UPDATES & ANALYSIS

3.05

January 2026 Opinion Roundup

by Matt McGuire | March 5, 2026

The Iowa Supreme Court entered opinions in ten cases in January 2026. At the links immediately below, you can read On Brief’s analysis of the following opinions:

• Betz v. Mathiesen et al., No. 23-1794, concerning when a party is on notice of a potential defamation claim sufficient to trigger the statute of limitations;
• State v. TikTok, Inc. et al., No. 24-1566, concerning whether online video provided TikTok possesses sufficient contacts with Iowa to confer personal jurisdiction in Iowa;
• State Public Defender v. Iowa District Court for Scott County, No. 25-0011, concerning courts’ discretion to refuse to allow public defenders to withdraw from criminal defense representations;

The remaining opinions from January are summarized below.

 

State of Iowa v. Ronald Richard Pagliai, No. 24–0353
Opinion date: January 9, 2026
On appeal from the Iowa District Court for Polk County

Issues:

• Whether a district court may assess costs against a defendant in a criminal case that has been dismissed.

Ronald Pagliai was charged with theft in the third degree in three separate cases and interference with official acts in a fourth case. As part of a plea agreement, Pagliai pleaded guilty in two theft cases, and the State agreed to dismiss the remaining two cases with Pagliai paying costs in the dismissed cases. The district court entered dispositional orders assessing costs against Pagliai in the dismissed cases. Pagliai appealed, challenging the district court’s authority to assess those costs.

The Supreme Court conditionally vacated the convictions, sentences, and dispositional orders and remanded the case with instructions, holding that no statute authorizes a district court to assess costs in a dismissed criminal case, and therefore the dispositional orders assessing costs were invalid. The Court reasoned that the legislature possesses the sole power to prescribe punishment for crime, and the district court’s dispositional authority is prescribed by statute. The Court explained that a bargained-for but unauthorized disposition impermissibly shifts lawmaking authority from the legislature to the parties and the courts. The Court distinguished Pagliai’s situation from prior cases allowing parties to bargain for cost apportionment in multicount actions where a conviction was entered, noting those cases involved a judgment of conviction in the case.

The Court’s opinion allowed the prosecutor to elect on remand between vacating only the unauthorized dispositional orders or vacating the entire plea bargain and reinstating charges in all four cases. Justice McDonald authored the opinion of the Court, joined by Justices Mansfield, Oxley, and May.

Justice McDermott concurred in the judgment, arguing that assessing costs on a dismissed charge violates the constitutional presumption of innocence under the federal and state Due Process Clauses.

Justice Waterman dissented, joined by Chief Justice Christensen, arguing that Pagliai waived any objection to the court’s lack of authority when he entered the plea agreement and that defendants should be able to agree to pay costs on dismissed counts as part of a plea bargain.

 

Mark Fink and Stacey Fink v. Donald Lawson and Linda Lawson, No. 23–1845
Opinion date: January 9, 2026
On further review from the Iowa Court of Appeals

Issues:

• Whether a district court has the power to reform a faulty easement deed so that it complies with the express intent of the grantor and the actual agreement of the parties.

This dispute arose over an easement granting river access to Lake Delhi in Delaware County. In 2002, the Lawsons purchased property from the Mary L. Becker Trust, and the trust executed a deed purporting to grant the Lawsons an easement across neighboring lots for access to the Maquoketa River. However, the easement deed contained defects: the grantor trust did not actually own the land over which the easement was granted, and the legal description did not reach the river’s edge. For nearly twenty years, the Lawsons used a well-worn path to access the river without incident. In 2021, after new neighbors, the Finks, purchased the lots, disputes arose, and the Finks sued to quiet title. The district court refused to reform the easement deed, and the Court of Appeals affirmed in part and reversed in part.

The Supreme Court vacated the Court of Appeals’ opinion, reversed the district court judgment, and remanded with instructions to reform the easement deed. It held that the district court erred in concluding it lacked authority to reform the faulty deed.

The Court reasoned that in interpreting a deed, the intent of the grantor is the “polestar.” The deed’s stated purpose—granting river access—was clear, and the Lawsons and Beckers mutually understood the easement’s scope based on their long course of conduct. The Court found that the naming of the wrong trust as grantor was a scrivener’s error because Mary Becker served as co-trustee of both trusts with independent authority to dispose of property. Regarding the faulty legal description, the Court relied on the principle that where both parties were mutually mistaken about the property description, and the grantor’s intent is clearly expressed, a court sitting in equity may reform the deed. The Court noted the Finks were not bona fide purchasers harmed by reformation because they knew of the easement’s existence and its legal infirmities before purchasing. Justice Waterman authored the opinion of the Court, in which all participating justices joined. Justices Mansfield and May took no part in the consideration or decision of the case.

