Justia Iowa Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of involuntary manslaughter by commission of public offense and child endangerment resulting in death. The trial court merged the sentences for the charges under the one-homicide rule and imposed a mandatory indeterminate fifty-year sentence. The court of appeals affirmed. The Supreme Court affirmed in part and vacated in part the decision of the court of appeals, holding (1) the district court did not err in denying Defendant’s motion to suppress; but (2) trial counsel was ineffective for failing to move for a judgment of acquittal on the child endangerment conviction under the theory that Defendant used unreasonable force that resulted in bodily injuries to the victim. Remanded for a new trial. View "State v. Schlitter" on Justia Law

Defendant was charged with two counts of robbery in the second degree. Defendant filed a motion to suppress, arguing that the warrantless search of his closed backpack by an officer who relied on a third party’s consent in conducting the search was unreasonable. Specifically, Defendant asserted that the third party had neither actual authority nor apparent authority to consent to the search of his backpack. The district court denied the motion to suppress and found Defendant guilty of the charged crimes. The Court of Appeals affirmed, concluding that Defendant had apparent authority, but not actual authority, to consent to the search of the backpack. The Supreme Court vacated the decision of the court of appeals, reversed the judgment of the district court, and remanded for a new trial, holding that the warrantless search of Defendant’s backpack violated his Fourth Amendment rights because the third party lacked apparent authority to consent to the search. View "State v. Jackson" on Justia Law

Defendant pled not guilty to the charge of delivering methamphetamine. During jury selection, the prosecutor posed hypothetical questions approximating the facts of the case, intimated the State possessed additional evidence supporting guilt but could only present some of it, and implied that the State only prosecutes guilty people. The jury later returned a verdict finding Defendant guilty. Defendant filed a motion in arrest of judgment and motion for new trial. The trial court denied the motion, concluding that the State’s comments and questions were not so inflammatory as to deny Defendant a fair trial. The court of appeals concluded that the prosecutor’s questions ventured into a gray area but concluded that the remarks did not cause juror bias or make the trial unfair. The Supreme Court affirmed, holding (1) of the four lines of voir dire inquiry challenged by objection and preserved for appellate review, two were permissible; and (2) the district court mitigated any prejudice resulting from the two lines of questionable voir dire inquiry, the court’s remediate efforts were adequate under the circumstances presented here. View "State v. Martin" on Justia Law

After a jury trial, Defendant was convicted of three counts of delivery of a controlled substance. The court of appeals reversed, concluding that defendant’s right to a fair trial by an impartial jury was violated due to certain statements a prospective juror made during voir dire. The Supreme Court vacated the decision of the court of appeals and affirmed in part and reversed in part the judgment of the district court, holding (1) the district court did not deny Defendant a fair trial by an impartial jury because the statements the prospective juror made during voir dire were not so prejudicial as to warrant a presumption they tainted at least one member of the jury panel; (2) the district court did not abuse its discretion by declining to holding a hearing to permit defense counsel to show cause for missing an extended discovery and deposition deadline; (3) the record was inadequate to assess whether prejudice resulted from defense counsel’s breach of an essential duty, and Defendant may bring his ineffective assistance claim in a future postconviction relief action; and (4) the district court applied the incorrect standard in denying Defendant’s motion for new trial on the ground the verdicts were contrary to the weight of the evidence. Remanded. View "State v. Ary" on Justia Law

After a jury trial, Defendant was convicted of three counts of delivery of a controlled substance. The court of appeals reversed, concluding that defendant’s right to a fair trial by an impartial jury was violated due to certain statements a prospective juror made during voir dire. The Supreme Court vacated the decision of the court of appeals and affirmed in part and reversed in part the judgment of the district court, holding (1) the district court did not deny Defendant a fair trial by an impartial jury because the statements the prospective juror made during voir dire were not so prejudicial as to warrant a presumption they tainted at least one member of the jury panel; (2) the district court did not abuse its discretion by declining to holding a hearing to permit defense counsel to show cause for missing an extended discovery and deposition deadline; (3) the record was inadequate to assess whether prejudice resulted from defense counsel’s breach of an essential duty, and Defendant may bring his ineffective assistance claim in a future postconviction relief action; and (4) the district court applied the incorrect standard in denying Defendant’s motion for new trial on the ground the verdicts were contrary to the weight of the evidence. Remanded. View "State v. Ary" on Justia Law

