who does not exist.
Iowa Supreme Court affirms child endangerment convictions and extends emotional harm theory to siblings
In a 5–2 decision filed on June 12, 2026, the Iowa Supreme Court in State v. Gibbs upheld a mother’s three child endangerment convictions under Iowa Code section 726.6(1)(a). Chief Justice Christensen wrote the majority opinion, joined by Justices McDonald, Oxley, McDermott, and May. Justice Mansfield filed a partial dissent, joined by Justice Waterman, concurring as to two convictions but dissenting as to the third.
Iowa Supreme Court upholds harassment conviction and clarifies that a defendant need not initiate contact to commit harassment
In a unanimous decision filed on May 22, 2026, the Iowa Supreme Court in State v. Hall held that a defendant need not be the person who initiated an encounter to commit harassment.
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First, Justice Oxley noted the Court has “never affirmatively recognized a viable negligent supervision claim in favor of a plaintiff suing her own employer based on the wrongful conduct of a coemployee.” Some federal courts have recognized such a common law claim, but others found such claims to be preempted by the ICWA. The IWCA contains an exclusivity provision that preempts common law claims that overlap with claims under the IWCA. The exclusivity provision applies to intentional torts in the workplace and negligent supervision and retention by an employer. For the exclusivity provision to apply the employee’s injury must “arise out of and in the course of employment,” requiring a causal connection between the injury and employment.