Cory Burnett v. Phillip Smith and State of Iowa

Summary

The court affirmed summary judgment for the defendants and overruled the precedent recognizing direct constitutional damages claims under the Iowa Constitution. It held that Iowa courts may not recognize a standalone constitutional damages action unless the claim is authorized by common law, an Iowa statute, or the express terms of a constitutional provision. Because Burnett's claim depended on the overruled constitutional-tort doctrine, the court did not reach probable cause, preclusion, statutory immunity, or due-care immunity.