Articles Posted in Iowa Supreme Court

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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

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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

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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

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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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After Tenants moved out of an apartment, Landlord deducted $904 fomr the rental deposit for an automatic carpet-cleaning charge, replacement of an interior door, and monthly penalties for failure to pay for the door. Tenant filed a small claims action alleging that Landlord unreasonably failed to return the rental deposit and willfully used a rental agreement with known prohibited provisions. A magistrate determined that Landlord violated the Iowa Uniform Residential Landlord and Tenant Act (IURLTA) by requiring Tenants to pay for the interior door repair and for the cost of carpet cleaning. The magistrate concluded that Tenant was entitled to punitive damages for bad-faith retention of the rental deposit and an award of two months’ rent for willfully using provisions in its rental agreement that violated the IURLTA. The magistrate awarded Tenant an additional two months’ rent and attorneys’ fees. The district court affirmed. The Supreme Court affirmed in all respects except on the issue of a knowing use of provisions violating the IURLTA and a bad-faith retention of the rental deposit, holding (1) the record does not contain sufficient evidence to support a knowing violation of the IURLTA, and (2) there was insufficient fact-finding on the issue of bad-faith retention of the rental deposit. Remanded. View "Caruso v. Apartments Downtown, Inc." on Justia Law