 

Sara Montague, individually, as parent and next friend of C.M., and as representative of the Estate of Robert McFarland, deceased v. Beth Skinner et al., No. 24–1745

Opinion date: January 9, 2026
On appeal from the Iowa District Court for Jones County

Issues:

• Whether Iowa workers’ compensation law bars gross negligence claims by a state employee against state co-employees.
• Whether the plaintiff adequately exhausted administrative remedies under the Iowa Tort Claims Act by identifying all culpable state employees in her administrative claims.

On March 23, 2021, two inmates at Anamosa State Penitentiary armed with hammers from the prison machine shop killed corrections officer Robert McFarland and a nurse during an escape attempt. McFarland’s surviving spouse, Sara Montague, filed gross negligence claims against numerous former co-employees, alleging serious security lapses allowed the inmates to enter the infirmary with weapons. The defendant state employees moved to dismiss, arguing that workers’ compensation law barred such claims by public employees and that Montague had failed to comply with the administrative claims process of the Iowa Tort Claims Act. The district court denied the motion, and the defendants appealed.

The Supreme Court treated the defendants’ appeal as an application for interlocutory review, and affirmed in part and reversed in part the district court’s ruling. The Court held that workers’ compensation law does not bar gross negligence claims by state employees against co-employees. The Court reasoned that Iowa Code section 85.2, which makes workers’ compensation “exclusive, compulsory, and obligatory” for state and local governments, means the chapter as a whole applies, including section 85.20(2)’s express carveout permitting co-employee gross negligence claims. The Court noted that section 85.2 dates back to 1913 and merely indicated that public employers could not opt out of the workers’ compensation system, unlike private employers who originally had that choice.

However, the Court held that Montague could only proceed against those state employees she had identified by name during the ITCA administrative claims process, requiring dismissal of the claims against those defendants. Justice Mansfield authored the opinion of the Court, in which all justices joined.

 

Jacob M. Rose and Jeremy P. Rose v. Oakland Healthcare Management, LLC, d/b/a Oakland Manor, No. 23–1788
Opinion date: January 23, 2026
On further review from the Iowa Court of Appeals

Issues:

• Whether the plaintiffs presented sufficient evidence of reckless or willful misconduct to overcome statutory immunity under Iowa’s COVID-19 Response and Back-to-Business Limited Liability Act.

Jacob (Jack) Rose was a resident of Oakland Manor, a skilled nursing facility, when he tested positive for COVID-19 and subsequently died in August 2020. A Centers for Medicare and Medicaid Services (CMS) report identified deficiencies in Oakland Manor’s infection-control practices, including improper sanitization, incomplete hand hygiene, inconsistent personal protective equipment use, and failure to completely seal an isolation area. Jack’s sons brought wrongful death and other claims against the facility. Oakland Manor moved for summary judgment based on statutory immunity under Iowa Code chapter 686D, which shields health care providers from COVID-19-related liability absent reckless or willful misconduct. The district court granted summary judgment, and a divided Court of Appeals affirmed.

The Court affirmed the district court judgment, holding that the plaintiffs failed to present sufficient evidence to create a triable issue of fact on whether Oakland Manor acted recklessly.

Under Iowa law, recklessness requires more than the unreasonable risk of harm present in ordinary negligence. To establish recklessness, a plaintiff must prove the actor intentionally performed an unreasonable act, in disregard of a known or obvious risk, making it highly probable that harm would follow. The deficiencies identified in the CMS Report—inconsistent sanitization, incomplete PPE use, an incompletely sealed isolation area—reflected lapses in execution rather than intentional acts done with conscious disregard of risk. The Court noted these are “the very type of shortcomings for which the legislature eliminated civil liability as a matter of public policy.” The Court also found the plaintiffs’ expert opinion insufficient because it was conclusory, lacking factual detail or analysis supporting an inference of intentional conduct rather than mere negligence. Justice McDonald authored the opinion of the Court, in which all justices joined.

 

Victoria Abrahamson et al. v. Benjamin Scheevel et al., No. 24–1133
Opinion date: January 30, 2026
On further review from the Iowa Court of Appeals

Issues:

• Whether the two-year statute of limitations under the Iowa Municipal Tort Claims Act applies to claims for improper access to and dissemination of confidential criminal history and intelligence data.
• When the plaintiffs bringing claims for improper access to and dissemination of confidential criminal history and intelligence data suffered their injury for purposes of calculating the applicability of the statute of limitations.

Ten plaintiffs sued a former Estherville police officer, the police chief, and the City of Estherville, alleging that the officer improperly accessed and disseminated confidential criminal history and intelligence data for personal purposes, including stalking and harassing some of the plaintiffs and aiding a private vehicle repossession company. The plaintiffs alleged the misconduct ended by the time the officer resigned on May 3, 2019, but the plaintiffs did not file suit until July 2023. Several plaintiffs claimed they did not learn of the misconduct until 2021 or 2022. The district court denied the defendants’ motion to dismiss on statute of limitations grounds, but the Court of Appeals reversed.

