Justia Family Law Opinion Summaries

A married couple accumulated significant assets during a nineteen-year marriage, including a successful business started by the husband prior to the marriage. The wife, an accountant, worked for the business during the marriage but let her CPA license lapse. Upon dissolution of the marriage, the husband retained ownership of the business, and the wife received a large cash equalization payment to offset the division of assets. The wife’s request for substantial monthly spousal support was based on the disparity between her potential income and the husband’s anticipated future income from the business.The Iowa District Court for Audubon County presided over the dissolution trial. After valuing the assets, it awarded the husband the business and other properties, and the wife the lake house and a cash equalization payment exceeding $3 million. The court concluded the wife’s ability to earn investment income from the equalization payment, combined with her earning capacity as an accountant, was sufficient for her to maintain her marital standard of living. It denied her request for traditional spousal support. On appeal, the Iowa Court of Appeals affirmed the property division but modified the decree to award the wife $3,500 per month in spousal support, reasoning that the income gap and business growth potential justified support.The Supreme Court of Iowa reviewed both parties’ challenges. It adopted the Court of Appeals’ analysis on property valuation but vacated the appellate court’s award of spousal support. The Supreme Court held that when a property division provides the spouse seeking support with sufficient assets and income to maintain her predivorce lifestyle, an additional award of traditional spousal support is not warranted. The focus is on need, not income equalization or duplicating business value already considered in property division. The district court’s denial of spousal support was affirmed. View "In re the Marriage of Owen and Brinker" on Justia Law

A divorced couple with two children entered into a stipulation to resolve their dissolution proceeding, agreeing to joint legal custody, physical care with the mother, and visitation for the father. The stipulation also detailed the children’s school arrangements. Shortly after the decree was entered, the father expressed regret about its terms and, just fifty-one days later, filed a petition to modify the custody, care, visitation, and support arrangements. During discovery, the father admitted there had been no material change in circumstances since the decree, conceding the petition was motivated by dissatisfaction with the decree’s terms rather than new facts.The Iowa District Court for Delaware County found that the petition was filed in violation of Iowa Rule of Civil Procedure 1.413, which requires pleadings to be well-grounded in fact and not filed for improper purposes. The court found the father’s claims of changed circumstances not credible and concluded the petition was an improper attempt to relitigate the decree. As sanctions, the district court dismissed the petition and ordered the father to pay the mother’s attorney fees. On appeal, the Iowa Court of Appeals affirmed the finding that the rule was violated and upheld the monetary sanction but reversed the dismissal sanction, holding that dismissal was not an appropriate remedy under rule 1.413.On further review, the Supreme Court of Iowa addressed only whether rule 1.413 authorizes dismissal as a sanction. The court held that, while the rule allows for various sanctions, including attorney fees, it does not itself provide an independent basis for dismissal of a petition. The court affirmed the imposition of attorney fees but reversed the district court’s dismissal, remanding the case for further proceedings consistent with its opinion. View "In re the Marriage Kraus" on Justia Law

A mother sought to modify an existing child custody order to change the school district her daughter attends after moving to a new residence. The father objected, arguing that changing schools would be disruptive and limit his time with the daughter. Unable to reach an agreement through mediation, the mother petitioned the court to modify the custody decree.The Iowa District Court for Worth County denied the mother's request, determining that changing school districts was not in the daughter's best interests. The mother appealed, and while the appeal was pending, the Iowa Supreme Court decided In re Marriage of Frazier. The Court of Appeals, interpreting Frazier, concluded that the district court lacked authority to hear the mother's petition because she was not seeking to alter the parents' status as joint legal custodians. The Court of Appeals affirmed the district court's ruling without considering the merits of the mother's petition.The Iowa Supreme Court reviewed the case and disagreed with the Court of Appeals' interpretation of Frazier. The Supreme Court held that a court that entered a custody decree has the authority to modify it when requested, even if the modification does not relate to who has legal custody. The Supreme Court found that the district court had the authority to rule on the mother's petition since the decree specified the daughter's school district, and the mother sought to modify that based on a change of circumstances.On de novo review, the Iowa Supreme Court agreed with the district court's determination that changing school districts was not in the daughter's best interests. Therefore, the Supreme Court vacated the Court of Appeals decision and affirmed the district court's order denying the modification petition. View "Venechuk v. Landherr" on Justia Law

