The Iowa Supreme Court heard arguments in seven cases on September 9th and 10th. Five other cases were submitted to the Court without oral argument. The following are summaries of those cases.
State v. Patterson
Argued September 9th at 9:00 AM.
Question: Did the district court apply the correct standard when determining competency when it adopted a medical provider’s competency determination?
The State appeals the district court’s ruling that Colton Patterson is incompetent to stand trial and unrestorable to competency. Patterson was charged with second-degree sexual abuse and lascivious acts with a child. An initial evaluation found Patterson incompetent but likely restorable with restoration treatment involving targeted education focused on trial-related topics. After restoration treatment, Patterson scored 84%, then 100% later on a legal-knowledge quiz administered to patients. However, another doctor evaluated Patterson in a 75-minute interview and concluded that Patterson was unrestorable. The district court ultimately adopted this doctor’s opinion, concluded Patterson was incompetent and unrestorable, and rejected the State’s argument that the facts underlying the evaluation showed Patterson was competent. The State argues the district court erred in adopting the doctor’s diagnosis and therefore the district court did not evaluate Patterson’s ability to understand the proceedings and assist in his defense. The State also argues the district court misapplied the burden of proof and should have placed the burden of proof on the defendant to prove competency under State v. Brown. The defendant argues the district court applied the correct standard and did not err in adopting the doctor’s opinion.
State v. Amyda
Argued September 9th at 9:00 AM.
Question: Did the district court err in admitting a video of alleged sexual abuse without proper authentication and without establishing the video was an original under the best evidence rule and not a “deepfake”?
Max Amyda seeks review of a Court of Appeals decision affirming his conviction for third-degree sexual abuse. The victim’s sister received a video allegedly taken by Amyda showing him sexually abusing the sleeping victim. Amyda argued the video was inadmissible because no witness testified that they witnessed the conduct or could describe how the video was produced, and therefore the video could not be authenticated. Amyda also argued the video was inadmissible under the best-evidence rule under a theory that the video was an AI-generated “deepfake” based on his argument that Amyda’s hand tattoo did not match the tattoo in the video, (although the State presented evidence that Amyda’s tattoo had been tattooed over after the video was taken). The Court of Appeals held that circumstantial evidence, including the victim recognizing her room and Amyda’s tattoo, sufficiently authenticated the video. The Court of Appeals further held that Amyda’s argument that the video was an AI deepfake was not supported by any evidence in the record and therefore amounted to unsubstantiated speculation.
Robert Teig v. Iowa Judicial Branch, et al.
Submitted September 9th without oral argument.
Question: Does Iowa Court Rule 35.4, deeming attorney-client files confidential, conflict with the disclosure requirements of the Iowa Open Records Act, and did state agencies fail to comply with the Act’s requirements to designate and publicly announce the person responsible for handling records requests?
Robert Teig sued the Iowa Judicial Branch, the Iowa Office of Professional Regulation, and the Iowa Supreme Court Attorney Discipline Board alleging violations of Iowa Code chapter 22 after each refused to provide copies of documents regarding an attorney-discipline complaint he filed against federal prosecutors. The district court dismissed Teig’s open records claims based on Iowa Court Rule 35.4(3), providing that disciplinary files are confidential, and later granted defendants’ summary judgment motion on Teig’s remaining requests based on attorney-client privilege and work-product protections. The district court did not reach Teig’s argument that OPR and the Board did not comply with chapter 22’s requirement to delegate and publicly identify a records custodian. Teig argues that a court rule such as Rule 35.4 cannot override the Iowa Open Records Act under separation-of-powers principles, citing State v. Thompson, and that the district court erred in granting summary judgment because the record shows no delegation was made and the requested materials are not protected by attorney-client privilege and work product protection.
Joshua Davenport v. Nathanael K. Fuller, PA-C
Argued September 9th at 1:30 PM.
Question: Is a general surgeon an individual licensed to practice in the same or substantially similar field as a physician’s assistant in order to provide a certificate of merit under Iowa Code section 147.139 in a lawsuit against the physician assistant for malpractice?
Joshua Davenport brought a medical malpractice action against Nathanael Fuller, a physician assistant, after Fuller allegedly misdiagnosed Davenport’s diverticulitis that progressed to bowel perforation and septic shock. Davenport’s expert witness, who submitted a certificate of merit, was a general surgeon with active trauma-call experience, but none in family medicine. The district court dismissed the suit, reasoning that a general surgeon does not practice in the same field as a family-practice physician assistant. Davenport contends that the district court misinterpreted the meaning of the word “field” under the statute—Davenport argues it should be defined by licensure of the expert and not by the expert’s specialty. Davenport further argues that Fuller failed to show that physicians and physician assistants are not substantially similar fields given the regulatory overlap of their responsibilities. Fuller argues the district court correctly concluded Davenport’s expert is not licensed to practice in the same or substantially similar field, including that the expert was not a physician assistant and did not practice in the area of family medicine.
