Justia Iowa Supreme Court Opinion Summaries

Jeffrey Flynn was stopped by Dubuque County Deputy Sheriff Rob Freund for speeding. Freund suspected Flynn was intoxicated after smelling alcohol and hearing Flynn admit to drinking. Flynn performed poorly on field sobriety tests and a preliminary breath test indicated a blood alcohol concentration above the legal limit. Flynn was arrested for operating a motor vehicle while intoxicated (OWI) and transported to the law enforcement center. Freund requested Flynn submit to a chemical breath test without providing a written request or advising Flynn of the consequences of refusal or submission. The test showed a blood alcohol concentration of .110, and Flynn was charged with OWI first offense.The Iowa District Court for Dubuque County granted Flynn’s motion to suppress the chemical breath test evidence. The court reasoned that the statutory requirements for a written request and advisories were mandatory and not followed by Freund. The court concluded that the failure to comply with these requirements rendered the test results inadmissible.The Iowa Supreme Court reviewed the case and affirmed the district court’s decision. The court held that the implied consent statute requires a peace officer to make a written request and provide advisories when requesting a motorist to submit to a chemical test under certain conditions, which were present in this case. The court rejected the State’s argument that the statute was not invoked and that actual consent was sufficient. The court concluded that the failure to follow the statutory procedures rendered the chemical breath test results incompetent for prosecution purposes. The case was remanded for further proceedings consistent with this opinion. View "State of Iowa v. Flynn" on Justia Law

N.S. was involuntarily committed at age sixteen in 2006, which disqualified him from possessing firearms under federal law. In August 2022, he filed a petition under Iowa Code section 724.31 for the restoration of his firearm rights. The State and the county attorney opposed his petition. The district court conducted an evidentiary hearing and denied his petition, finding that N.S. failed to prove he would not likely act in a manner dangerous to public safety. The court also rejected N.S.'s state constitutional challenge, ruling that Amendment 1A did not apply retrospectively to his 2006 disqualification and that section 724.31 survives strict scrutiny.The Iowa Supreme Court reviewed the case de novo and agreed with the district court's factual findings and determination that N.S. failed to meet his burden to satisfy the statutory criteria for restoration of his right to possess firearms. The court held that Amendment 1A applies prospectively to N.S.'s restoration proceeding in 2023. The court further held that section 724.31 survives strict scrutiny under Amendment 1A, as the State has a compelling interest in preventing gun violence and suicide, and the statute is narrowly tailored to serve that interest by keeping firearms from dangerous persons while allowing restoration of firearm rights upon a petitioner’s showing they are no longer a threat to public safety.The court declined to shift the burden of proof under section 724.31 from the petitioner to the State. Consequently, the Iowa Supreme Court affirmed the district court's judgment denying N.S.'s petition for the restoration of his firearm rights. View "In re N.S." on Justia Law

Daniel Murillo, a registered sex offender, sought to modify his registry requirements under Iowa Code section 692A.128. Murillo had pleaded guilty to sexual abuse in the third degree in 2005 and was required to register as a sex offender. He completed a sex offender treatment program (SOTP) while incarcerated and received a certificate of completion in 2009. In 2022, Murillo applied to be removed from the sex offender registry, citing his completion of the SOTP and a low-risk assessment for recidivism.The Iowa District Court for Polk County denied Murillo's application, determining that he had not "successfully completed" the SOTP because he only admitted guilt to avoid a longer sentence. The court also found that Murillo posed an ongoing risk to the community. The Iowa Court of Appeals affirmed the district court's decision.The Iowa Supreme Court reviewed the case and held that the district court erred in determining that Murillo had not successfully completed the SOTP, as he had a certificate of completion from the Department of Corrections. However, the Supreme Court found that the district court did not abuse its discretion in denying Murillo's application for modification. The court concluded that the district court properly considered relevant factors, including Murillo's inconsistent admissions of guilt and the need for further treatment, in determining that he posed an ongoing risk to the community.The Iowa Supreme Court vacated the decision of the Court of Appeals but affirmed the judgment of the district court, maintaining Murillo's registration requirements. View "Murillo v. State of Iowa" on Justia Law