A couple with older children volunteered to care for the newborn child of an incarcerated mother struggling with methamphetamine addiction. The mother relapsed multiple times, and the couple eventually became the child's guardians. The mother later sought to terminate the guardianship and raise her child, but the guardians had moved out of state with the child, who had become integrated into their family. The guardians sought to adopt the child, while the mother had made significant improvements in her life and wanted to regain custody.The Iowa District Court for Polk County denied the guardians' petition to terminate the mother's parental rights, finding that the guardians' restrictions on visitation and communication justified the mother's lack of contact with the child. The court noted that the guardians had moved out of state without informing the mother or the court, preventing her from maintaining regular contact.The Iowa Court of Appeals reversed the district court's decision, finding that the mother had abandoned the child under Iowa Code section 600A.8(3)(b) by failing to maintain substantial and continuous or repeated contact. The court of appeals determined that the guardians had not placed excessive restrictions on the mother's ability to communicate with the child and that the mother had not exerted sufficient effort to maintain contact.The Iowa Supreme Court affirmed the decision of the court of appeals, concluding that the mother had abandoned the child and that termination of her parental rights was in the best interests of the child. The court noted that the child had become integrated into the guardians' family and that granting the petition for termination would provide the child with stability and permanency. The case was remanded for further proceedings consistent with the opinion. View "In the Interest of J.V., Minor Child" on Justia Law

The case revolves around Abel Gomez Medina, who was convicted of sexual abuse and indecent contact with a minor. The minor, identified as Dorothy, was his stepdaughter. She reported the abuse to her school counselor, stating that it had been ongoing since she was eleven years old. Dorothy's stepbrother, Frank, also testified that he had witnessed inappropriate behavior between Medina and Dorothy. The defense presented witnesses who claimed they had never seen anything inappropriate between Medina and Dorothy.Prior to the trial, the State moved to permit Dorothy and Frank to testify via closed-circuit television, citing the potential trauma caused by in-person testimony. The district court granted this for Dorothy but denied it for Frank. During the trial, Dorothy turned eighteen and Medina objected to her continuing to testify via closed-circuit television, arguing that the statute permitting such testimony only applied to minors. The district court overruled this objection, citing a different paragraph of the statute that allowed for closed-circuit testimony for victims or witnesses with mental illnesses, regardless of age.Medina appealed his conviction, arguing that allowing Dorothy to testify via closed-circuit television violated both the Iowa Code and the Confrontation Clause of the United States Constitution. The court of appeals affirmed Medina's convictions, holding that permitting Dorothy’s closed-circuit testimony satisfied constitutional requirements while she was a minor, and that by meeting the requirements under Iowa Code after she turned eighteen, Medina’s claim of a Confrontation Clause violation similarly failed. Medina then filed an application for further review of the court of appeals ruling, which was granted by the Supreme Court of Iowa.The Supreme Court of Iowa affirmed the decisions of the lower courts. It concluded that Medina had failed to preserve error on his Confrontation Clause argument concerning Dorothy’s testimony after she turned eighteen. The court also found that the district court had properly applied the statute to permit Dorothy’s closed-circuit testimony, based on the evidence presented at the pretrial hearing. The court let the court of appeals decision stand on Medina's arguments that the district court abused its discretion by allowing the prosecutor to comment during closing argument and by excluding 911 call logs. View "State v. Medina" on Justia Law

The case involves a dispute over a postnuptial modification of a premarital agreement. The parties, David and Elizabeth Roberts, entered into a premarital agreement before their marriage in 1993. The agreement stipulated that each spouse waived their statutory elective share, but agreed that each would take one-third of the other’s net real property interests at the time of death. Twenty-four years later, the parties executed a new agreement, a "partial revocation" of the premarital agreement, which maintained the waiver of elective share but relinquished their one-third share in each other’s real property investments at the time of death. Elizabeth received approximately $15,000 cash and $50,000 in debt repayment or forgiveness from David, plus a monthly living allowance for as long as the couple remained married. After David's death, Elizabeth contested the validity of this partial revocation.The district court rejected Elizabeth's challenge and enforced the partial revocation. Elizabeth appealed the decision to the Supreme Court of Iowa.The Supreme Court of Iowa reversed the district court's decision. The court concluded that under Iowa law, specifically Iowa Code sections 596.7 and 597.2, a postmarital amendment to a premarital agreement relating to inchoate dower interests in property is not enforceable. The court found that the partial revocation was essentially an amendment, not a revocation, and that Iowa law does not permit married persons who previously entered into a premarital agreement to enter into a new agreement during their marriage relating to inchoate dower interests in each other’s property. The court remanded the case for further proceedings regarding counterclaims made by David's son, Eric, who asked that if the partial revocation agreement is invalidated, Elizabeth should be required to relinquish the benefits she received as a result thereof to avoid unjust enrichment. View "Roberts v. Roberts" on Justia Law

