Justia Iowa Supreme Court Opinion Summaries

Articles Posted in Civil Rights
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The Supreme Court affirmed Defendant's conviction of first-degree murder arising from events in 1990 after his fourth trial, held almost thirty years after the crime, holding that Defendant was not entitled to relief on any of his claims of error.On appeal, Defendant argued that his conviction must be reversed due to juror misconduct, the improper admission of certain testimony, the erroneous exclusion of hearsay evidence, and a violation of due process. The Supreme Court disagreed and affirmed his conviction, holding that none of Defendant's allegations of error warranted reversal of his convictions. View "State v. Liggins" on Justia Law

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The Supreme Court held that the Iowa Constitution is not the source of a fundamental right to an abortion necessitating a strict scrutiny standard of review for regulations affecting that right.In Planned Parenthood of the Heartland, Inc. v. Iowa Board of Medicine (PPH I), 865 N.W.2d 252 (Iowa 2015), the Supreme Court applied the federal undue burden test established in Planned Parenthood of Southeastern Pennsylvania v. Casey, 505 U.S. 833 (1992), under the Iowa Constitution. In Planned Parenthood of the Heartland v. Reynolds (PPH II), 915 N.W.2d 206, (Iowa 2018), the Supreme Court rejected the undue burden test and found that the due process clause of the Iowa Constitution protected abortion as a fundamental right. In 2020, the general assembly added a mandatory 24-hour waiting period for abortion to pending legislation limiting courts' ability to withdraw life-sustaining procedures. Planned Parenthood successfully sued in district court to block the statute from taking effect. The district court granted summary judgment for Planned Parenthood. The Supreme Court reversed, holding (1) PPH II is overruled; and (2) therefore, the Casey undue burden test applied in PPH I remains the governing standard. View "Planned Parenthood of the Heartland, Inc. v. Reynolds ex rel. State" on Justia Law

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The Supreme Court affirmed Defendant's convictions for drug- and firearm-related offenses, holding that the district court did not abuse its discretion by granting defense counsel's motion to withdraw and did not err in concluding that Defendant knowingly, voluntarily, and intelligently waived his right to counsel.The district court granted defense counsel's motion to withdraw from representation of Defendant approximately three weeks before Defendant's speedy trial expiration date. Although the district court offered to appoint another attorney to represent Defendant, Defendant demanded that he represent himself with the assistance of standby counsel. After conducting colloquies the district court allowed Defendant to proceed pro se with the assistance of standby counsel. The Supreme Court affirmed Defendant's convictions, holding that the district court (1) did not abuse its discretion by granting defense counsel’s motion to withdraw based on defense counsel’s statements that professional considerations required termination of the representation; and (2) correctly concluded that Defendant knowingly, intelligently, and voluntarily waived his right to counsel after engaging in a thorough colloquy. View "State v. Miller" on Justia Law

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A father going through a contentious divorce was accused by his young daughter of sexual abuse. A Department of Human Services social worker observed the forensic interview, believed it was credible, obtained additional information primarily from the mother, and obtained an ex parte court order requiring the father to leave the family home. An ensuing adversary proceeding determined that the allegation was unfounded and that the mother had “wanted [the father] out of the house.” The DHS finding was set aside and, eventually, the father obtained physical care of the children. In the father's subsequent suit, the district court granted the defendants summary judgment.The Iowa Supreme Court affirmed. The claim of intentional interference with the parent-child relationship fails because that claim applies to extralegal actions— such as absconding with a child—not to judicially-approved acts. The claim for intentional infliction of emotional distress fails because the conduct here did not reach the level of an “outrage” necessary to sustain such a claim. The unreasonable search and seizure claim cannot succeed because there was no showing that the DHS social worker falsified the affidavit she submitted to the court or that the removal order would not have been granted without her questioned statements. The substantive due process claim fails because DHS’s conduct does not “shock the conscience.” A procedural due process claim cannot prevail because the father was provided with adequate process, which ultimately cleared his name. View "Lennette v. State of Iowa" on Justia Law