The juvenile court adjudicated J.C. a delinquent child after finding beyond a reasonable doubt that J.C. committed assault with intent to commit sexual abuse. The court of appeals affirmed. At issue before the Supreme Court was whether the juvenile court violated J.C.’s constitutional right to confrontation by admitting the out-of-court statements made by a four-year-old victim to a physician during a medical assessment and to a forensic interviewer. The Supreme Court affirmed, holding (1) admission of the physician’s testimony and report did not violate J.C.’s confrontation rights under either the Sixth Amendment or the Iowa Constitution; and (2) any error in admission of the forensic interviewer’s testimony was harmless beyond a reasonable doubt. View "In re J.C." on Justia Law

The juvenile court adjudicated J.C. a delinquent child after finding beyond a reasonable doubt that J.C. committed assault with intent to commit sexual abuse. The court of appeals affirmed. At issue before the Supreme Court was whether the juvenile court violated J.C.’s constitutional right to confrontation by admitting the out-of-court statements made by a four-year-old victim to a physician during a medical assessment and to a forensic interviewer. The Supreme Court affirmed, holding (1) admission of the physician’s testimony and report did not violate J.C.’s confrontation rights under either the Sixth Amendment or the Iowa Constitution; and (2) any error in admission of the forensic interviewer’s testimony was harmless beyond a reasonable doubt. View "In re J.C." on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The trial court instructed the jury on both the premeditation and felony-murder alternatives of first-degree murder, with the underlying predicate felony being terrorism. In 2006, the Supreme Court decided State v. Heemstra, which was not given retroactive effect. If Heemstra had been controlling at the time of Defendant’s conviction, terrorism could not have been used as the predicate felony and the felony-murder instruction could not have been given as a theory to convict Defendant. Defendant later filed this second application for postconviction relief, arguing that his conviction should be vacated and a new trial ordered because the nonretroactive application of Heemstra violates constitutional due process, separation of powers, and equal protection guarantees. Defendant also argued for the first time on appeal that his postconviction counsel were ineffective. The Supreme Court affirmed, holding (1) the nonretroactivity of the rule set forth in Heemstra does not violate the due process, separation of powers, or equal protection clauses of the Iowa Constitution or the equal protection clause of the United States Constitution; and (2) Defendant’s postconviction counsel provided effective assistance. View "Nguyen v. State" on Justia Law

Defendant was approached by law enforcement officers while walking on the side of the road at 1:10 a.m. The officers asked Defendant if he would consent to a search of his person, and Defendant consented to a search. Defendant was subsequently charged with possessing methamphetamine. Defendant moved to suppress the evidence, arguing that the warrantless search violated the Federal and State Constitutions. The district court denied the motion, concluding that Defendant voluntarily consented to the search. On appeal, Defendant argued that the search violated Iowa Const. art. I, section 8, which requires police to “advise an individual of his or her right to decline to consent to a search.” The Supreme Court affirmed, holding (1) Defendant’s article I, section 8 argument was not preserved for appellate review; and (2) because the totality of the circumstances indicated that Defendant voluntarily consented to the search, the search was valid under the Fourth Amendment. View "State v. Prusha" on Justia Law

Plaintiff, who was employed as an engineer and paramedic for the City of Clinton fire department, requested light-duty assignments when she became pregnant. The fire chief denied Plaintiff’s request, determining that she was not entitled to light duty under the city administrative policy because she did not have a disabling injury that occurred on the job. When Plaintiff’s pregnancy had advanced, she took a leave of absence by using accrued vacation and sick leave time. Once she exhausted the vacation and sick leave, her leave of absence was unpaid. After Plaintiff gave birth, she brought a lawsuit against the City of Clinton and three of its employees, alleging pregnancy discrimination under Iowa Code 216.6(2) and violations of her equal protection and due process rights under the Iowa Constitution. The district court granted summary judgment in favor of Defendants. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) the Court’s test for the evaluation of pregnancy discrimination claims is hereby adapted in this opinion; and (2) the material facts of this case do not support equal protection and due process claims under the Iowa Constitution. Remanded for consideration of the statutory civil rights claim under the new standard. View "McQuistion v. City of Clinton" on Justia Law