Iowa Supreme Court · No. 23-0568

Donald Lyle Clark v. State of Iowa

Decided June 7, 2024 · appeal from Johnson County · Criminal

What the court decided

AI summary A person sued the state for legal malpractice after a public defender represented them in a criminal case, and a jury awarded them damages for emotional distress. The state appealed the decision, arguing that the person did not prove the attorney acted improperly and that the trial should have been declared a mistrial due to improper testimony. The court reversed the judgment and sent the case back to the lower court for further proceedings.1

Result: REVERSED AND REMANDED WITH INSTRUCTIONS

The court’s own summary

The State appeals a district court judgment entered on a jury verdict awarding plaintiff emotional distress damages for legal malpractice in connection with a public defender’s representation of plaintiff in criminal proceedings. The State contends the court erred in allowing emotional distress damages where plaintiff failed to establish his criminal trial attorney engaged in any illegitimate conduct during the representation. The State also contends the court erred in denying its motion for mistrial after plaintiff’s witness violated a pretrial order and revealed to the jury the public defender had been previously adjudicated to have provided ineffective assistance of counsel.

Holding: The State appeals from a judgment on a jury verdict awarding emotional distress damages in a legal malpractice action against a state public defender. REVERSED AND REMANDED WITH INSTRUCTIONS.

Read the opinion (PDF) · Case page on iowacourts.gov

Judges

Iowa Code it cites

§13B.9§663A.1§668A.1§669.21§669.5§702.17§709.1§709.3§815.10

Each links to the bills that change that chapter.