Maxine Gail Veatch v. City of Waverly and Jason Leonard, Individually and in His Official Capacity
2015 Iowa Sup. LEXIS 4
| Iowa | 2015Background
- Maxine Veatch, holding durable power of attorney for her mother Agnes Bell, was accused by nursing-home staff of shoving and yelling at Bell; staff reported fresh bruising and medical exam corroborated bruises.
- Waverly Police Detective Sgt. Jason Leonard investigated, met with nursing-home staff for 1–2 hours, reviewed prior incidents, and waited for Dr. Fagre’s report before acting.
- Veatch went to the station, invoked her right to counsel; Leonard shortly thereafter charged and arrested her for simple misdemeanor assault; a jury later acquitted her.
- Veatch sued in federal court under § 1983 and state torts; the federal courts held Leonard had probable cause and granted summary judgment on the § 1983 claim (Veatch II), dismissing state claims without prejudice.
- Veatch refiled state tort claims (false imprisonment, negligence, malicious prosecution) in Iowa district court; district court granted summary judgment for Leonard and the City based on issue preclusion; Iowa Court of Appeals reversed as to false imprisonment, holding a factual dispute existed under Iowa warrantless-arrest statute § 804.7(2).
- The Iowa Supreme Court granted further review and held as a matter of law that the facts known to Leonard provided reasonable ground (probable cause) to arrest Veatch for the indictable offense of dependent adult abuse under Iowa Code § 235B.20(6), affirming summary judgment for defendants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Veatch’s warrantless arrest was lawful under Iowa Code § 804.7(2) (arrest where a public offense has in fact been committed and officer has reasonable ground to believe suspect committed it) | Veatch argued factual dispute exists whether a public offense in fact occurred, so summary judgment improper. | Leonard/City argued arrest was lawful; alternatively invoked § 804.7(3) and good-faith reasonable belief. | Court did not decide § 804.7(2); resolution unnecessary because it found § 804.7(3) dispositive. |
| Whether arrest was justified under Iowa Code § 804.7(3) (reasonable ground to believe an indictable offense occurred and suspect committed it) | Veatch argued arrest was for a simple misdemeanor and Leonard did not subjectively consider an indictable offense; thus § 804.7(3) inapplicable. | Leonard/City argued objective standard governs; facts known provided reasonable ground to believe dependent adult abuse (an indictable/aggravated misdemeanor) occurred. | Held for defendants: objective inquiry satisfied; facts established reasonable ground as matter of law to believe dependent adult abuse occurred. |
| Effect of prior federal ruling (Veatch II) finding probable cause on state tort claims | Veatch contended federal probable-cause ruling does not resolve statutory warrantless-arrest question under Iowa law. | Defendants argued the federal decision produces issue preclusion on probable cause and supports state-law arrest justification. | Court relied on federal ruling for preclusive finding of probable cause for assault and used it (with other facts) to support objective reasonable ground for dependent adult abuse under § 804.7(3). |
| Whether immunity under Iowa Code § 670.4 shields defendants | Veatch opposed; court of appeals rejected immunity. | Defendants asserted statutory immunity as alternative ground for affirmance. | Iowa Supreme Court did not decide immunity because it resolved the case on § 804.7(3) grounds. |
Key Cases Cited
- Veatch v. Bartels Lutheran Home, 627 F.3d 1254 (8th Cir. 2010) (federal appellate decision finding probable cause for Veatch’s arrest)
- Children v. Burton, 331 N.W.2d 673 (Iowa 1983) (objective probable-cause inquiry in false arrest/imprisonment actions)
- Kraft v. City of Bettendorf, 359 N.W.2d 466 (Iowa 1984) (distinguishing cases where knowledge of complainant’s animus created fact question on probable cause)
- Fischer v. City of Sioux City, 654 N.W.2d 544 (Iowa 2002) (elements of issue preclusion and its application)
- United States v. Torres-Lona, 491 F.3d 750 (8th Cir. 2007) (discussing probable-cause standard for warrantless misdemeanor arrests)