A motorcyclist was struck by a semi while crossing traffic at an intersection and died from his injuries. The administrators of his estate filed suit against the State of Iowa alleging claims of negligence and gross negligence. In particular, the administrators alleged the State was grossly negligent because it had knowledge of the intersection’s defective design, the danger it posed to the public, and wantonly failed to communicate that danger, thereby creating “a trap to the public.” The State sought summary judgment on various grounds including the public-duty doctrine, which “precludes liability to individuals based on breach of a duty the state owes to the public at large.” The district court granted the State’s motion and the administrators appealed.
Affirming the district court’s ruling, the Court of Appeals held the public-duty doctrine barred the administrators’ claims against the State. The Court noted that the public-duty doctrine applied to the administrators’ claims because the decedent was a member of the general public and any duty owed to him “would be a duty owed to all users of this public road[.]”
The administrators attempted to carve out an exception to the public-duty doctrine, arguing it does not apply to gross negligence claims. The Court of Appeals disagreed, stating: “we do not think ‘gross negligence’ claims are categorically excluded from the public-duty doctrine.”
Estate of Houdek v. State, No. 20-1304 (Iowa Ct. App. 2021).