Justia Iowa Supreme Court Opinion Summaries

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

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