In Iowa in 2021, a mother of six, Paula Cole, left her five oldest children, ranging in age from 12 to five, asleep at home while she left to go to Walmart for groceries, taking her youngest, an infant, with her. While she was gone, a disagreement arose between two of the children, leading one to leave their apartment building. A neighbor, with whom the family had an open-door policy, helped the children and eventually called 911 due to the disagreement and the child leaving the building. Upon return, Cole was charged with child endangerment. She was convicted and appealed the decision. The court of appeals affirmed the conviction, but Cole sought further review from the Supreme Court of Iowa.The Supreme Court of Iowa reversed the conviction, holding that Cole did not create a risk that violated section 726.6(1)(a), which defines child endangerment as knowingly acting in a manner that creates a substantial risk to a child's physical, mental, or emotional health or safety. The court concluded that while leaving her children home alone could potentially pose risks, these were not risks created by Cole's decision to go shopping, but rather, they were ordinary risks of everyday life. The court also noted that no evidence suggested the home was unsafe, the older children could help care for the younger ones, and a neighbor was available to assist. The court stressed that not all risks children encounter are created by their parents or caregivers, and life inherently poses risks. Additionally, the court stated that a parent does not create a risk if the risk is part of the background risk of ordinary life. View "State of Iowa v. Cole" on Justia Law

In the Supreme Court of Iowa, the case involved a dispute between divorced parents who held joint legal custody of their children. The parents disagreed on whether their children should receive the COVID-19 vaccine. The mother filed an application for vaccination determination after unsuccessful mediation, seeking the district court's authorization to vaccinate the children. The district court dismissed the case, concluding it lacked the authority to act. The court of appeals reversed the decision, instructing the district court to hear the mother's application on the merits.Upon review, the Supreme Court of Iowa vacated the decision of the court of appeals and affirmed the district court's dismissal of the case. The Supreme Court held that the language of Iowa Code section 598.1(3) provides parents with equal participation in decisions affecting their children's medical care. The court found that the mother's application for vaccination determination attempted to circumvent the dissolution decree that gave the parents joint legal custody. Without a request for a modification of the custody agreement, the district court did not have the authority to resolve the parents' dispute. Therefore, the court concluded that the district court did not have the authority to resolve the parties' conflict over vaccinating their children against COVID-19. View "In re Marriage of Frazier" on Justia Law

The Supreme Court affirmed the judgment of the juvenile court dismissing an attorney's pro se petition to establish an involuntary guardianship of J.W., holding that the juvenile court did not abuse its discretion under the unique circumstances of this case.J.W. was the nine-year-old daughter of Mother, Attorney's former client. Attorney had represented Mother in prior custody disputes involving the child over which he sought to be named the guardian. The juvenile court dismissed the petition on the grounds that Attorney violated his duties to Mother as a former client under the Iowa Rules of Professional Conduct. The court of appeals reversed, concluding that the juvenile court erred in order dismissal as a remedy for any purported ethical violations. The Supreme Court vacated the decision of the court of appeals and affirmed the juvenile court's judgment, holding that dismissal was not clearly untenable. View "In re Guardianship of J.W." on Justia Law

The Supreme Court reversed the judgment of the court of appeals modifying a dissolution decree to award a payee spouse seven years of transitional spousal support, holding that, under the circumstances, the court of appeals erred in modifying the decree to award transitional spousal support.Rachael and David Sokol married in 2002 and had two children. In 2019, Rachael petitioned for dissolution of the marriage. As to spousal support, the district court ordered Rachael to pay David $3,000 per month in rehabilitative spousal support for four years. After the district court entered its decree David appealed, arguing, as relevant to this appeal, that the length of the marriage warranted traditional, rather than rehabilitative, spousal support. As to spousal support, the court of appeals modified David's award from rehabilitative support at $3,000 per month for four years to transitional support at $5,000 per month for seven years. The Supreme Court reversed the court of appeals' modification of the district court's spousal award and reinstated the original award, holding that the modification of the decree was inconsistent with caselaw regarding both the category and duration of spousal support. View "In re Sokol" on Justia Law