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In 2005, Sandoval was convicted of two counts of first-degree murder and two counts of attempted murder. He was sentenced to serve concurrent terms of life imprisonment without the possibility of parole for the murder convictions and 25 years’ imprisonment for the attempted murder convictions. Sandoval unsuccessfully challenged his convictions on direct appeal and in three different applications for postconviction relief.The Iowa Supreme Court affirmed the dismissal of Sandoval’s fourth application for postconviction relief, which the district court held was barred by the three-year statute of limitations of Iowa Code section 822.3. Sandoval argued that because he was only 19 at the time he murdered two people, his mandatory life sentences without the possibility of parole violated the federal and state constitutional prohibitions against “cruel and unusual punishment.” U.S. Const. amend. VIII; Iowa Const. art. I. The court disagreed. Sandoval’s mandatory sentences of lifetime incarceration without the possibility of parole for committing these offenses are not categorically prohibited by either the Federal Constitution or the state constitution. View "Sandoval v. State of Iowa" on Justia Law

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In 1994, Dorsey shot and killed a woman when he was 18 years and five days old. He was found guilty of murder in the first degree and was sentenced to a mandatory term of life in prison without the possibility of parole.In Dorsey’s fifth attempt to obtain post-conviction relief, the Iowa Supreme Court affirmed his sentence, rejecting Dorsey’s argument that the sentence violates his state constitutional right to be free from “cruel and unusual punishment.” He argued the state constitution prohibits imposing a mandatory punishment on a young adult offender and instead requires the district court to hold an individualized sentencing hearing before imposing any sentence and that his life sentence without the possibility of parole is grossly disproportionate to the crime. Considerations of efficiency and certainty require a bright line separating adults from juveniles. There is nothing unique about the facts of this case that raise an inference of gross disproportionality. Dorsey’s willful, deliberate, and premeditated murder of an unarmed woman in her own home justifies the most severe sentence allowed under our law. View "Dorsey v. State of Iowa" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals reversing the order of the district court granting Defendant's motion to suppress evidence of drugs seized following a pat-down, holding that law enforcement's conclusion that Defendant possessed drugs met the bar to establish probable cause.The district court concluded that the officer's inability to discern the type of the drugs in the packaging before removing them from Defendant's pocket required suppression of the evidence. The court of appeals reversed, determining that the evidence was sufficient under the plain-feel exception to the warrant requirement that Defendant believed the package contained heroin, powder cocaine, or crack cocaine, despite not knowing which one. The Supreme Court affirmed, holding that the evidence established probable cause for the officer to have arrested Defendant for drug possession. View "State v. Hunt" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress and convicting him of possession of methamphetamine, second offense, holding that law enforcement acted reasonably under the Fourth Amendment and Iowa Const. art. I, 8 by ordering Defendant out of the vehicle.Defendant was the passenger in a vehicle that was stopped for speeding. Officers asked Defendant to exit the vehicle in order to facilitate the lawful arrest of the back-seat passenger. Officers then asked if they could check Defendant for weapons. The officer's pat-down revealed a methamphetamine pipe and a baggie containing methamphetamine. Defendant moved to suppress the evidence obtained after the exit order, which the district court denied. The Supreme Court affirmed, holding (1) Defendant's consent was voluntary based on the totality of the circumstances; and (2) the Iowa Constitution does no require that subjects of a search must be informed of their right to decline the search in order for their consent to be voluntary. View "State v. Hauge" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court denying Defendant's motion to suppress and convicting him of being a felon in possession of a firearm, holding that there was no error in the denial of the motion to suppress.Defendant was a passenger in a Lyft vehicle that was stopped for traffic violations. The officers recognized Defendant from past eluding incidents and ordered him out of the vehicle to conduct a pat-down for weapons. Defendant moved to suppress the evidence, arguing that the officer lacked reasonable and articulable facts to justify ordering him out of the vehicle and patting him down. The district court denied the motion to suppress, and the court of appeals affirmed. The Supreme Court affirmed, holding that the officer had reasonable suspicion to justify ordering Defendant out of the vehicle and subsequently patting him down for weapons. View "State v. Williams" on Justia Law

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In this criminal action, the Supreme Court affirmed the ruling of the district court on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury, holding that Defendant's conviction of second-degree murder stands.On appeal, Defendant, an African-American, argued that his right to an impartial jury under the United States Constitution had been violated because his jury pool contained only two African-Americans, one of whom was later excused. The Supreme Court made refinements to how a defendant must prove a fair-cross-section constitutional violation and remanded the case to give Defendant an opportunity to develop his impartial-jury arguments. On remand, the district court rejected Defendant's further-developed claims. The Supreme Court affirmed, holding that the district court did not err in ruling on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury. View "State v. Williams" on Justia Law