Justia Iowa Supreme Court Opinion Summaries

The Supreme Court vacated the decision of the court of appeals reversing Defendant's conviction of second-degree murder, holding that Defendant was not entitled to a new trial on any of his allegations of error.After trial, Defendant filed a motion for a new trial alleging, among other things, that the trial court erred in refusing to disqualify a juror who allegedly made out-of-court statements regarding Defendant's guilt and misconduct and bias related to extraneous information reaching the jury about a possible riot if a certain verdict was not returned. The district court denied the motions for a new trial and entered judgment. The court of appeals reversed, concluding that juror misconduct and bias warranted a new trial. The Supreme Court vacated the decision of the court of appeals and affirmed the district court judgment, holding that Defendant was not entitled to a new trial under the facts of this case. View "State v. Christensen" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming in part and reversed in part the judgment and sentence of the district court convicting Defendant of operating while intoxicated (OWI) second offense, holding that the clause of the OWI statutes that makes it unlawful for a person to operate a motor vehicle with any amount of a controlled substance in his or her person does not violate the Due Process Clause of either the United States or Iowa Constitution as applied to the facts of this case.The court of appeals found Iowa Code 321J.2(a)(c), which makes it unlawful for a person to operate a motor vehicle "[w]hile any amount of a controlled substance is present in the person," does not violate due process guarantees but reversed the judgment and sentence after concluding that the district court failed to engage in a proper colloquy before accepting a stipulation relating to the prior conviction for OWI. The Supreme Court only addressed the due process claim and affirmed the court of appeals as to the remaining issues, holding that section 321J.2(1)(c) does not violate the requirements of due process under the federal or state Constitutions as applied to this case. View "State v. Newton" on Justia Law

The Supreme Court conditionally affirmed Defendant's conviction and sentence for first-degree murder but remanded for further proceedings consistent with decisions it also filed today in State v. Lilly, __ N.W.2d __ (Iowa 2019), and State v. Veal, __ N.W.2d __ (Iowa 2019), and this opinion, holding that further consideration of Defendant's claim that his jury was not drawn from a fair cross section of the community, in violation of the Sixth Amendment to the United States Constitution and article I, section 10 of the Iowa Constitution, was warranted.Defendant, an African-American, was charged with first-degree murder in a county that was approximately 2.3 percent African-American in population. The jury pool of unexcused jurors, however, contained only one African-American. The Supreme Court held (1) as in Lilly and Veal, the appropriate course of action is to remand the case to offer Defendant a further opportunity to develop his arguments that his Sixth Amendment right to an impartial jury was violated; and (2) Defendant's remaining claims of error did not warrant a new trial. View "State v. Williams" on Justia Law

The Supreme Court conditionally affirmed Defendant's conviction for aiding and abetting a bank robbery and remanded for further consideration of Defendant's claim that his jury was not drawn from a fair cross section of the community, in violation of the Sixth Amendment to the United States Constitution and article I, section 10 of the Iowa Constitution, holding that further consideration of this claim was warranted.Defendant, an African-American, was convicted following a trial by a jury that contained no African-Americans. Further, there were no African-Americans in the jury venire that reported that day. On appeal, Defendant argued that the racial composition of the jury pool violated his rights to an impartial jury under both the federal and the state constitution. The Supreme Court held that the typical jury management practices can support a systematic exclusion claim under the framework established in State v. Plain, 898 N.W.2d 801 (Iowa 2017), and Duren v. Missouri, 439 U.S. 357 (1979), where the evidence shows one or more of those practices have produced underrepresentation of a minority group, and this case will be remanded to give Defendant a further opportunity to develop his fair-cross-section claim. View "State v. Lilly" on Justia Law

The Supreme Court conditionally affirmed Defendant's conviction of two counts of first-degree murder while remanding the case for further proceedings consistent with State v. Lilly, __ N.W.2d __ (Iowa 2019), also decided today, holding that further consideration of Defendant's claim of violation of his right to an impartial jury drawn from a fair cross section of the community was warranted.Defendant was an African-American. Although the jury venire contained five African-Americans, no African-American was seated on the jury that heard Defendant's case. On appeal, Defendant asserted a number of trial-related issues, including the claim that his jury was not drawn from a fair cross section of the community in violation of the Sixth Amendment. The Supreme Court held (1) as in Lilly, the appropriate course of action is to remand the case to offer Defendant a further opportunity to develop his arguments that his Sixth Amendment right to an impartial jury was violated; and (2) Defendant's remaining claims did not warrant reversal. View "State v. Veal" on Justia Law