In re Detention of Joshua Andrew Harlow
Argued September 9th at 1:30 PM.
Question: Does Iowa Code section 229A.2(10), regarding commitment of sexually violent predators, satisfy due process when it allows for confinement for a special sentence violation unrelated to a sexual offense without proof of an overt act?
Joshua Harlow discharged his sentence for a 2017 sexual-abuse conviction and began serving a lifetime special sentence under Iowa Code chapter 903B. He returned to prison later for failing to report to a work-release facility. The State petitioned to civilly commit Harlow as a sexually violent predator based on that confinement under Iowa Code chapter 229A, without alleging a recent overt act. The State argued that the legislature’s 2023 amendment to Section 229A.2(10) which defines “presently confined” includes confinement for a special-sentence violation such as Harlow’s. The district court denied Harlow’s motion to dismiss and found him to be a sexually violent predator. Harlow argues the Iowa Supreme Court’s decisions in In re Detention of Wygle and In re Detention of Gonzales concluded that confinement only for a special-sentence violation is not a “recent overt act” as due process requires, and the 2023 amendment therefore violates the due process clauses of the state and federal constitutions. The State argues the 2023 amendments comport with due process requirements.
State v. McKnight
Submitted September 9th without oral argument.
Question: Can a defendant who pleaded guilty to two counts of willful injury appeal his concurrent sentences and argue his sentences are illegal because there was no factual basis for two separate counts of willful injury and therefore the convictions merged into one count, despite not filing a motion in arrest of judgment?
Jerell McKnight pled guilty to two counts of willful injury after shooting a man several times, and was sentenced concurrently on both counts. McKnight argues on appeal that the convictions should have merged because neither his plea nor the court’s findings established a “break in the action” between the shots. The Court of Appeals dismissed the appeal for a lack of jurisdiction, holding that his claim was unpreserved based on McKnight’s failure to file a motion in arrest of judgment. McKnight contends that a failure to merge the convictions is an “illegal sentence” claim that Iowa courts have allowed to be raised at any time, without applying traditional error-preservation rules. McKnight alternatively argues the Iowa Supreme Court should adopt plain-error review.
In the Matter of $11,500 Seized from Bitcoin Depot Operating, LLC
Argued September 10th, 9:00 AM.
Question: Does Iowa Code chapter 533C, requiring digital-asset kiosks to provide refunds to customers who fell victim to fraud, apply retroactively to transactions prior to the statute’s effective date such that the district court may order seized funds be returned to the victim-customer?
Bitcoin Depot sought the return of $11,500 seized from a kiosk after Gary VanderWerf told police he had been defrauded into sending Bitcoin to a scammer. The district court denied the return of the funds under Iowa Code section 533.1004, which requires digital-asset kiosk operators such as Bitcoin Depot to refund defrauded customers who meet certain conditions. Bitcoin Depot contends that the statute cannot be applied to VanderWerf’s transaction unless it expressly applies retroactively, and that even if it did apply retroactively, it would only create a separate refund obligation rather than determining who has the right to possess the seized funds under the return-of-seized-property statute. Further, it contends that VanderWerf did not provide the proof of fraud as the statute requires. The Attorney General argues it has authority to represent the State in the appeal and the State had authority to appear in the underlying seized property action. The Attorney General argues the district court correctly refused to order return of the seized property to Bitcoin Depot based on the victim-customer’s right to a refund under Iowa Code chapter 533C.
[Note: Nyemaster Goode represents the appellant]
State v. West
Argued September 10th at 9:00 AM.
Question: Where the alleged sexual abuse in a criminal prosecution may have occurred outside of Iowa, was there sufficient evidence that Iowa had territorial jurisdiction over a truck driver for sexually abusing a child during a month-long, multi-state trip?
John West, a long-haul trucker, was convicted in Muscatine County of seven counts of second-degree sexual abuse and four counts of lascivious acts with a child from a truck-driving trip he took with an eleven-year-old boy. Parts of the abuse occurred while they were out of state, and the child could not definitively testify whether any of the abuse occurred in Iowa. The Court of Appeals affirmed, holding that evidence that an incident occurred at a Muscatine motel at the outset of the truck-driving trip, and West taking the child out of state, were sufficient circumstantial evidence to establish Iowa’s territorial jurisdiction under Iowa Code section 803.1. West contends that the conduct the court of appeals found supported territorial jurisdiction over West related only to a charge he was acquitted of, indecent acts with a child, and therefore cannot establish jurisdiction over the lascivious acts with a child and second-degree sexual abuse charges he was convicted of because Iowa Code section 803.1 requires that the elements of the charged offenses occur in Iowa.
