Employers Mutual Casualty Company v. Lacinda Ranee Van Haaften
2012 Iowa Sup. LEXIS 58
| Iowa | 2012Background
- Lacinda Van Haaften, PCM secretary, allegedly embezzled from the Student Activity Fund and faced a first-degree theft charge.
- The district court accepted Van Haaften’s Alford plea to first-degree theft and later entered a deferred judgment on sentencing.
- EMCC, PCM’s subrogated insurer, paid PCM $66,749 for losses and obtained assignment of PCM’s claims.
- EMCC sued Van Haaften in a civil action to recover $66,749.21 and sought issue preclusion based on the plea.
- The district court granted summary judgment for EMCC in the amount of $10,000 (the threshold element) plus damages, but later granted summary judgment for the full amount, which the Iowa Supreme Court partially reversed.
- The Iowa Supreme Court held the plea’s factual-basis determination precludes relitigation of essential elements up to $10,000, with remaining damages requiring trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does an Alford plea with a deferred judgment have issue preclusion effect in a subsequent civil action? | EMCC: plea has preclusive effect under prior rulings. | Van Haaften: deferred judgment negates preclusion. | Yes; plea basis remains preclusive despite deferred judgment. |
| Is the deferred judgment final for purposes of issue preclusion?</n> | Factual-basis ruling is final for preclusion. | Deferred judgment is not a final judgment. | No; factual-basis determination is final for preclusion regardless of deferred judgment. |
| May EMCC use offensive issue preclusion against Van Haaften based on the plea? | Offensive use is permitted to establish liability. | Offensive use may be inappropriate under circumstances. | Yes; EMCC may use the plea offensively to bar relitigation of essential elements. |
| Is the amount of theft ($10,000 threshold) an essential element precluded by the plea? | Yes; theft amount above $10,000 is established by the plea. | Amount is not an essential element; damages are separate. | The essential elements are the misappropriation and value over $10,000; amount beyond $10,000 is not essential to the offense. |
| Can summary judgment on damages exceed $10,000 be sustained where damages are disputed? | Damages beyond $10,000 are precluded by the plea. | Genuine issues exist as to the excess damages; summary judgment improper. | Summary judgment only for $10,000; remaining damages require trial. |
Key Cases Cited
- Ideal Mut. Ins. Co. v. Winker, 319 N.W.2d 289 (Iowa 1982) (guilty pleas can preclude relitigation of essential crime elements)
- Aid Ins. Co. (Mut.) v. Chrest, 336 N.W.2d 437 (Iowa 1983) (Alford pleas given preclusive effect where factual basis found)
- Dettmann v. Kruckenberg, 613 N.W.2d 238 (Iowa 2000) (standard for issue preclusion in Iowa)
- Hunter v. City of Des Moines, 300 N.W.2d 121 (Iowa 1981) (dual requirement for issue preclusion mutuality and fair opportunity)
- Soults Farms, Inc. v. Schafer, 797 N.W.2d 92 (Iowa 2011) (describe additional considerations for offensive use of issue preclusion)
- State v. Deng Kon Tong, 805 N.W.2d 599 (Iowa 2011) (distinguishes adjudication of guilt from post-plea judgment)