Justia Health Law Opinion SummariesArticles Posted in Iowa Supreme Court
Planned Parenthood of the Heartland, Inc. v. Reynolds ex rel. State
The Supreme Court held that the Iowa Constitution is not the source of a fundamental right to an abortion necessitating a strict scrutiny standard of review for regulations affecting that right.In Planned Parenthood of the Heartland, Inc. v. Iowa Board of Medicine (PPH I), 865 N.W.2d 252 (Iowa 2015), the Supreme Court applied the federal undue burden test established in Planned Parenthood of Southeastern Pennsylvania v. Casey, 505 U.S. 833 (1992), under the Iowa Constitution. In Planned Parenthood of the Heartland v. Reynolds (PPH II), 915 N.W.2d 206, (Iowa 2018), the Supreme Court rejected the undue burden test and found that the due process clause of the Iowa Constitution protected abortion as a fundamental right. In 2020, the general assembly added a mandatory 24-hour waiting period for abortion to pending legislation limiting courts' ability to withdraw life-sustaining procedures. Planned Parenthood successfully sued in district court to block the statute from taking effect. The district court granted summary judgment for Planned Parenthood. The Supreme Court reversed, holding (1) PPH II is overruled; and (2) therefore, the Casey undue burden test applied in PPH I remains the governing standard. View "Planned Parenthood of the Heartland, Inc. v. Reynolds ex rel. State" on Justia Law
Riley Drive Entertainment I, Inc. v. Reynolds
The Supreme Court affirmed the judgment of the district court granting the governor's request to dismiss this lawsuit challenging the Governor's August 2020 public health disaster proclamation that temporarily required taverns and bars in six counties to close, holding that this case was moot.Six establishments brought this action seeking an injunction that would block the order of Governor Kimberly K. Reynolds, which was issued during the COVID-19 pandemic, on the grounds that it exceeded her statutory and constitutional authority. After the Governor rescinded her order, the district court granted the Governor's request to dismiss the lawsuit as moot. The Supreme Court affirmed, holding that this case was moot and that no mootness exception applied. View "Riley Drive Entertainment I, Inc. v. Reynolds" on Justia Law
Kostoglanis v. Yates
The Supreme Court affirmed the decision of the district court granting Defendants' motion for summary judgment and dismissing Plaintiff's claims for negligent misrepresentation, fraudulent misrepresentation, and breach of contract, holding that Plaintiff's claims were subject to the two-year statute of limitations set forth in Iowa Code 614.1(9) and were untimely.On Defendants' motion for summary judgment, the district court held that Plaintiff's causes of action arose out of patient care and were barred by section 614.1(9), the two-year statute of limitations governing malpractice action. The Supreme Court affirmed, holding that each of Plaintiff's allegations originated from representations regarding patient care and the patient care Defendants provided, and therefore, Plaintiff's claims were untimely under section 614.1(9). View "Kostoglanis v. Yates" on Justia Law
Susie v. Family Health Care of Siouxland, P.L.C.
The Supreme Court affirmed the judgment of the district court granting summary judgment for Defendants on Plaintiffs' medical malpractice claims, holding that Plaintiffs failed to set forth specific facts showing a prima facie case of causation and lost chance of survival.Sharon Susie lost her right arm and eight of her toes due to a disorder known as necrotizing fasciitis. Sharon and her husband (together, Plaintiffs) filed a negligence claim against Defendants seeking damages for the amputation of Sharon's arm and other injuries. Plaintiffs alleged that Defendants were negligent because Sharon's condition was not properly diagnosed and treatment was not timely commenced and that Defendants' actions resulted in the lost chance to save Sharon's arm and toes from amputation. The district court granted summary judgment for Defendants. The Supreme Court affirmed, holding that summary judgment was properly granted because Plaintiffs failed to set forth specific facts showing a prima facie case of causation and lost chance of survival. View "Susie v. Family Health Care of Siouxland, P.L.C." on Justia Law
Albaugh v. The Reserve
The Supreme Court affirmed the judgment of the district court granting summary judgment in favor of a "senior adult congregate living facility" on Plaintiff's complaint alleging that the facility would not return her mother's entrance fee or supplemental amount when her mother had to vacate the facility for health reasons, holding that the district court properly granted summary judgment in favor of the facility.In her complaint, Plaintiff, on behalf of her mother, argued that the agreement between her mother and the facility violated the Iowa Uniform Residential Landlord and Tenant Act (IURLTA), Iowa Code chapter 562A, and alleged several other claims, including consumer fraud, breach of the implied covenant of good faith and fair dealing, breach of fiduciary duty, and unconscionability. The district court held that the IURLA did not apply to the facility and that the facility was entitled to judgment as a matter of law on the remaining claims. The Supreme Court affirmed, holding (1) the fees regulated under Iowa Code chapter 523D are not subject to the IURLTA; and (2) the district court did not err in granting summary judgment on Plaintiff's remaining claims. View "Albaugh v. The Reserve" on Justia Law
Struve v. Struve
In this intrafamily dispute regarding farmland the Supreme Court affirmed the rulings of the district court denying substitute petitioners' petition for relief from elder abuse specifically seeking relief for the loss associated with certain real estate transactions, holding that the substitute petitioners failed to prove that their father was a vulnerable elder at the time of the challenged transactions.The substitute petitioners for their father filed this petition pursuant to Iowa Code 235F alleging that their brother and his son committed elder abuse against their father by unduly influencing the father to enter into below-mark-rate lease agreements to farm the father's land, to gift some of the land to the brother and his son, and to write a new will to reflect the gifted land. The district court concluded that the substitute petitioners failed to establish that their father was a "vulnerable elder" subject to "financial exploitation" within the meaning of chapter 235F. The Supreme Court affirmed, holding that the substitute petitioners filed to prove by a preponderance of the evidence that their father was vulnerable elder at the time of the challenged transactions. View "Struve v. Struve" on Justia Law
Cox v. Iowa Department of Human Services
The Supreme Court affirmed the judgment of the district court affirming the position of the Iowa Department of Human Services (DHS) determining that transfers made by Petitioners, nursing home residents, to a pooled special needs trust were for less than fair market value and required a delay in Petitioners’ eligibility for Medicaid benefits, holding that the district court and DHS correctly construed and applied federal law requiring the delay in Medicaid benefits for long-term institutional care.Federal eligibility requirements provide that state ensure that Medicaid benefits are reserved for persons who lack financial means and have not transferred personal asserts that could pay for their care. Petitioners, at age sixty-five, transferred more than one-half million dollars to a pooled special needs trust. The Supreme Court held that the district court and DHS properly interpreted federal law effectively requiring Petitioner’s to tap their pooled trust assets first to pay for their nursing home care. View "Cox v. Iowa Department of Human Services" on Justia Law
In re Detention of Jeffrey Anderson
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
In re M.W.
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
Chicoine v. Wellmark, Inc.
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