In the Interest of E.S., Minor Child
Submitted September 10th without oral argument.
Question: Should an appeal from a juvenile court permanency order be reinstated where the Court of Appeals dismissed it as untimely based on filing mistakes while the appellant was representing herself?
After a permanency hearing and termination of parental rights trial, the juvenile court found grounds to terminate a mother’s parental rights but declined to do so. Instead, the district court dismissed the termination petition and changed the permanency goal from reunification with the mother to sole custody to the father. The pro se mother-appellant filed her petition one day after the deadline under Iowa Rule of Appellate Procedure 6.201(1)(b). The Court of Appeals dismissed the mother’s appeal, holding that because she chose to proceed without counsel, she was held to the same standard as a lawyer and did not show that the delay was outside her control.
Swan Lake Road Farms, LLC v. Iowa Utilities Commission
Argued September 10th at 1:30 PM.
Question: Did the district court err in affirming the Iowa Utilities Commission’s grant of a franchise despite finding Iowa Code § 306.46 unconstitutional, and did the district court err in ordering compensation rather than requiring the utility to obtain eminent domain authority?
The Iowa Utilities Commission granted ITC Midwest a franchise to build a new transmission line along Swan Lake Road in Johnson County. The Commission relied on Iowa Code section 306.46 to place poles and lines in the road’s right-of-way on land owned by Swan Lake Road Farms without paying compensation. Swan Lake challenged this ruling as an unconstitutional taking of its property. The district court agreed with Swan Lake that applying section 306.46 constituted an unconstitutional taking, but left the franchise in place and ordered ITC Midwest to pay just compensation through condemnation-commission proceedings.
Swan Lake argues on appeal that the district court erred on the grounds that once a taking is found, the utility can only proceed with eminent domain authority if the franchise is “necessary for public use” under Iowa Code section 478.15, asking the Supreme Court to reverse the franchise and order an evidentiary hearing on the necessity for public use.
State v. Belt
Argued September 10th at 1:30 PM.
Question: Does a district court have discretion to remove an elected official from office under Iowa’s removal from office statute based on one instance of the elected official’s intoxication at a public town hall event as being intoxicated in his official capacity?
Following a two-day bench trial, the district court removed Scott Belt, a Pottawattamie County supervisor, from office after finding that he was intoxicated while serving as emcee of a November 2025 town hall. The district court found there was clear, satisfactory, and convincing evidence that Belt was intoxicated at the town hall meeting. Belt contends that Iowa’s removal statute is discretionary, rather than mandatory, and that the district court failed to consider that it had discretion to deny the petition for removal under the circumstances. Further, he contends that the State failed to prove he was acting in his “official capacity” at a voluntary event with no official business on the agenda, and he seeks attorneys’ fees. The State argues removal was appropriate because Belt was acting in his official capacity even if the town hall was not a statutorily required meeting, and the district court properly exercised its discretion in removing Belt.
NewRez LLC, d/b/a Shellpoint Mortgage Servicing v. Lynae D. McMillen Dickey Tesdall
Submitted September 10th without oral argument.
Question: Is a homeowner who signs a mortgage, and not the promissory note, a “borrower” entitled to notice of the right to cure a default before foreclosure?
Lynae Tesdall and her partner bought a house and signed the mortgage. The mortgage documents described Tesdall and her partner both as “Borrower,” but only Tesdall’s partner signed the promissory note. After her partner moved out and defaulted, the lender sent notice of the right to cure only to him and not to Tesdall. The lender then filed the foreclosure action without notifying Tesdall, and Tesdall argued the lender’s failure to provide notice of the right to cure prevented foreclosure. The district court concluded Tesdall was not a “borrower” in default under Iowa Code section 654.2D because she did not sign the promissory note and therefore was not entitled to a right to cure. The Court of Appeals affirmed summary judgment for the lender, agreeing with the district court that a “borrower” is someone who has been loaned money and is obligated to repay, notwithstanding being labeled “Borrower” on a mortgage. Tesdall contends that the statute’s plain text includes Tesdall based on the plain-language definition of mortgage, and that reading the statute otherwise would undermine homeowner protections.
The post Summary of Iowa Supreme Court Cases Argued and Submitted Sept. 9 and 10 appeared first on Nyemaster Goode On Brief.