UPDATES & ANALYSIS

October 2025 Opinion Roundup

by Matt McGuire | January 6, 2026

The Iowa Supreme Court entered opinions in four cases in October 2025. At the following link, you can read On Brief’s analysis of State v. Manning, concerning whether an officer’s body camera capture of a video being played for the officer qualifies as admissible evidence, by Rox Laird. The remaining opinions from October are summarized below.

Den Hartog Industries and West Bend Mutual Insurance Company v. Tyler Dungan, No. 23-1402

Opinion date: October 3, 2025
On further review from the Iowa Court of Appeals

Issues:

• Whether Iowa Code section 85.34(2)(v) requires compensation for an unscheduled injury based on functional impairment rather than loss of earning capacity when the employee returns to work at the same or greater wages.

Tyler Dungan injured his back at work and later held jobs paying the same or more than his pre-injury wage. The workers’ compensation commissioner awarded permanent partial disability based on industrial disability (loss of earning capacity), which the district court and a divided court of appeals affirmed. The Iowa Supreme Court granted further review.

The Court vacated the court of appeals’ decision, reversed the district court, and remanded to the commissioner to calculate benefits based solely on functional impairment. The Court held that section 85.34(2)(v)’s plain text requires the functional‑impairment method when an employee returns to work at the same or greater earnings and is not terminated by the same employer, and that contrary policy arguments cannot overcome the statute’s language.

The Court reasoned that sentence 3 of section 85.34(2)(v) distinctly directs that compensation “shall be” based only on functional impairment when the employee returns at the same or greater earnings. Sentence 4 provides a review‑reopening pathway using the industrial method only if the employee returns to the same employer and is later terminated; that did not occur here. The Court rejected characterizations of the statute as ambiguous or as creating a mandatory “bifurcated litigation process,” explaining that those readings would nullify sentence 3. The decision aligned with the Court’s 2024 opinion in Loew v. Menard, Inc., which treated functional impairment as the exclusive basis for calculating disability when the worker returned at equal or higher pay. Justice Mansfield authored the opinion for a unanimous Court.

A more detailed interpretation of the workers’ comp ramifications of this case written by Nyemaster’s workers’ comp legal team is available here.

State of Iowa v. Matthew James Meisheid, No. 23-1475

Opinion date: October 24, 2025
On further review from the Iowa Court of Appeals

Issues:

• Whether substantial evidence showed the defendant “displayed in a threatening manner any dangerous weapon toward another” under Iowa Code section 708.1(2)(c).

Deputies responded to a fireworks complaint and encountered Matthew Meisheid outside his home. During a heated exchange, Meisheid pulled a handgun from his waistband, raised it overhead, and said, “I’ll show you a firework,” causing the deputies to retreat. A jury convicted Mesheid of assault on peace officers with a dangerous weapon. The court of appeals affirmed; the Supreme Court granted further review on one question regarding sufficiency of the evidence.

The Supreme Court affirmed. It held that a rational jury could find that Meisheid “displayed” a dangerous weapon “toward” the deputies within the meaning of section 708.1(2)(c) and under the unobjected‑to jury instructions.

The Court explained that under the instructions, “displayed in a threatening manner” means making the existence of the weapon apparent so as to intimidate. The evidence—including body camera footage—showed Meisheid faced the deputies, produced the gun so they could see it, and announced he was “show[ing]” it in response to their inquiries, permitting the jury to conclude the display was directed “toward” them even if the muzzle was not pointed at them. The Court emphasized reading “toward” in context; a person can display an object toward someone by holding it up so it is visible, without aiming it at that person. Justice May authored the opinion for a unanimous Court.

Iowa Department of Health and Human Services v. Iowa District Court for Polk County, No. 24-0834

Opinion date: October 31, 2025
On further review from the Iowa Court of Appeals

Issues:

• Whether a juvenile court may temporarily suspend HHS’s planned change in a child’s placement to hold an evidentiary hearing reviewing the decision under Iowa Code section 232.102(1)(b)(1).
• Whether the dispute was moot and, if so, whether the public‑importance exception applies.

The Iowa Department of Health and Human Services (HHS) sought to move a toddler from her long‑term foster home to live with siblings. The child’s guardian ad litem requested review of the move. The juvenile court set an evidentiary hearing and temporarily prohibited the transfer until that hearing occurred. HHS sought certiorari, and the court of appeals sustained the writ. The Supreme Court granted further review.

The Supreme Court vacated the court of appeals’ decision and annulled the writ. It held that the juvenile court acted within its authority in temporarily staying the move to conduct an evidentiary hearing, emphasizing the statutory priority of the child’s best interests and chapter 232’s preventative and remedial character. The Court also reached the merits under the public‑importance exception to mootness.

The Court reasoned that section 232.102(1)(b)(1) gives HHS authority to select a placement within a court‑approved category “subject to court review at the request of an interested party.” That review is not limited to after‑the‑fact challenges; a temporary stay may be necessary to avoid avoidable trauma and to ensure meaningful review focused on the child’s best interests. Interpreting review as only retrospective would hinder the court’s ability to prevent harm and would not conform to chapter 232’s directive to prioritize the child’s welfare, including the statutory standard requiring deference to but not blind acceptance of HHS’s decision. Chief Justice Christensen authored the opinion for a unanimous Court.

Tags: Iowa Supreme Court 2025-26