Cory Burnett v. Phillip Smith and State of Iowa

Summary

The court affirmed summary judgment for the defendants, but it did not decide whether the officer had probable cause to arrest Burnett or whether the arrest violated the Iowa Constitution. Instead, the court overruled the prior decision recognizing standalone constitutional damages claims and held that such claims are unavailable unless authorized by common law, statute, or the express terms of a constitutional provision. The court concluded that the prior decision was inconsistent with constitutional text and history, separation of powers, sovereign immunity principles, and practical workability.