Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court sentencing Defendant to prison for a maximum of ten years for theft in the first degree, to be served consecutively with five years for theft in the second degree, holding that Defendant failed to preserve his due process claim for direct appeal and that this Court could not reach Defendant’s ineffective assistance of counsel due process claim on direct appeal for the reasons stated in State v. Gordon, __ N.W.2d __ (Iowa 2018), also decided today.On appeal, Defendant argued that the district court violated his due process rights by using an Iowa Risk Revised assessment report (IRR) in sentencing. In the alternative, Defendant argued that the court abused its discretion by considering the IRR without understanding the contours of the IRR. Defendant further asserted an ineffective assistance of counsel claim. The Supreme Court affirmed for the reasons set forth in Gordon. View "State v. Buesing" on Justia Law

The Supreme Court vacated the decision of the court of appeals finding that there is no legislative authority supporting the use of the Iowa Risk Revised risk assessment tool (IRR) at sentencing and affirmed the decision of the district court, holding that the court’s use of the IRR in sentencing Defendant did not violate his due process rights.Defendant pled guilty to burglary in the second degree as part of a plea agreement. Defendant later violated the conditions of release and pled guilty to the additional charge of interference with official acts. The presentence investigation report stated that the interviewer completed an IRR, which recommended that Defendant be supervised at an intensive level. The district court sentenced Defendant to prison for an indeterminate term, not to exceed ten years plus ninety days in jail, to be served concurrently with the burglary sentence. The court of appeals vacated the sentence. The Supreme Court vacated the court of appeals and affirmed the judgment of the district court, holding (1) the court did not infringe on Defendant’s due process rights based on its use of the IRR at sentencing; and (2) the court did not abuse its discretion by discussing an unproven or unprosecuted offense. View "State v. Guise" on Justia Law

The Supreme Court vacated the decision of the court of appeals reversing Defendant’s sentence and affirmed the judgment of the district court, holding that Defendant failed to preserve error on his due process claim and that the district court did not use an unproven or unprosecuted offense when it sentenced Defendant.Defendant pled guilty to third-degree sexual abuse. As part of the presentence investigation, Defendant underwent a psychosexual evaluation, resulting in a psychosexual assessment report. The district court ultimately sentenced Defendant to a prison term not to exceed ten years. The court of appeals reversed, holding the the legislature has not deemed sex offender risk assessment tools relevant in imposing prison sentences. The Supreme Court vacated the court of appeals and affirmed the district court’s sentence, holding (1) the district court did not violate Defendant’s due process rights by consideration of and reliance on the sex offender risk assessment tools in imposing its sentence; and (2) the district court did not abuse its discretion by relying on an unproven or unprosecuted offense. View "State v. Gordon" on Justia Law

The Supreme Court affirmed the decision of the district court denying Appellant’s application for postconviction relief (PCR), holding that Appellant’s requested remand for a new hearing was not available and that Appellant’s claim that his postconviction counsel was ineffective must be brought in a separate application for PCR.In his application for PCR Appellant sought to vacate his conviction based on newly discovered evidence. The district court denied the PCR application and rejected Appellant’s ineffective assistance of counsel claim. On appeal, Appellant argued that the district court improperly dismissed his PCR application because his postconviction counsel failed to present physical evidence at the PCR hearing to support his claim. Therefore, Appellant asked that his PCR application be remanded to the district court for a new hearing. The Supreme Court affirmed, holding that no error occurred, that the request made to remand the case failed, and that Appellant must raise his claim of ineffective assistance of postconviction counsel in a separate application for PCR. View "Goode v. State" on Justia Law

The Supreme Court reversed in part the decision of the court of appeals denying Defendant’s ineffective assistance of counsel claim on appeal, holding that the court erred in finding that Defendant waived his ineffective assistance claim by only including a cursory discussion of ineffective assistance in a footnote.Defendant was convicted of drug offenses. On appeal, the court of appeals held (1) there was sufficient evidence to support the convictions, and (2) Defendant failed to preserve error on his ineffective assistance of counsel claim. On further review, the Supreme Court held that the court of appeals erred in rejecting Defendant’s ineffective assistance claim rather than preserving it for a postconviction relief proceeding. The Court then affirmed the judgment of the district court and instructed that Defendant could bring a separate postconviction relief action based on his ineffective assistance of counsel claim. View "State v. Harris" on Justia Law