The Supreme Court affirmed the decision of the Court of Appeals and remanded for dismissal of the action, holding that the claims were time-barred under the two-year statute of limitations in the Iowa Municipal Tort Claims Act. The Court held that language in Iowa Code section 692.6, which states that a person or governmental body proven to have violated chapter 692 shall be liable for damages, costs, expenses, and reasonable attorney fees “notwithstanding any provisions of chapter 6[6]9 [or] 670 to the contrary,” did not override the statute of limitations contained within section 670.5 The Court held that section 692.6 merely authorizes a plaintiff to sue for damages, as governed by the statute of limitations and other procedural rules.

The Supreme Court also held that the plaintiffs possessed a cause of action at the moment their confidential data were accessed and disseminated. The Court concluded that each plaintiff suffered a legally compensable injury no later than May 2019, when the wrongful acts occurred, making the July 2023 lawsuit untimely. Justice Mansfield authored the opinion of the Court, in which all justices joined.

 

State of Iowa v. Malorie Lynn Hallock, No. 24–1166
Opinion date: January 30, 2026
On further review from the Iowa Court of Appeals

Issues:

• Whether a defendant must object at sentencing to an oral victim-impact statement to preserve error for appeal.

Malorie Hallock pleaded guilty to first-degree theft after embezzling approximately $120,000 from her employer over nine months. Both parties recommended a deferred judgment. At sentencing, the business owner delivered an oral victim-impact statement describing the financial and emotional effects of the embezzlement. The district court rejected the parties’ joint recommendation and sentenced Hallock to the maximum penalty of imprisonment for an indefinite term not to exceed ten years. On appeal, Hallock argued the district court improperly considered unproven allegations contained in the victim-impact statement. The Court of Appeals affirmed, holding Hallock failed to preserve error by not objecting to the statement at sentencing.

The law states that a person or governmental body proven to have violated chapter 692 shall be liable for damages, costs, expenses, and reasonable attorney fees “notwithstanding any provisions of chapter 6[6]9 [or] 670 to the contrary.”

Court vacated the court of appeals decision but affirmed the district court judgment.  It held that a defendant need not object to an oral victim-impact statement presented for the first time at sentencing to preserve error, but concluded the district court did not rely on improper sentencing factors and did not abuse its discretion.

The Court reasoned that procedural errors at sentencing are generally excepted from normal error preservation requirements and may be raised for the first time on appeal. The Court distinguished the presentence investigation report, where error preservation is required because defense counsel receives it in advance and has an opportunity to object. For an oral victim-impact statement delivered for the first time at sentencing, requiring the defendant to object contemporaneously would be “exceedingly unfair” because the defendant and counsel have had no preview or opportunity to consult. The Court also noted that requiring objections during victim statements is unfair to victims and largely unnecessary because courts are presumed to “filter out” improper material absent clear evidence to the contrary.

On the merits, the Court found the victim-impact statement was “overwhelmingly appropriate” and there was no indication the district court relied on any improper material. The Court also found no abuse of discretion, noting Hallock’s age, prior theft conviction, the large amount stolen, and the prolonged nature of the offense. Justice Mansfield authored the opinion of the Court, in which all justices joined.

 

State of Iowa v. Douglas Neal Warburton, No. 24–1143
Opinion date: January 30, 2026
On further review from the Iowa Court of Appeals

Issues:

• Whether the defendant’s notice of appeal of a final judgment was sufficient to bring the district court’s denial of a motion for resentencing within the scope of appellate review.
• Whether the defendant was entitled to resentencing to allow a victim-impact statement to be presented.

Douglas Warburton pleaded guilty to lascivious acts with a child and was sentenced to incarceration for up to ten years plus lifetime supervision. At sentencing, the prosecutor noted that no victim-impact statement had been received. The day after sentencing, Warburton moved for resentencing, claiming the victim had provided a written statement after the hearing advocating for Warburton not to be sentenced to prison. The prosecutor’s resistance stated the written statement appeared to have been created after sentencing. The district court denied the motion. The Court of Appeals concluded it lacked jurisdiction to address the denial of the motion for resentencing because it was not specifically identified in the notice of appeal from the district court’s judgment.

The Supreme Court affirmed the Court of Appeals opinion decision in part and vacated it in part, and affirmed the district court judgment. The Court held that the notice of appeal was sufficient to bring the denial of the motion for resentencing within the scope of review, but the district court did not err in denying the motion.

The Court held that once an appellate court has jurisdiction over a case, it has jurisdiction over all issues presented, and notices of appeal are liberally construed. Because Warburton’s notice stated it was an appeal from the final judgment and “all adverse rulings therein,” and because the motion for resentencing directly challenged the validity of the sentencing proceeding, the denial was within the scope of review.

On the merits of Warburton’s motion, the Supreme Court found no error because a defendant generally has no entitlement to a second sentencing, and the circumstances indicated the victim-impact statement was likely generated after sentencing. The Court also emphasized that the victim’s statutory right to make a statement is an entitlement for the victim, not the defendant, and a defendant cannot compel a victim to provide a statement. Justice McDonald authored the opinion of the Court, in which all justices joined.

Tags: Iowa Supreme Court 2025-26