Justia Landlord - Tenant Opinion Summaries
Articles Posted in Iowa Supreme Court
Randolph v. Aidan, LLC
The case revolves around Lori Randolph, who was injured after falling down stairs in a rental property owned by Aidan, LLC. Randolph sued Aidan, alleging negligence in failing to provide safe stairs. Aidan, in turn, filed a third-party claim against Sioux City, asserting that a city employee had inspected the property and declared it compliant with the municipal code. Aidan claimed that the city was negligent in hiring, retaining, or supervising the unqualified inspector, and thus, should indemnify Aidan for any damages owed to Randolph. Sioux City moved to dismiss Aidan’s claim, arguing it was immune under Iowa Code section 670.4(1)(j).The district court denied Sioux City's motion to dismiss Aidan's claim. Sioux City and Randolph requested interlocutory review, which was granted. The Supreme Court of Iowa was tasked with reviewing the denial of Sioux City's motion for the correction of errors at law.The Supreme Court of Iowa reversed the district court's decision. The court held that Sioux City was immune from Aidan's claim under Iowa Code section 670.4(1)(j). The court reasoned that Aidan's claim for negligent hiring was "based upon" the negligence of Sioux City's employee in inspecting the stairs. Therefore, the claim fell within the scope of the immunity provided by section 670.4(1)(j). The court remanded the case for further proceedings, including the dismissal of Aidan's claim against Sioux City. View "Randolph v. Aidan, LLC" on Justia Law
Barnes v. CDM Rentals, LLC
The Supreme Court affirmed the summary judgment of the district court concluding that a condominium owner-landlord owed no duty of care with respect to a downspout that discharged water directly onto a shared driveway, holding that the owner-landlord had no common law, contractual, or statutory duty to keep the driveway clear.The condominiums at issue in this case were subject to a horizontal property regime pursuant to Iowa Code ch. 449B, which, in turn, was governed by a document referred to as the declaration. Shelly and Cameron Barnes leased a condominium unit from CDM Rentals, LLC. After Shelly fell on ice on the shared driveway the Barneses brought this negligence lawsuit. The district court granted summary judgment for CDM on the ground that CDM lacked control over the common areas. The Supreme Court affirmed, holding (1) regarding premises liability, CDM lacked control of the driveway and downspout under the declaration; and (2) the district court correctly concluded that the Uniform Residential Landlord and Tenant Act, Iowa Code ch. 562A, requires landlords to maintain common areas but only to the extent the landlord has control over those areas. View "Barnes v. CDM Rentals, LLC" on Justia Law
Dolly Investments, LLC v. MMG Sioux City, LLC
In this case stemming from a commercial lease dispute between Landlord and Tenant the Supreme Court held that both parties breached the lease agreement but that only the tenant's breach was material.At issue in this case was which party was first to materially breach the lease agreement at issue and whether the other's material breach discharged either party's obligations to perform under the agreement. The district court ruled for Landlord on breach of contract claims and awarded her damages. On reconsideration, the district court determined that Landlord materially breached the lease and reduced her damages. The Supreme Court reversed, holding (1) both Tenant and Landlord breached the commercial lease; (2) Tenant's breach was material, and Landlord's breach was not; and (3) Tenant's material breach suspended Landlord's duty to perform during a cure period, and once that period ended, Landlord's duty to perform was discharged. View "Dolly Investments, LLC v. MMG Sioux City, LLC" on Justia Law
Lewis v. Howard L. Allen Investments, Inc.
