Articles Posted in Iowa Supreme Court

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Jeffrey Anderson challenged a district court order placing him in a transitional release program at the Civil Commitment Unit for Sexual Offenders (CCUSO) as a violation of his due process rights. After a jury determined that Anderson was a sexually violent predator, Anderson was civilly committed to CCUSO under the Sexually Violent Predators Act. Anderson was later granted release with supervision but violated the terms of his release-with-supervision plan. The district court revoked Anderson’s release-with-supervision status and ordered him placed at a transitional release program housed at CCUSO. It was this order that Anderson challenged on appeal. The Supreme Court affirmed, holding that the order revoking Anderson’s release-with-supervision status and placing him at the transitional release program at CCUSO did not violate his substantive or procedural due process rights under either the Iowa Constitution or the United States Constitution. View "In re Detention of Jeffrey Anderson" on Justia Law

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On December 8, after a hearing, a judicial hospitalization referee entered an order finding M.W. seriously mentally impaired and ordered M.W. involuntarily hospitalized. M.W. appealed the denial of his motion to continue the hearing. On December 9, the district court entered a ruling determining that the referee did not abuse her discretion in denying M.W.’s motion to continue and noted that M.W. had the right to challenge all of the rulings of the referee at a de novo hearing before the district court. Thereafter, M.W. was released from involuntary hospitalization. The district court thus dismissed the case. M.W. appealed the December 8 referee order and the December 9 district court order. The Supreme Court dismissed the appeal, holding that neither the referee’s order issued on December 8 nor the district court’s order issued on December 9 were appealable as a matter of right. View "In re M.W." on Justia Law

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Several Iowa chiropractors brought this class-action lawsuit against Wellmark, Inc., Iowa’s largest health insurer, alleging that it conspired with competitors to fix prices, allocate markets, and engage in other anticompetitive conduct in violation of the Iowa Competition Law. The district court stayed the case pending further proceedings in federal multidistrict litigation (MDL) in Alabama brought under federal antitrust laws. The Supreme Court vacated the order staying this action, holding that the district court abused its discretion in staying the Iowa litigation pending further proceedings in the Alabama MDL because (1) resolution of the Alabama MDL could take years, and (2) there are considerable differences in the issues the two cases present. Remanded. View "Chicoine v. Wellmark, Inc." on Justia Law

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In 1986, the Iowa legislature enacted House File 2219 to provide for payment by healthcare service corporations for services performed by chiropractors. Following the Supreme Court’s decision in Mueller v. Wellmark, several Iowa-licensed chiropractors (collectively, Appellants) brought this action alleging that Wellmark, Inc. wrongfully imposes restrictions and pays lower rates for chiropractic services than for equivalent services offered by medical and osteopathic doctors in violation of Iowa Code 514F.2. The Insurance Commissioner concluded that section 514F.2 does not require health insurers to compensate the chiropractors equally with medical and osteopathic doctors in network. The district court affirmed the Commissioner’s decision. The Supreme Court affirmed, holding (1) the interpretation of section 514F.2 has not been clearly vested by a provision of law in the discretion of the Commissioner; (2) the statute regulates payments to providers; (3) Wellmark’s fees for chiropractic care are not based solely on licensure; and (4) ERISA preempts the application of section 514F.2 to self-funded health plans. View "Abbas v. Iowa Insurance Division" on Justia Law

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This petition for injunctive relief and writ of mandamus challenged the Governor’s item veto of appropriations intended to fund the Mount Pleasant and Clarinda Mental Health Institutes. The AFSCME Iowa Council 61 president and twenty state legislators brought suit against the Governor, alleging that the Iowa Code mandates the existence of the Mount Pleasant and Clarinda Mental Health Institutes and their continued operation. The district court granted summary judgment to the Governor and dismissed the petition. The Supreme Court affirmed, holding (1) the appeal was timely, and the issue of the Governor’s veto was not moot; and (2) the Governor’s exercise of his item veto of appropriations for the mental health institutes at issue did not exceed the scope of his constitutional authority. View "Homan v. Branstad" on Justia Law

