Justia Iowa Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of going armed with intent and willful injury causing bodily injury. Defendant appealed, arguing that defense counsel provided ineffective assistance by failing to challenge the sufficiency of the evidence supporting submission of the going-armed-with-intent charge to the jury and failing to object to the jury instruction on going armed with intent on the ground that it omitted an element of the charged offense. The Supreme Court reversed, holding (1) defense counsel was not ineffective in failing to challenge the sufficiency of the evidence; but (2) defense counsel breached a duty in failing to object to the marshaling instruction for the going-armed-with-intent offense, and Defendant suffered prejudice as a result. Remanded. View "State v. Harris" on Justia Law

In 2004, Gary Pettit pled guilty to third-degree sexual abuse and third-degree kidnapping, Pettit was incarcerated at the Anamosa State Penitentiary. In 2015, the Iowa Department of Corrections (IDOC) informed Pettit that he would be required to complete sex offender treatment. After a sex offender treatment program (SOTP) classification hearing, an administrative law judge (ALJ) affirmed the classification decision, concluding that Pettit was required to complete the SOTP. Pettit filed a petition for judicial review, claiming that the IDOC violated his due process rights by refusing to allow him access to counsel during the classification hearing. The district court determined that Pettit was entitled to counsel at the hearing. The Supreme Court vacated the judgment of the district court and remanded, holding that the district court did not have authority to review the classification hearing under Iowa Code chapter 17A. Remanded for dismissal of Pettit’s petition for judicial review. View "Pettit v. Iowa Department of Corrections" on Justia Law

Defendant was charged with driving while barred. Defendant filed a motion to suppress, which the district court denied. Defendant was subsequently convicted. Defendant appealed the denial of his motion to suppress, arguing that a law enforcement officer, after making a valid traffic stop supported by reasonable suspicion that an offense may being committed, must terminate the stop when the underlying reason for the stop is no longer present. The Supreme Court agreed with Defendant and reversed, holding (1) when the reason for a traffic stop is resolved and there is no other basis for reasonable suspicion, Iowa Const. art. I, 8 requires that the stop must end; and (2) consequently, the law enforcement officer that stopped Defendant in this case violated Defendant’s rights under the Iowa Constitution. View "State v. Coleman" on Justia Law

Appellant pleaded guilty to failure to appear for sentencing. Appellant filed a postconviction relief action asserting that his counsel provided ineffective assistance for several reasons. The district court denied relief. Appellant appealed, arguing that counsel was ineffective by allowing Appellant to plead guilty when a factual basis did not exist for the plea. The court of appeals concluded that it could not reach this issue on appeal because the record was insufficient to determine whether a factual basis existed at the time Appellant pleaded guilty. The Supreme Court vacated the decision of the court of appeals and affirmed the district court judgment, holding (1) a factual basis existed in the record for the court to accept Appellant’s plea; and (2) Appellant’s remaining claims were without merit. View "Yocum v. State" on Justia Law

Defendant was on probation after having been convicted of drug offenses related to methamphetamine when his sister and father, concerned that he had relapsed, contacted his probation officer. Probation officers were dispatched to Defendant's residence and, with the father’s consent and without objection from Defendant, entered Defendant’s bedroom. Defendant admitted he had relapsed and used methamphetamine. The State commenced a probation revocation proceeding. Defendant filed a motion to suppress, claiming that the probation officers’ warrantless entry into his bedroom violated article I, section 8 of the Iowa Constitution. The district court denied the motion. The Supreme Court affirmed, holding that assuming, without deciding, that Defendant had a legitimate expectation of privacy in his bedroom, the probation officers’ entry was justified by the special-needs doctrine, and therefore, the entry into Defendant’s room did not violate his rights under article I, section 8 of the Iowa Constitution. View "State v. Brooks" on Justia Law

Defendant was charged with operating while intoxicated, third offense. Defendant filed a motion to suppress evidence obtained after a police officer pulled his patrol car into Defendant’s driveway with its emergency lights flashing, approached Defendant on foot, and directed him to step down from his front porch onto the driveway. Defendant argued that the officer’s conduct amounted to an unlawful seizure. The district court denied the motion to suppress, concluding that no seizure occurred. The court of appeals affirmed. The Supreme Court reversed, holding that Defendant was seized within the meaning of the Fourth Amendment when the officer directed Defendant to step off the front porch and onto the driveway. Remanded. View "State v. White" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The court of appeals reversed, concluding (1) the State violated Appellant’s Sixth Amendment right to counsel by acquiring incriminating evidence through a jailhouse informant when Defendant was represented by counsel, and the error was not harmless; and (2) the trial court’s instructions on aiding and abetting and joint criminal conduct were not supported by substantial evidence. The Supreme Court affirmed in part and vacated in part the court of appeals’ decision and reversed in part the trial court’s judgment, holding that the trial court erred in overruling Defendant’s motion to suppress as to one of the jailhouse informants. View "State v. Marshall" on Justia Law

Defendant was detained at the police station for suspicion of drunk driving but was not yet formally charged when he made a phone call with a lawyer to get advice regarding the implied-consent procedure and his decision whether to refuse a breathalyzer test. The arresting officer was present during Defendant’s phone call, which was allowed under Iowa Code 804.20. Defendant’s lawyer did not arrive in time, and Defendant submitted to the test. Defendant was subsequently charged with operating a motor vehicle while intoxicated. Defendant filed a motion to suppress the test result, arguing that he was entitled to a private phone consultation with counsel before chemical testing was conducted. The district court denied the motion, and Defendant was convicted as charged. The Supreme Court affirmed, holding (1) the right to counsel under the Iowa and United States Constitutions does not attach until formal criminal charges are filed; and (2) Defendant’s right to counsel had not attached at the time Defendant was asked to submit to the chemical breath test, and therefore, Defendant’s constitutional right to counsel was not violated. View "State v. Senn" on Justia Law

Appellant, a high school football player, was charged with possession of a firearm as a felon, carrying a weapon on school grounds, carrying a weapon, and possession of a controlled substance after the school superintendent searched Appellant’s school-issued equipment bag. The superintendent was moving the bag to the floor when he heard a “metallic sound.” Appellant filed a motion to suppress the evidence found in the bag. The district court denied the motion to suppress, concluding that, under New Jersey v. T.L.O., the search was justified at its inception and the scope of the search was reasonable. The Supreme Court affirmed, holding that the search fell within the general parameters of reasonableness as outlined in T.L.O. View "State v. Lindsey" on Justia Law

Defendant was charged with one count of driving while barred and one count of prostitution. Defendant filed a motion to dismiss, asserting that the state failed to try her case within ninety days of filing the trial information. After a hearing, the district court ruled that Defendant waived speedy trial. The trial court subsequently found Defendant guilty. Defendant appealed, arguing that the State failed to bring her to trial within the speedy trial deadline, that she did not waive her speedy trial rights, that there was not good cause for the delay, and that she timely asserted her speedy trial rights. The Supreme Court reversed, holding (1) the State did not meet its burden of showing good cause for the delay; and (2) the State did not meet its burden in showing that Defendant waived her right to a speedy trial. Remanded for dismissal of all charges. View "State v. Taylor" on Justia Law