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A “criminal case” as used in Iowa’s recently enacted expungement law, Iowa Code 901C.2, refers to a single numbered legal proceeding. In 2011, Defendant was charged with several aggravated misdemeanors in a single trial information. At the same time, he was separately charged by criminal complaint with a single misdemeanor. Defendant pleaded guilty to a lesser included offense of one count of the trial information, and all other charges, including the simple misdemeanor criminal complaint, were dismissed. In 2016, Defendant sought expungement of the record of the dismissed simple misdemeanor complaint. The magistrate and district court denied relief, concluding that the misdemeanor and the offense to which Defendant had pled guilty in the trial information comprised a single criminal case within the meaning of section 901C.2(1)(a)(1) because they were factually related. The Supreme Court reversed the district court’s judgment denying expungement, holding that Defendant was entitled to expungement of the record of the dismissed simple misdemeanor complaint. View "State v. Clemens" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed the judgment of the district court granting summary judgment on Plaintiff’s malicious prosecution claim on the ground that Defendants did not instigate Plaintiff’s criminal prosecution. Linda Linn and Mark Shuck (together, Plaintiffs) brought suit against Defendants claiming defamation and malicious prosecution. The district court granted summary judgment and partial summary judgment on the defamation claim based on the running of the statute of limitations and granted summary judgment on the malicious prosecution claim. Shuck appealed. The Supreme Court held (1) due to an answer to a special interrogatory by the jury, the court will not reach the statute of limitations arguments made by Shuck on the defamation claim; and (2) the district court did not err in granting summary judgment on the malicious prosecution claim where Defendants merely furnished information to law enforcement. View "Linn v. Montgomery" on Justia Law

Posted in: Personal Injury

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A hearing conducted by the district court to determine if a juvenile offender should be sentenced to a minimum term of incarceration without eligibility for parole did not, in this case, comply with constitutional safeguards. The district court concluded that the juvenile in this case should serve the statutory mandatory minimum term of incarceration before becoming eligible for parole. The court of appeals affirmed. The Supreme Court reversed, holding that the district court abused its discretion in its application of the sentencing factors because critical conclusions drawn by the court at the sentencing hearing were not grounded in science but rather based on generalized attitudes of criminal behavior that may or may not be correct as applied to juveniles. The court remanded the case for resentencing in light of State v. Roby, 897 N.W.2d, 127 (Iowa 2017). View "State v. White" on Justia Law

Posted in: Juvenile Law

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The Supreme Court affirmed the judgment of the district court granting summary judgment to Defendants in this case brought by an independent contractor who sued for damages when he purchased a used tractor from a John Deere implement dealer that proved to be a “lemon.” The contractor brought suit against several parties, including the implement dealer. The court of appeals affirmed the judgment of the district court in all respects but reversed the district court’s grant of summary judgment on the contractor’s express warranty claim against the implement dealer. The Supreme Court vacated in part the decision of the court of appeals, holding that the disclaimers contained in the purchase agreement negated any express warranties allegedly made by the implement dealer. View "Cannon v. Bodensteiner Implement Co." on Justia Law

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Defendant was required to register as a sex offender under Iowa Code 692A.103(1) upon his conviction of lascivious conduct with a minor and release on bond, notwithstanding this appeal. Defendant argued that he had no obligation to register after posting an appeal bond to stay execution of the underlying criminal judgment and before he began serving any prison sentence or was placed on probation. The district court concluded that Defendant was required to register as of the date he was sentenced to prison for the sex offense and was released on the appeal bond. Defendant’s conviction was later affirmed on appeal. Now Defendant faced new criminal charges for violating chapter 692A’s sex offender residency restrictions before his conviction was affirmed. The Supreme Court affirmed the judgment of the district court, holding (1) the stay of execution on Defendant’s criminal judgment did not delay the automatic administrative registration requirement for convicted sex offenders; and (2) Defendant’s release on the appeal bond constituted a “release from incarceration” within the meaning of section 692A.103(1). View "Maxwell v. Iowa Department of Public Safety" on Justia Law