Chad Allen Staton was convicted by a jury of incest and sexual abuse of his daughter. He appealed his conviction, arguing that the evidence was insufficient, the district court erred by allowing his daughter to testify about a prior uncharged incident, and his right to allocute was violated when the sentencing court disallowed discussion of rejected plea offers. Staton contended that the rejected plea offers demonstrated his sincerity in professing innocence, which should mitigate his lack of remorse at sentencing.The Iowa District Court for Black Hawk County, presided over by Judge Linda M. Fangman, sentenced Staton to indeterminate prison sentences totaling forty years with a mandatory minimum of seventeen and a half years. Staton appealed, and the Iowa Court of Appeals affirmed his conviction and sentence, finding the evidence sufficient and the admission of the prior incident appropriate. The court also concluded that Staton’s right to allocute was not violated as he and his counsel had opportunities to address mitigation.The Iowa Supreme Court reviewed the case to address whether the defendant’s right to allocute was violated by disallowing discussion of rejected plea offers. The court held that the district court correctly cut off discussion of rejected plea offers during allocution, as such offers are inadmissible under Iowa Rule of Criminal Procedure 2.10(5). The court reasoned that allowing discussion of rejected plea offers could deter prosecutors from making plea offers. The court affirmed the decision of the Iowa Court of Appeals and the judgment of the district court, concluding that Staton’s right to allocute was not violated since he and his counsel were allowed to argue his professed innocence to explain his lack of remorse. View "State v. Staton" on Justia Law

Reuben Schooley was convicted of child endangerment causing bodily injury after an incident where he slapped his nine-year-old daughter, spanked her, yanked her by the shirt, and told her to leave the house. The child was found with marks on her collar and bruising on her buttocks. Schooley admitted to spanking her frequently and acknowledged that his actions were inappropriate. The jury found him guilty based on the evidence presented.The Iowa District Court for Emmet County sentenced Schooley to five years of incarceration. Schooley appealed, arguing that there was insufficient evidence to support his conviction and that his sentence was improperly influenced by a victim-impact statement from the guardian ad litem (GAL). He contended that the GAL was not authorized to provide such a statement and that it contained unproven allegations.The Iowa Supreme Court reviewed the case and found that sufficient evidence supported the jury's verdict. The court noted that the reasonableness of corporal punishment is generally a question for the jury and that the evidence showed Schooley's actions were excessive and abusive. The court also addressed Schooley's challenge to the GAL's victim-impact statement, concluding that Schooley had waived this issue by not raising it in the district court. Additionally, the court found no affirmative showing that the district court relied on improper information from the GAL's statement when sentencing Schooley.The Iowa Supreme Court affirmed Schooley's conviction and sentence, holding that the evidence was sufficient to support the jury's verdict and that the district court did not abuse its discretion in considering the GAL's statement. View "State of Iowa v. Schooley" on Justia Law

A couple with older children volunteered to care for the newborn child of an incarcerated mother struggling with methamphetamine addiction. The mother relapsed multiple times, and the couple eventually became the child's guardians. The mother later sought to terminate the guardianship and raise her child, but the guardians had moved out of state with the child, who had become integrated into their family. The guardians sought to adopt the child, while the mother had made significant improvements in her life and wanted to regain custody.The Iowa District Court for Polk County denied the guardians' petition to terminate the mother's parental rights, finding that the guardians' restrictions on visitation and communication justified the mother's lack of contact with the child. The court noted that the guardians had moved out of state without informing the mother or the court, preventing her from maintaining regular contact.The Iowa Court of Appeals reversed the district court's decision, finding that the mother had abandoned the child under Iowa Code section 600A.8(3)(b) by failing to maintain substantial and continuous or repeated contact. The court of appeals determined that the guardians had not placed excessive restrictions on the mother's ability to communicate with the child and that the mother had not exerted sufficient effort to maintain contact.The Iowa Supreme Court affirmed the decision of the court of appeals, concluding that the mother had abandoned the child and that termination of her parental rights was in the best interests of the child. The court noted that the child had become integrated into the guardians' family and that granting the petition for termination would provide the child with stability and permanency. The case was remanded for further proceedings consistent with the opinion. View "In the Interest of J.V., Minor Child" on Justia Law

A credit union filed a claim in probate court, asserting that the decedent owed money on a car loan. The estate mailed a notice of disallowance to the credit union, but the credit union claimed it never received the notice. The estate argued that the claim was time-barred because the credit union did not request a hearing within twenty days of the notice. The credit union conducted an internal investigation and submitted an affidavit stating it never received the notice and that the person who signed for it was not an employee of the credit union but an agent of the U.S. Postal Service.The Iowa District Court for Linn County imposed sanctions on the credit union and its attorneys for violating Iowa Rule of Civil Procedure 1.413(1), which requires that filings be well-grounded in fact and law after reasonable inquiry. The court found that the credit union's investigation was insufficient and that the attorneys made incorrect assertions about the mailing. The Iowa Court of Appeals upheld the sanctions.The Iowa Supreme Court reviewed the case and concluded that the district court abused its discretion in awarding sanctions. The Supreme Court found that the credit union and its counsel conducted a reasonable investigation under the circumstances, given the time constraints and the information available. The court emphasized that the reasonableness of the investigation should be assessed based on the time of the filing, not with hindsight. The Supreme Court vacated the decision of the Court of Appeals, sustained the writ of certiorari, vacated the sanctions, and remanded the case for further proceedings. View "Dupaco Community Credit Union v. Iowa District Court for Linn County" on Justia Law

