UPDATES & ANALYSIS

January 2024 Opinion Roundup

by Matt McGuire | February 28, 2024

The Iowa Supreme Court entered opinions in six cases during January 2024. You can read Rox Laird’s analysis of In re Detention of Schuman and Chicoine v. Wellmark, Inc. The remaining opinions from January are summarized below.

Lorri Hagen vs. Serta/National Bedding Co. LLC and Safety National Casualty Co., No. 22–0684

Opinion date: January 5, 2024

On further review from the Iowa Court of Appeals

• Whether the workers’ compensation commissioner abused his discretion by excluding untimely evidence from the claimant’s experts.

Lorri Hagen was injured at work and sought workers’ compensation benefits. During the workers’ compensation proceeding, Hagen failed to timely submit expert reports, leading to their exclusion by the commissioner. Hagen sought judicial review, and the district court reversed the commissioner’s ruling. The Court of Appeals affirmed, with one judge dissenting.

On Serta’s application for further review, the Iowa Supreme Court reversed the district court’s ruling and remanded. The Supreme Court emphasized that the commissioner possesses significant discretion in enforcing procedural rules and did not abuse his discretion in this case. Here, the expert reports disclosed new opinions roughly two weeks before the hearing, and the Court held that the commissioner was within his discretion to conclude that this belated disclosure prejudiced Serta. Chief Justice Christensen authored the opinion of a unanimous Court.

In re Marriage of Mary C. Frazier and Shannon L. Frazier, No. 22–0686

Opinion date: January 12, 2024

On further review from the Iowa Court of Appeals

• Whether the district court has authority to make decisions regarding the vaccination of children in cases where divorced parents with joint legal custody disagree and have not sought modification of custody.

Mary Streicher and Shannon Frazier were divorced and shared joint legal custody of their children. Streicher and Frazier disagreed as to whether their children should be vaccinated against COVID-19, and Streicher petitioned the Iowa District Court for Clinton County for approval to vaccinate the children. The district court concluded it lacked authority to grant the relief requested and dismissed, but the Iowa Court of Appeals reversed and remanded.

On further review, the Iowa Supreme Court vacated the Court of Appeals’ decision and affirmed the district court’s dismissal of Streicher’s petition. The Court concluded that without an existing agreement or court order specifying otherwise, neither parent with joint legal custody has authority to unilaterally make decisions about major aspects of their children’s lives, including vaccination. In the absence of mutual agreement between the parents or modification of the custody agreement, a court lacks power to diminish one parent’s equal decision-making rights. Chief Justice Christensen authored the opinion of a divided Court, joined by Justices Mansfield, Oxley, and McDermott. Justice Waterman took no part in the decision.

Justice McDonald dissented, joined by Justice May. Justice McDonald’s dissent criticized as unduly narrow the majority’s interpretation of the district court’ s powers to resole impasses between joint legal custodians over children’s care. Justice McDonald argued that the district court, as a court of general jurisdiction with inherent equitable powers, should have the authority to interpret, enforce, and apply decrees to settle disputes between joint legal custodians without necessitating a petition to modify custodial rights.

State of Iowa v. Nelson Carlos Flores, No. 21–1676

Opinion Date: January 26, 2024

On further review from the Iowa Court of Appeals

• Whether the district court erred in admitting a video recording of a forensic interview with a child sex abuse victim after the defendant’s cross-examination highlighted inconsistencies with the victim’s trial testimony.
• Whether the video’s admission was harmless in light of the evidence of the defendant’s guilt.

Nelson Carlos Flores was convicted of sexually abusing a minor. During trial, the defense’s cross-examination of the victim at trial prompted the prosecution to seek to introduce a video of the child’s forensic interview in response. The Iowa District Court for Crawford County allowed the video to be introduced into evidence pursuant to the rule of completeness, Iowa Rule of Evidence 5.106. Flores appealed, arguing that the video should not have been shown to the jury, among other grounds. The Iowa Court of Appeals questioned whether the district court should have allowed the entire video to be shown but concluded any error was harmless, and it affirmed Flores’s conviction.

On application for further review, the Iowa Supreme Court vacated the Court of Appeals’ opinion regarding the admissibility of the video but otherwise affirmed. The Supreme Court concluded that the district court was within its discretion to allow the entire video interview to be played to assist the jury in determining whether the child’s interview actually was insistent with her trial testimony. The Court noted that it may not always be appropriate to play the entire interview in every scenario where a video is being introduced under the rule of completeness. Justice Waterman authored the opinion of a unanimous Court.

State of Iowa v. Demetrias Martin, No. 21–0102

Opinion Date: January 26, 2024

On further review from the Iowa Court of Appeals

• Whether the district court erred in considering a risk assessment in sentencing without detailed information on its methodology.

Demetrias Martin was convicted of first-degree robbery and sentenced to 25 years with a 70% mandatory minimum requirement. Martin appealed, and the Iowa Court of Appeals affirmed. Martin argued the Iowa District Court for Scott County erred in considering a risk assessment indicating a “high” risk of violent recidivism, which Martin argued was considered without sufficient detail on its methodology, violating his due process rights.

The Iowa Supreme Court affirmed both lower-court rulings, concluding that the district court did not abuse its discretion in sentencing. The Court noted that procedural mechanisms exist for defendants to challenge presentence investigation reports, including risk assessments. Martin’s failure to utilize these mechanisms or present evidence challenging the assessment’s conclusions meant he did not demonstrate that the district court’s reliance on the assessment was unfounded. In addition, the Court concluded that it is not necessary for a district court to possess detailed information regarding the methodology of risk assessments before considering in sentencing. Justice McDermott authored the opinion of a unanimous Court.

Tags: Iowa Supreme Court 2023-24