The Supreme Court reversed the judgment of the trial court convicting Defendant of operating while intoxicated (OWI), holding that the stop of the van in which Defendant was a passenger violated Iowa Const. art. I, section 8.After responding to a dispatch report of a vehicle in a roadside ditch, officers saw a van pass by on the road. Discovering that the van’s license plate was registered to another member of the same household that the vehicle in the ditch had been registered to, the officers followed the van and pulled it over. The driver of the car that had gone into the ditch was riding as a passenger in the van. That person, Defendant, was convicted of OWI. Defendant appealed the denial of his motion to suppress, arguing that the stop of the van was not permissible under the community caretaking doctrine. The Supreme Court agreed and reversed Defendant’s conviction and sentence, holding that the community caretaking exception did not apply under article I, section 8. View "State v. Smith" on Justia Law

In this case challenging an automated traffic enforcement (ATE) program implemented by the City of Des Moines and its private contractor, Gatso USA, Inc., the Supreme Court reversed in part and affirmed in part the district court’s judgment, holding that the district court (1) erred in finding that the City’s ATE ordinance violated procedural due process; (2) properly granted Defendants’ motion to dismiss on grounds of preemption; (3) did not err in granting summary judgment to Gatso on Plaintiffs’ unjust enrichment claims; (4) erred in dismissing Plaintiffs’ equal protection, substantive due process, and privileges and immunities claims; and (5) erred in holding that there was no action for damages under the Iowa Constitution. Further, in light of the changed posture of the case, the Supreme Court vacated the district court’s order on unjust enrichment and the order on class certification and remanded for further consideration. View "Weizberg v. City of Des Moines" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court granting summary judgment in favor of Defendants on Plaintiffs’ class-action petition claiming that an automated traffic enforcement system (ATE) as implemented by Defendants violated the due process, privileges and immunities, and equal protection clauses of the Iowa Constitution.Specifically, hte Supreme Court held (1) the ATE system does not infringe on a fundamental right to intrastate travel; (2) the ATE system does not violate substantive due process; (3) the district court properly granted summary judgment on Plaintiffs’ equal protection and privileges and immunities claims; (4) the provisions of the ordinance that purportedly impose liability on a protesting vehicle owner under certain circumstances are irreconcilable with the provisions of Iowa Code 364.22 and are thus preempted; (5) the process outlined in the ATE ordinance complies with due process; (6) Plaintiffs’ unlawful delegation claims failed; and (7) because the district court’s judgment on the issue of preemption is reversed, the court’s judgment on unjust enrichment must be vacated and remanded for further consideration in light of the changed posture of the case. View "Behm v. City of Cedar Rapids" on Justia Law

The Supreme Court held that Division I of Senate File 471 (the Act), which creates new prerequisites for physicians performing an abortion, violates both the due process and equal protection clauses of the Iowa Constitution because its restrictions on women are not narrowly tailored to serve a compelling interest of the State.The district court held that the Act, which includes a mandatory seventy-two-hour waiting period between informational and procedure appointments, did not violate the Iowa Constitution. The Supreme Court reversed, holding that the “seventy-two hour[]” waiting requirement of the Act violates the right to equal protection and due process under the Iowa Constitution. View "Planned Parenthood of the Heartland v. Reynolds ex rel. State" on Justia Law

At issue was whether the three-year statute of limitations in Iowa Code 822.3 applies where a postconviction relief (PCR) petitioner files an untimely second petition for PCR alleging that counsel for his timely filed first petition for PCR was ineffective.The district court concluded that the second petition’s allegations of ineffective assistance of postconviction counsel were not grounds to avoid the three-year statutory bar. The court of appeals affirmed, citing the Supreme Court’s decision in Dible v. State, 557 N.W.2d 881, 883, 886 (Iowa 1996).The Supreme Court qualified Dible and held that where a PCR petition alleging ineffective assistance of trial counsel has been timely filed per section 822.3 and there is a successive PCR petition alleging that postconvcition counsel was ineffective in presenting the ineffective-assistance-of-trial-counsel claim, the timing of the filing of the second PCR petition relates back to the timing of the filing of the original PCR petition for purposes of Iowa Code section 822.3 if the successive PCR petition is filed promptly after the conclusion of the first PCR petition. The Court therefore vacated the court of appeals and reversed the decision of the district court and remanded the case. View "Allison v. State" on Justia Law