The Supreme Court affirmed the district court's grant of summary judgment in favor of Defendants on Plaintiffs' claim that the 2017 amendments to Iowa Code chapter 20, the Public Employment Relations Act (PERA), violate the equal protection clause of the Iowa Constitution, holding that the 2017 amendments withstood the constitutional challenges.The 2017 amendments resulted in new classifications that made many public employees lose significant statutory bargaining rights compared to other public employees with ostensibly similar jobs. A public employee union and some of its members filed this action against the State and the Public Employment Relations Board (PERB) seeking injunctive and declaratory relief alleging that the amendments violated the equal protection clause of the Iowa Constitution and their right to freedom of association. The district court dismissed the action on summary judgment. The Supreme Court affirmed, holding that the legislative classifications are not so overinclusive or underinclusive as to be unconstitutional and that the amendments do not violate constitutional rights of freedom of association. View "AFSCME Iowa Council 61 v. State" on Justia Law

The Supreme Court affirmed the district court's summary judgment in favor of Defendants on Plaintiffs' claim that the 2017 amendments to Iowa Code chapter 20, the Public Employment Relations Act (PERA), violate the equal protection clause of the Iowa Constitution, holding that the 2017 amendments withstood the constitutional challenges.The 2017 amendments resulted in new classifications that made many public employees lose significant statutory bargaining rights compared to other public employees with ostensibly similar jobs. Two unions representing public school employees filed this action seeking injunctive and declaratory relief against the State, the Iowa Public Employment Relations Board (PERB), and three PERB board members, alleging that the amendments violated the equal protection clause of the Iowa Constitution. The district court dismissed the action on summary judgment. The Supreme Court affirmed, holding that the legislative classifications are not so overinclusive or underinclusive as to be unconstitutional under this Court's rational basis test. View "Iowa State Education Ass'n v. State, Iowa Public Employment Relations Board" on Justia Law

The Supreme Court affirmed the ruling of the district court denying Jane Doe's motion to expunge her record, holding that the condition in Iowa Code 901C.2, the expungement statute, that an individual pay all court-imposed costs and fees does not violate the Equal Protection Clauses of the United States or Iowa Constitutions.Section 901C.2 creates a statutory right to expungement subject to several conditions. Doe was an indigent defendant who was denied expungement for failure to pay off her court-appointed attorney fees. On appeal, Defendant argued that the condition that she pay her court-appointed attorney fees violated her equal protection rights. The district court denied Doe's constitutional challenge and denied her motion to expunge her record. The Supreme Court affirmed, holding that the requirement to pay court costs, including court-appointed attorney fees, is rationally related to the government interest in collecting court debt. View "State v. Doe" on Justia Law

The Supreme Court affirmed Defendant's conviction but vacated the portion of Defendant's sentence regarding restitution, holding that remand was required because the district court did not have the benefit of the procedures outlined in State v. Albright, __ N.W.2d __ (Iowa 2019).The court of appeals affirmed Defendant's conviction, holding that Defendant's counsel was not ineffective for failing to challenge the sufficiency of the evidence. The court further found that the district court did not err in assessing restitution for appellate attorney fees. The Supreme Court granted further review and affirmed Defendant's conviction, letting the court of appeals decision stand as this Court's final decision regarding Defendant's ineffective assistance of counsel claims. As to Defendant's argument that the district court erred in ordering him to pay restitution in the form of appellate attorney fees without first determining his reasonable ability to pay those fees, the Court held that the restitution part of Defendant's sentence regarding those fees should be vacated and the case remanded to the district court to impose restitution consistent with this Court's decision in Albright. View "State v. Dieckmann" on Justia Law

The Supreme Court affirmed the judgment of the district court holding that sex offender registration requirements are not punitive and convicting Defendant of failing to report his Internet identifier for a Facebook account he was using under an assumed name, holding that the Internet identifier reporting requirement withstands challenge under the First Amendment and article I, section 7 of the Iowa Constitution.Defendant pleaded guilty to lascivious acts with a child and was placed on the sex offender registry pursuant to Iowa Code chapter 692A. The legislature's 2009 amendment to that statute added the requirement that the offender disclose his Internet identifiers. Defendant was later charged with failing to report his Internet identifier. Defendant argued that the statute, as applied, violated the Free Speech and Ex Post Facto Clauses in the state and federal constitutions. The district court rejected Defendant's constitutional challenges. The Supreme Court affirmed, holding that the Internet identifier reporting requirement of Iowa Code chapter 692A.104(1) is narrowly tailored to serve a significant governmental interest. View "State v. Aschbrenner" on Justia Law