The Supreme Court affirmed the ruling of the district court granting summary judgment dismissing Kristina Lewis's negligence claims against Howard L. Allen Investments, Inc. (Allen Investments), holding that Allen Investments did not owe a duty to protect Lewis from the harm she suffered.Allen Investments sold a house under a contract of sale that required the buyers to make monthly payments for ten years. Five years into the payment period the buyers leased the house to Lewis and her fiancé. The house subsequently caught fire, causing Lewis to suffer serious injuries. Lewis brought this negligence action against the buyers and Allen Investments. The district court granted summary judgment for Allen Investments, concluding that the company, as a contract seller, owed no duty to Lewis. The Supreme Court affirmed, holding (1) Allen Investments was not the landlord of the property under Iowa's Uniform Residential Landlord and Tenant Act, Iowa Code chapter 562A; and (2) Allen Investments owed no duty of care to Lewis to maintain the property. View "Lewis v. Howard L. Allen Investments, Inc." on Justia Law
Cohen v. Clark
In this case brought by a tenant against her landlord and a neighboring tenant alleging breach of the lease's no-pets provision the Supreme Court reversed the judgment of the district court dismissing the case, holding that the landlord's accommodation of an emotional support dog was not reasonable.Plaintiff moved into an apartment building because of its no-pets policy. Afterwards, another tenant requested a reasonable accommodation to have his emotion support animal (ESA), a dog, with him on the apartment premises. The landlord allowed the ESA and tried to accommodate the two tenants, but Plaintiff still suffered from allergic attacks. Plaintiff sued, alleging breach of the lease and interference with the quiet enjoyment of her apartment. The landlord asserted in its defense that its waiver of the no-pets policy was a reasonable accommodation that it was required to grant under the Iowa Civil Rights Act (ICRA). The small claims court concluded that the landlord's accommodations were reasonable. The district court dismissed the case. The Supreme Court reversed and remanded the case, holding (1) the landlord's accommodation of the ESA was not reasonable because Plaintiff had priority in time and the dog's presence posed a direct threat to her health; and (2) Plaintiff was entitled to recover on her claims. View "Cohen v. Clark" 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
Seeberger v. Davenport Civil Rights Commission
The Supreme Court affirmed the judgment of the district court vacating an award of fees incurred during agency proceedings under a fee-shifting provision in Division II of the Davenport Civil Rights Ordinance for a housing discrimination violation charged under Division III that lacked a corresponding fee-shifting remedy, holding that that the district court correctly denied an award of attorney fees.A tenant filed a complaint with the Davenport Civil Rights Commission alleging discrimination based on familial status in violation of the Davenport Civil Rights Ordinance and the Federal Fair Housing Act (FHA). An administrative law judge found that the landlord committed a Division III fair housing violation and award the tenant both damages and attorney fees and costs. The Commission approved the ALJ’s decision. The district court reversed the damages award and vacated the fee award. The court of appeals reinstated the fee award. The Supreme Court held that the court of appeals erred in awarding attorney fees because (1) the fee-shifting provision in Division II of the Ordinance was inapplicable to the fair housing violation in Division III; and (2) the Commission could not award fees under the FHA. View "Seeberger v. Davenport Civil Rights Commission" on Justia Law
Walton v. Gaffey
Landlord brought this interlocutory appeal challenging a summary judgment in favor of Tenant and the district court’s order certifying a class of tenants. Tenant filed an action seeking a declaration that certain lease provisions violated the Iowa Uniform Residential Landlord and Tenant Act. The Supreme Court affirmed in part and reversed in part, holding (1) some, but not all, of the challenged lease provisions were prohibited under the Act; and (2) the certification of a class in this case was procedurally flawed. The court remanded the cause for the district court to make the findings required under Iowa R. Civ. P. 1.263(1). View "Walton v. Gaffey" on Justia Law
Kline v. Southgate Property Management, LLC
After their leases expired, three tenants, on behalf of themselves and other similarly situated residential tenants, brought suit against their landlord. The district court granted summary judgment for the tenants, declaring that certain of the landlord's lease provisions violated the Iowa Uniform Residential Landlord and Tenant Act. The court also certified a class of tenants. The landlord brought this interlocutory appeal. The Supreme Court affirmed in part and reversed in part, holding (1) some, but not all, of the challenged lease provisions were prohibited under the Act; and (2) the class certification was procedurally flawed in the absence of findings required under Iowa R. Civ. P. 1.263(1). The court remanded the cause for further proceedings. View "Kline v. Southgate Property Management, LLC" on Justia Law
De Stefano v. Apartments Downtown, Inc.
After Tenants moved out of an apartment, Landlord withheld the rental deposit for an automatic carpet-cleaning charge, replacement of a damaged door, and monthly penalties for failure to pay for the door. Tenant sued in small claims court alleging that Landlord improperly failed to return the rental deposit. The magistrate held for Tenant on most issues and awarded damages. The district court upheld some but not all of the magistrate’s decision, concluding (1) Landlord could charge Tenant for the replacement of the exterior door; (2) Tenant was liable to Landlord for rent during two months when the premises was vacant; but (3) Landlord’s automatic deduction from the rental deposit for carpet cleaning violated the Iowa Uniform Residential Landlord and Tenant Act (IURLTA). The Supreme Court affirmed in part and reversed in part, holding (1) the district court correctly found in favor of Tenant on the issue of cleaning costs; (2) the district court erred in ruling against Tenant on the issue of liability for the door repair and on the claim for damages for failure to permit Tenants from subleasing the apartment; and (3) the district court erred in awarding punitive damages under IURLTA. View "De Stefano v. Apartments Downtown, Inc." on Justia Law
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Iowa Supreme Court, Landlord - Tenant