Justia Iowa Supreme Court Opinion Summaries

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

Appellant was a passenger in an out-of-state vehicle that had been pulled over for traffic violations. The state trooper decided to detain the drive and Appellant while a narcotics dog was called in. The narcotics dog alerted on the vehicle. A subsequent search of the car revealed small amounts of marijuana, $33,100 in cash, and evidence of marijuana dealing. In a criminal proceeding, Appellant was ultimately acquitted of marijuana possession. Meanwhile, in the forfeiture proceeding for the $33,100, Appellant alleged he was the owner of the $33,100. Appellant filed a motion to suppress, arguing that the money had been seized in violation of his constitutional rights. The district court denied Appellant’s motion to suppress based on res judicata from Appellant’s criminal proceeding, concluding that the denial of Appellant’s motion to suppress in his criminal case had preclusive effect in the forfeiture case. The court then ordered the money forfeited. The court of appeals affirmed. The Supreme Court reversed, holding (1) res judicata did not apply in this case because Appellant was acquitted in the criminal case; and (2) the trooper prolonged the stop in violation of the Fourth Amendment beyond what was necessary to address the observed traffic violations. Remanded. View "In re Property Seized from Robert Pardee" on Justia Law

Upon stopping Defendant for an expired license plate, a police officer smelled marijuana and confiscated a marijuana blunt from Defendant. After arresting Defendant for the possession of marijuana the police searched the passenger compartment where a locked safe was held. An officer opened the safe without a search warrant. Based upon the evidence of the search, Defendant was charged with possession of marijuana with intent to deliver, failure to affix a drug tax stamp, and knowingly transporting a revolver in a vehicle. The district court denied Defendant’s motion to suppress the evidence obtained from a search of the locked container and convicted him of the charges. The Supreme Court reversed, holding that the warrantless search of the safe was not a valid search incident to Defendant’s arrest because Defendant could not access anything inside the vehicle or the locked safe when the search occurred. View "State v. Gaskins" on Justia Law

Defendant was convicted of murder in the second degree for the death of her newborn son (Baby Tyler). The Supreme Court affirmed in part and reversed in part, holding (1) the district court abused its discretion in allowing the medical examiner to testify to the cause and manner of Baby Tyler’s death and in admitting the unredacted autopsy report into evidence; (2) the district court erred in denying Defendant’s motion to suppress evidence obtained by the police during the search of Defendant’s hotel room on the basis that Defendant had no reasonable expectation of privacy in the room because she obtained it for the purpose of committing a crime; and (3) the district court did not err in denying Defendant’s motion to suppress statements she made to police. Remanded for a new trial. View "State v. Tyler" on Justia Law

After a jury trial in 1988, Defendant was convicted of first-degree murder. Defendant was sentenced to life imprisonment without parole (LWOP), as required by Iowa law at that time. At the time she committed the crime, Defendant was seventeen years old. After Miller v. Alabama was decided, the Iowa Governor commuted Defendant’s LWOP sentence, along with the sentences of several other juvenile offenders, to life imprisonment with the possibility of parole after sixty years in prison. After the Iowa Supreme Court decided State v. Ragland, the Court summarily vacated Defendant’s sentence and remanded the case for an individualized sentencing hearing. After a hearing, the district court resentenced Defendant to a definite term of twenty-five years with credit for time served, thereby discharging her from prison immediately and releasing her to correctional supervision for no more than two years. The court also imposed an alternative sentence of life in prison with the possibility of parole after twenty-five years. The Supreme Court vacated the sentence, holding that the district court (1) lacked authority to impose a determinate sentence of twenty-five years, but (2) did have authority to impose a sentence of life in prison with eligibility for parole. View "State v. Louisell" on Justia Law

Defendant was seventeen years old when he committed first-degree murder. Defendant was sentenced to life without parole, as required by Iowa law. Defendant later filed a motion to correct an illegal sentence. Before the trial court heard the motion and shortly after Miller v. Alabama was decided, Iowa’s Governor commuted the sentences of all juveniles previously convicted of first-degree murder to a life sentence with the possibility of parole after sixty years. The trial court then granted Defendant’s motion to the extent his sentence was imposed without “individualized consideration of the circumstances.” The court upheld Defendant’s sentence of life with parole eligibility after sixty years as commuted by the Governor. The Supreme Court vacated the sentence, holding (1) a court must use certain factors when it sentences a juvenile offender for first-degree murder; and (2) because the district court did not have the benefit of this decision when it sentenced Defendant, this case must be remanded for resentencing. View "State v. Seats" on Justia Law

After Defendant was released on parole, Defendant’s parole officer made a home visit to check on Defendant and conducted a search of Defendant’s bedroom. The search uncovered evidence used to prosecute and convict Defendant of the crime of possession of a controlled substance as a habitual offender. Defendant appealed the denial of his motion to suppress, arguing that the evidence was obtained in violation of the State Constitution. The Supreme Court adopted a special-needs exception that authorizes parole officers to search the home of a parolee without a warrant for purposes of parole supervision and then affirmed, holding that, under the special-needs exception to allow narrowly tailored parolee searches, Defendant’s constitutional rights were not violated in this case. View "State v. King" on Justia Law