Articles Posted in Civil Rights

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The Supreme Court reversed the judgment of the district court denying Defendant’s motion to suppress evidence obtained after an officer stopped his vehicle for being on a county access road after hours. The district court determined that Defendant violated Iowa Code 350.5 by entering the county access area after hours, regardless of whether there was a sign posted to identify the county access area or the park hours. The Supreme Court disagreed, holding (1) the officer did not have probable cause or reasonable suspicion to stop Defendant’s vehicle when it was on the county access road after hours because, without a proper posting of the closing time, the officer did not have probable cause or reasonable suspicion to stop Defendant; and (2) therefore, the district court should have suppressed any drug evidence found in Defendant’s vehicle. View "State v. Scheffert" on Justia Law

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Iowa may constitutionally deny an inheritance tax exemption for bequests to stepchildren when the marriage between parent and stepparent was dissolved before the stepparent’s death, while granting an exemption when the marriage was not dissolved. The Supreme Court affirmed the judgment of the district court affirming the administrative ruling of the Iowa Department of Revenue denying an estate’s request for a tax refund. An administrative law judge rejected the decedent’s stepchildren’s protest challenging the denial of the tax refund on the ground that Iowa Code 450.1(1)(e)’s classification of stepchildren violated their equal protection rights under Iowa Const. art. I, 6. The district court affirmed the Department’s decision. The Supreme Court affirmed, holding that section 450.1(1)(e) does not violate article I, section 6 of the Iowa Constitution because a rational basis exists for the legislature to exclude stepchildren postdivorce from the inheritance tax exemption for surviving spouses lineal descendants, lineal ascendants, and other stepchildren. View "Tyler v. Iowa Department of Revenue" on Justia Law

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Defendant was not entitled to an automatic new trial after the district court, over Defendant’s objection, required a standby interpreter for his jury trial. Defendant requested, and was provided, an interpreter for all of his pretrial hearings. Defendant sought to waive the interpreter for his jury trial, however. The district court nevertheless ordered a standby interpreter to sit in the gallery translating through a wireless earpiece Defendant could remove at his option. Defendant waived the jury and, after a bench trial, was convicted of selling cocaine. The Supreme Court affirmed, holding (1) Defendant had a right to waive the interpreter, but the district court did not abuse its discretion by ordering a standby interpreter over Defendant’s objection; and (2) the record was inadequate to review Defendant’s claim that his counsel was ineffective in waiving the jury. View "State v. Garcia" 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

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This case involved claims brought against various state officials for damages related to public employment. Plaintiff was an Iowa Workers’ Compensation Commissioner. At issue in this interlocutory appeal were four counts alleging violation of due process and equal protection provisions of the Iowa Constitution. The district court granted summary judgment for Defendants on these claims finding that there are no private causes of action for violations of the Iowa Constitution. The Supreme Court reversed in part and affirmed in part, holding that Defendants were not entitled to summary judgment on Counts VI and VII where (1) the equal protection clause of the Iowa Constitution is self-executing; (2) classic preempt doctrine does not apply to the question of whether a Bivens-type damage remedy is available through the Iowa Constitution; and (3) the different nature of the interests protected weighs in favor of allowing a Bivens-type claim to go forward against Defendants. View "Godfrey v. State" on Justia Law

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The administration of a warrantless breath test to Defendant violated Iowa Const. art. I, 8 because the State failed to prove that Defendant voluntarily consented to the warrantless breath test and failed to prove that the breath test was justified by an exception to the warrant requirement. Defendant was convicted of operating a motorboat while under the influence. Defendant appealed the denial of his motion to suppress all evidence after an officer seized the boat he was operating, including the results of a blood test he submitted to. The Supreme Court reversed, holding (1) the law enforcement officer’s seizure of the boat Defendant was operating was constitutional because the officer had a reasonable, articulable suspicion Defendant was committing a crime; but (2) Defendant did not effectively consent to the warrantless breath test, and therefore, the admission of the breath test results violated article I, section 8. View "State v. Pettijohn" on Justia Law

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In this employment discrimination case, prejudicial errors in four jury instructions required a new trial. Plaintiff filed claims against her former employer, alleging sexual harassment and retaliation under the Iowa Civil Rights Act (ICRA). The jury returned a verdict for Plaintiff on both counts and awarded damages in the amount of $1.4 million. Employer then filed a motion for new trial, which the district court denied. The Supreme Court reversed, holding (1) workers may bring a direct-liability negligence claim under the ICRA against an employer for supervisor harassment, but the plaintiff must prove that the employe knew or should have known of the harassment and failed to take prompt and appropriate remedial action to end it; (2) the district court did not abuse its discretion in admitting expert testimony on legal standards; but (3) the district court misinstructed the jury in four jury instructions, necessitating a new trial. View "Haskenhoff v. Homeland Energy Solutions, LLC" on Justia Law

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Defendant did not have a right to counsel under Iowa Const. art. I, section 10 when he voluntarily participated in a noncustodial police interview under the supervision of an Iowa county attorney even though the State’s criminal investigation was focusing on Defendant as the primary suspect at the time. Defendant was found guilty of murder in the first degree. During trial, the district court instructed the jury that it could infer Defendant acted with malice aforethought from his use of a baseball bat. The jury found Defendant killed the victim without justification and with malice aforethought. The court of appeals affirmed the judgment and sentence. The Supreme Court affirmed, holding (1) the level of prosecutorial involvement at the time of the interview did not create a prosecution or case that would trigger the right to counsel under article I, section 10; and (2) the jury could properly infer malice aforethought from Defendant’s use of a deadly weapon even though Defendant did not bring the weapon to the encounter. View "State v. Green" on Justia Law

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The Supreme Court reversed Defendant’s conviction for domestic abuse assault, third offense, and remanded this case for a new trial, holding that Defendant received ineffective assistance of counsel because his trial counsel failed to request a jury instruction defining “household member.” The court thus vacated the decision of the court of appeals, which affirmed the conviction over a dissent. The majority concluded that defense counsel had breached an essential duty by failing to request the definition instruction but that Defendant failed to show prejudice because the State had presented sufficient evidence of cohabitation. The Supreme Court held (1) because the central issue at trial was whether Defendant and the victim had been cohabitating, the jury should have been given the definition instruction, which accurately set forth the factors bearing on that issue; and (2) therefore, defense counsel’s failure to request the instruction was prejudicial, necessitating a new trial. View "State v. Virgil" on Justia Law