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In response to a 2009 executive order announcing a ten percent reduction in state departments and agencies for the fiscal year ending June 30, 2010, the Iowa Department of Human Services (IDHS) promulgated temporary rules adjusting the reimbursement rates paid to Medicaid service providers. Thereafter, the legislature passed a law directing IDHS to continue for the next fiscal year the rate reductions as specified under the 2009 executive order. Accordingly, IDHS promulgated permanent rules implementing certain rate reductions. IDHS, however, inadvertently omitted a reduction for one component of the rate calculation for certain Medicaid service providers. Nevertheless, IDHS continued to reimburse those service providers at the reduced rates established under the temporary rules. In an administrative proceeding, Plaintiffs, several providers, challenged the rate calculation, arguing that, even if the “missing” rule was an oversight, IDHS could not reimburse them at the reduced rate without a rule authorizing it to do so. An administrative law judge granted summary judgment for IDHS, and the decision was affirmed on review. The district court reversed. The Supreme Court reversed, holding that the statute provides sufficient authority for IDHS to reimburse service providers at the reduced rates without a rule authorizing it to do so. View "Exceptional Persons, Inc. v. Iowa Dep’t of Human Servs." on Justia Law

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Plaintiffs filed a class action alleging that the fees Defendant charged for providing copies of their medical records and billing statements were excessive in violation of Iowa Code 622.10(6). Defendant filed a motion to dismiss for failure to state a claim, alleging that section 622.10(6) did not apply to it because it was not a provider under the statute. The district court denied the motion to dismiss. The Supreme Court affirmed, holding (1) an entity that acts as a provider’s agent in fulfilling records requests covered by section 622.10(6) cannot charge more for producing the requested records than the provider itself could legally charge; and (2) the well-pleaded facts in the petition indicated that Defendant acted as an agent of the providers by fulfilling the records requests on their behalf, and therefore, the district court was correct in denying Defendant’s motion to dismiss Plaintiffs’ petition. View "Young v. Healthport Technologies, Inc." on Justia Law

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After Plaintiff, an at-will employee, reported a forgery on the part of supervisors at an assisted living facility, the facility terminated Plaintiff's employment. The Department of Inspections and Appeals later concluded that certain state-mandated documents relating to the facility's dementia training program had been forged. Plaintiff subsequently filed an action against the facility for wrongful discharge. The jury returned a verdict for Plaintiff, finding the facility terminated her in retaliation for whistleblowing and a willful and wanton disregard for the rights or safety of others. The jury also awarded punitive damages. The court of appeals (1) affirmed the court's finding that the public-policy exception to the at-will employment doctrine protected Plaintiff's employment from retaliatory termination, but (2) reversed the court's decision to submit the issue of punitive damages to the jury. The Supreme Court affirmed, holding (1) an employer's retaliatory discharge of Plaintiff violated public policy; and (2) the district court should not have submitted the punitive damages claim to the jury because at the time of Plaintiff's discharge, the Court did not recognize a public-policy exception to the at-will employment doctrine based upon a violation of administrative rules. View "Dorshkind v. Oak Park Place of Dubuque II, LLC" on Justia Law

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Plaintiffs, several nursing homes approved by the Iowa Department of Human Services (DHS) as Medicaid providers, submitted annual reports disclosing their income and expenses to DHS. DHS used the reports to calculate the Medicaid per diem reimbursement rates for the nursing homes. Some of the facilities' expenses were disallowed by DHS, and DHS reduced reimbursement rates accordingly. The facilities appealed the adjustments. The director of human services upheld the action. The district court affirmed. The court of appeals reversed, concluding that the DHS rules did not support its decision that the disputed costs were not allowable. The Supreme Court affirmed, holding that DHS's exclusion of the facilities' lab, x-ray, and prescription drug costs from the nursing homes' reports was based on an incorrect interpretation of its rules. View "Sunrise Ret. Cmty. v. Iowa Dep't of Human Servs." on Justia Law

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The Iowa Board of Nursing and Iowa Department of Public Health (collectively, Defendants) enacted rules allowing advanced registered nurse practitioners (ARNPs) to supervise radiologic technologists using fluoroscopy machines. Several physician associates brought this action against Defendants to invalidate the rules. Two nursing associations intervened to defend the rules. The district court invalidated the rules, concluding that Defendants exceeded their authority in promulgating the rules. The Supreme Court reversed, holding (1) the Board's application of law to fact was not irrational, illogical, or wholly unjustifiable; (2) the rules fell within the authority of the Board and Department; and (3) the other challenges to the rules failed. Remanded. View "Iowa Med. Soc'y v. Iowa Bd. of Nursing" on Justia Law