Justia Iowa Supreme Court Opinion Summaries

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

In 2013, the Iowa Board of Medicine passed a rule establishing standards requiring physicians who prescribe or administer abortion-inducing drugs to personally perform a physical examination and to be physically present when the abortion-inducing drug is provided. Planned Parenthood challenged the rule as both improperly enacted and in violation of the Iowa Constitution. The district court denied Planned Parenthood’s claims and upheld the rule addressing each of Planned Parenthood’s challenges. The Supreme Court reversed, holding (1) the Board’s rule violates the controlling “undue burden” test announced by the U.S. Supreme Court as the federal constitutional test; and (2) therefore, the rule violates the Iowa Constitution under the less stringent Iowa constitutional standard advanced by the Board. View "Planned Parenthood of the Heartland, Inc. v. Iowa Bd. of Med." on Justia Law

After a jury trial, Defendant was found guilty of theft in the first degree. Defendant appealed the denial of his motion to suppress the search of his trailer, arguing that there was no probable cause to support the search warrant. Defendant also raised numerous claims of ineffective assistance of trial counsel. The court of appeals reversed and remanded the case for a new trial, concluding that there was no probable cause to support the search warrant. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding (1) the district court properly denied the motion to suppress because the issuing judge had a substantial basis for concluding there was probable cause to support the search warrant; and (2) the record was inadequate to reach the merits of Defendant’s ineffective-assistance-of-counsel claims. View "State v. McNeal" on Justia Law

After a jury trial, Defendant was found guilty of second-degree murder. Defendant appealed, arguing that his conviction should be vacated because of juror misconduct and juror bias and because of assorted errors in the district court’s evidentiary rulings. The court of appeals reversed Defendant’s conviction on the issue of juror bias. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the trial court, holding (1) the evidence does not support a finding of juror misconduct in this case; (2) the district court did not abuse its discretion in finding that a juror was not actually biased when, prior to the verdict, the juror clicked “like” on a Facebook comment by the victim’s stepmother which stated, “Give me strength”; and (3) the district court did not commit prejudicial error in its evidentiary rulings. View "State v. Webster" on Justia Law

Employers filed a petition against the City claiming that a city ordinance prohibiting discrimination by all employers violated their constitutional rights. The Supreme Court held that the antidiscrimination ordinance exceeded the City’s home rule authority and remanded. On remand, Employers argued that the City was liable under 42 U.S.C. 1983 as a matter of law for attempting to enforce the antidiscrimination ordinance in violation of Employers’ rights of freedom of speech and freedom of association and their federal constitutional rights of due process and equal protection. The district court granted summary judgment for the City. The Supreme Court affirmed, holding (1) the ordinance did not violate Employers’ federal constitutional rights; and (2) the district court did not abuse its discretion when it allowed Employers to amend their petition. View "Baker v. City of Iowa City" on Justia Law