Posted in: Criminal Law

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In this will contest, the district court did not abuse its discretion in denying the unsuccessful will contestant’s motion to amend the pleadings to conform to the proof at the close of his case. The contestant’s motion at issue sought to broaden the contestant’s undue influence claim to include all of the testator’s prior wills and codicils. The Supreme Court held that the last-minute amendment would have broadened the issues and the proof. In addition, this issue fell within precedent upholding denials of motions to amend under Iowa R. Civ. P. 1.457 when the motion is based on facts the movant knew or should have known before trial. As to the contestant’s other issue asking the Supreme Court to overturn a ruling on burden of proof that was incorporated within a pretrial order denying summary judgment, this issue was not preserved for review. Accordingly, the Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court. View "In re Estate of Margaret E. Workman" on Justia Law

Posted in: Trusts & Estates

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Under the circumstances of this case, Defendant was denied procedural protections for determining his status as an habitual offender at trial, and Defendant did not need to preserve error by filing a motion in arrest of judgment. After a bench trial, Defendant was convicted of indecent exposure and sentenced as a habitual offender. Defendant also pled guilty to indecent exposure. On appeal, the State conceded that the plea colloquy was insufficient. However, contrary to Defendant’s arguments, the State argued that the stipulation relating to Defendant’s prior convictions was sufficient. The court of appeals concluded that Defendant failed to preserve error on his claim that the stipulation concerning his prior convictions was deficient and that Defendant was required to challenge the sufficiency of the proceedings either by filing a motion in arrest of judgment or by another means. The Supreme Court vacated the decision of the court of appeals and reversed the judgment and sentences of the district court, holding (1) requirements of the enhanced-penalty hearing were not followed by the district court; and (2) the error preservation rule established in State v. Harrington, 893 N.W.2d 36 (Iowa 2017) was not in existence at the time. View "State v. Steiger" on Justia Law

Posted in: Criminal Law

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The Iowa Department of Corrections (IDOC) may not forfeit earned time an inmate accrued before his refusal of or removal from the Sex Offender Treatment Program (SOTP). For more than a decade, the IDOC policy stopped only the ongoing accrual of earned time for inmates upon a refusal or removal from SOTP without forfeiting previously accrued earned time. This interpretation was upheld by the Supreme Court in Holm v. State, 767 U.W.2d 409 (Iowa 2009). In 2016, the IDOC changed its policy to additionally forfeit all previously accrued earned time upon a refusal or removal from SOTP and applied that change retroactively. The district court concluded that the new IDOC policy interpretation and application to a certain inmate whose release was delayed by more than three years due to the new policy was contrary to Holm and violated the state and federal Ex Post Facto Clauses. The Supreme Court applied stare decisis and the interpretation fixed in Holm and affirmed. View "State v. Iowa District Court for Jones County" on Justia Law

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The Supreme Court decided not to abandon the automobile exception to the search warrant requirement under Iowa Const. art. I, 8 despite technological advances enabling police to obtain warrants from the scene of a traffic stop. Defendant was convicted of possession with intent to deliver. Defendant appealed the denial of his motion to suppress, arguing that the warrantless search of his vehicle violated the Iowa Constitution because police can now obtain warrants electronically from the side of the road. The Supreme Court elected to retain the automobile exception, consistent with precedent, federal caselaw, and the overwhelming majority of other states. The court thus affirmed Defendant’s conviction. View "State v. Storm" on Justia Law

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In this case, the Supreme Court abandoned the exclusive use of absolute disparity as a test for jury representativeness under the Sixth Amendment and permitted absolute disparity, comparative disparity, and standard deviation analyses to be used. Defendant, a black man, was convicted by an all-white jury of one count of harassment in the first degree. On appeal, Defendant argued that the racial composition of the jury pool violated his Sixth Amendment right to an impartial jury. The Supreme Court conditionally affirmed Defendant’s conviction and remanded the case for development of the record on the Sixth Amendment challenge, holding that the district court erred as a matter of law in concluding that the absolute disparity test must be used in deciding whether the jury pool was drawn from a fair cross-section of the community. View "State v. Plain" on Justia Law