Raymond Sullins v. Iowa District Court for Polk County, and City of Des Moines and Safari II, L.L.C., Intervening
16-0958
| Iowa Ct. App. | Nov 8, 2017Background
- Sullins leased commercial property from Safari II, LLC to operate a pallet business; the City of Des Moines issued a zoning citation alleging pallet storage violated the municipal ordinance.
- Safari sued Sullins in small claims court via a forcible entry and detainer (FED) action alleging lease violations; the FED court ordered removal after a hearing.
- The City separately brought a small‑claims ordinance violation proceeding; Safari later stipulated the property violated the ordinance and agreed to a penalty; Sullins sought to intervene but was denied.
- Sullins appealed both small‑claims decisions to the district associate court, which affirmed (finding municipal‑code violations supported the FED and that Safari adequately represented Sullins in the ordinance matter). Discretionary review of the FED appeal was denied by the supreme court.
- Sullins then filed certiorari petitions and motions to vacate/for new trial in district court challenging the small‑claims and district associate rulings; the district court denied relief, concluding it lacked jurisdiction over certiorari to review district associate decisions and that res judicata barred reconsideration of the small‑claims rulings.
- Sullins appeals; the Court of Appeals affirms the district court in all respects.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jurisdiction to seek certiorari from district associate court decisions | Sullins sought certiorari review in district court of district associate rulings | Defendants: Supreme Court (original) has exclusive jurisdiction for certiorari against district associate judges | District court lacked jurisdiction; such certiorari must be filed in the supreme court; denial affirmed |
| Preclusion of challenges to small‑claims rulings (issue preclusion) | Sullins argued small‑claims and associate court acted illegally/irregularly on same issues | Defendants argued the district associate court already decided the issues; issue preclusion applies | Issues actually decided by the district associate court are barred by issue preclusion; claims denied |
| Preclusion of other claims from small‑claims appeals (claim preclusion) | Sullins sought to relitigate or advance new theories attacking the small‑claims outcomes | Defendants: earlier final judgments and appeals barred relitigation of claims that were or could have been raised | Claims that could have been raised in the associate‑court appeal are barred by claim preclusion; denial affirmed |
| Intervention and irregularity/judicial‑conduct claims | Sullins contended denial of intervention and alleged irregularities/judicial‑conduct violations warranted vacatur or new trial | Defendants: intervention denial was within small‑claims court discretion; no irregularity shown that prevented fair process | Denial of intervention was proper (Safari adequately represented Sullins; permissive intervention discretionary); no irregularity or Code of Judicial Conduct breach shown; motion for new trial denied |
Key Cases Cited
- State Pub. Def. v. Iowa Dist. Ct., 886 N.W.2d 595 (Iowa 2016) (standard for certiorari: jurisdictional excess or illegality; review for correction of errors at law)
- Bennett v. MC No. 619, Inc., 586 N.W.2d 512 (Iowa 1998) (definition and scope of res judicata)
- Hunter v. City of Des Moines, 300 N.W.2d 121 (Iowa 1981) (elements for issue preclusion)
- Pavone v. Kirke, 807 N.W.2d 828 (Iowa 2011) (elements and effect of claim preclusion)
- Costello v. McFadden, 553 N.W.2d 607 (Iowa 1996) (definition and requirements for vacatur for irregularity)
- In re Marriage of Ginsberg, 750 N.W.2d 520 (Iowa 2008) (addressing whether court may raise claim preclusion sua sponte)
- Channon v. United Parcel Serv., Inc., 629 N.W.2d 835 (Iowa 2001) (standards of review for motions for new trial: discretionary vs. legal questions)
- Bechtold v. City of Rosemount, 104 F.3d 1062 (8th Cir. 1997) (supporting courts raising claim preclusion sua sponte to protect finality of judgments)