UPDATES & ANALYSIS

Iowa Court of Appeals February 2024 Published Opinion Roundup

by Matt McGuire | February 23, 2024

The Iowa Court of Appeals selects certain opinions for publication within the North Western Reporter. On February 9, 2024, the Court of Appeals selected three opinions for publication, summarized below:

State of Iowa v. Rickie Matrese Perkins, No. 22-1224

Opinion Date: October 11, 2023

On appeal from Iowa District Court for Black Hawk County

Issue:

• Whether the district court erred in denying Perkins’s motion to suppress evidence on the grounds that the officer had both probable cause and reasonable suspicion to initiate a traffic stop.

Rickie Matrese Perkins was convicted of operating while intoxicated. Before the district court, Perkins moved to suppress evidence from his traffic stop, arguing that the arresting officer lacked probable cause or reasonable suspicion to pull his vehicle over for speeding. The district court found that the officer who arrested stopped Perkins, Jordan Ehlers, observed Perkins’s vehicle “traveling at a high rate of speed” and estimated that Perkins was traveling at a speed in excess of the speed limit before initiating a stop. The Court found that Ehlers had both probable cause and reasonable suspicion for the stop, based on his observation of the vehicle’s speed and corroborating squad car footage. The Court emphasized Ehlers’s experience and training in speed estimation, affirming the district court’s ruling. Judge Thomas Bower authored the opinion of a unanimous panel.

State of Iowa v. Grubbs, No. 23-0065

Opinion Date: December 6, 2023

On appeal from Iowa District Court for Scott County

Issue:

• Whether the district court improperly considered the community’s issues with firearm violence in issuing a sentence to a criminal defendant.

The Iowa Court of Appeals affirmed a five-year prison sentence imposed on Jayvon Jamere Grubbs for being a felon in possession of a firearm, rejecting his claim that the district court relied on an improper factor by referencing the community’s issue with firearm violence. The Court found that considering the community’s problems with firearm violence did not constitute consideration of an improper sentencing factor, aligning with past decisions in similar cases. The district court weighed both positive aspects of Grubbs’ character and the seriousness of firearm violence in the community, concluding that incarceration was appropriate. The Court of Appeals held that this decision was in line with the court’s responsibility to protect the community and did not represent an abuse of discretion. Judge Mary Chicchelly authored the opinion of a unanimous panel.

Archer Daniels Midland v. Richie Williams, No. 22-2075

Opinion Date: December 20, 2023

On appeal from Iowa District Court for Polk County

Issues:

• Whether a workers’ compensation claimant preserved error on the issue of his injury being considered a scheduled shoulder injury.
• Whether the claimant was entitled to healing period benefits for days he called in sick due to shoulder pain.

Richie Williams filed a workers’ compensation claim seeking benefits for an injury he argued affected his body as a whole, and for healing period benefits for days he called in sick prior to the injury. The deputy commissioner determined the injury was to a scheduled member (shoulder) and denied healing period benefits for absences before the injury. The workers’ compensation commissioner affirmed.

Both parties filed petitions for judicial review, with Williams challenging both findings and the employer, Archer Daniels Midland (ADM), contested whether Williams preserved error as to the challenge to the scope of his injury. The district court reversed the commissioner’s decision regarding the scope of Williams’ injury, remanding for further findings, but upheld the denial of healing period benefits.

The Iowa Court of Appeals reversed the district court’s decision on the scope-of-injury issue, finding Williams did not preserve error because he introduced a new argument on judicial review not considered by the agency. On the second issue, the court affirmed the district court’s decision, upholding the commissioner’s denial of additional healing period benefits to Williams. The court of appeals found substantial evidence supported the commissioner’s decisions, emphasizing the proper procedures for preserving issues for review and the requirements for entitlement to healing period benefits. Judge Paul Ahlers authored the opinion of a unanimous panel.

Tags: Iowa Supreme Court 2023-24