Donald Lyle Clark v. State of Iowa

Summary

The court held that negligence alone cannot support emotional-distress damages in a criminal legal-malpractice action arising from imprisonment. The plaintiff must prove by a preponderance of clear, convincing, and satisfactory evidence that the criminal defense attorney acted with willful and wanton disregard for the client's rights or safety. Because the jury was instructed that negligence was sufficient, the court reversed the judgment and remanded for further proceedings under the clarified standard.