The defendant engaged in online conversations with an undercover police officer posing as a fifteen-year-old girl. He arranged to meet the girl for sex at a gas station shower room. Upon arrival, he was arrested and charged with solicitation of commercial sexual activity under Iowa Code section 710A.2A. The defendant argued that there was insufficient evidence to support the charge because he did not offer or promise anything of value in exchange for sexual activity. The district court rejected these arguments, and a jury convicted him.The Iowa District Court for Polk County denied the defendant's motion for a new trial and sentenced him to five years in prison. The Iowa Court of Appeals conditionally affirmed the conviction but remanded the case for the district court to reconsider the motion for a new trial under the correct standard. The defendant sought further review.The Iowa Supreme Court reviewed the case and found that the evidence was insufficient to show that the defendant was attempting to engage in commercial sexual activity. The court noted that while the defendant's behavior was reprehensible, he did not give or promise the undercover officer any item of value in exchange for a sex act. The court concluded that the statutory definition of "commercial sexual activity" requires an express or implied quid pro quo, which was not present in this case. Consequently, the court vacated the decision of the court of appeals, reversed the district court's judgment, and remanded the case for dismissal. View "State v. Fenton" on Justia Law

A baby, S.K., was injured during labor and delivery, allegedly due to the negligence of the delivering doctor, Dr. Goodman, who used a Mityvac obstetrical vacuum delivery system. The plaintiff, S.K.'s conservator, claimed that the use of the vacuum caused brain damage to S.K. and sought damages from Dr. Goodman’s employer, Obstetric & Gynecologic Associates of Iowa City and Coralville, P.C. (the clinic).A jury in the Iowa District Court for Johnson County found in favor of the plaintiff, awarding substantial damages. The clinic appealed, arguing that the district court erred in admitting a package insert from the vacuum, which contained hearsay statements about when the vacuum should not be used and potential harms from its use. The clinic contended that the insert's admission violated Iowa’s hearsay rule and prejudiced the trial's outcome.The Iowa Supreme Court reviewed the case and agreed with the clinic. The court found that the package insert contained hearsay and did not fit within any recognized exceptions, including the residual exception and the market reports exception. The court noted that the insert's admission was prejudicial, as it directly addressed a central dispute in the case and was emphasized in the plaintiff's closing argument. The court concluded that the erroneous admission of the insert deprived the clinic of a fair trial.The Iowa Supreme Court reversed the district court's judgment and remanded the case for a new trial. The court also addressed a procedural issue raised by the clinic regarding the plaintiff's certificate of merit affidavit, ultimately denying the clinic's motion to reverse on those grounds. View "S.K. v. Obstetric & Gynecologic Associates of Iowa City and Coralville, P.C." on Justia Law

Sarah Berg, an employee at Casey’s General Store, activated three gift cards without paying for them and used one to purchase gas the next day. She was arrested for fourth-degree theft. The county attorney did not file a trial information for this charge within the required 45 days. Instead, a trial information was later filed for unauthorized use of a credit card.The Iowa District Court for Black Hawk County denied Berg’s motion to dismiss the trial information for unauthorized use of a credit card, despite the missed speedy-indictment deadline for the theft charge. Berg was found guilty following a trial on the minutes. She was sentenced to 120 days in jail (suspended), a fine (suspended), court costs, probation, and potential restitution. Berg appealed, arguing the district court erred in denying her motion to dismiss and that the evidence was insufficient to support her conviction. The Iowa Court of Appeals affirmed her conviction.The Iowa Supreme Court reviewed the case and affirmed the lower courts' decisions. The court held that fourth-degree theft and unauthorized use of a credit card are not the same offense for speedy-indictment purposes. The court reasoned that the charges relied on distinct underlying facts: the theft charge required proof of taking property valued between $300 and $750, while the unauthorized use charge required proof of using a credit card to obtain property or services. Therefore, the State was not precluded from filing the new charge after the 45-day period had elapsed. View "State of Iowa v. Berg" on Justia Law