Justia Iowa Supreme Court Opinion Summaries

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

A police officer stopped Defendant’s vehicle based upon a suspicion that Defendant was operating a vehicle without proper illumination. Defendant was subsequently arrested for, and charged with, driving while intoxicated. Defendant filed a motion to suppress, alleging that the arresting officer lacked reasonable suspicion to make a traffic stop and that, after his arrest, his rights under Iowa Code 804.20 were violated because the officer failed properly to inform him of the purpose of a phone call. The district court denied the motion. A jury subsequently found Defendant guilty of operating a motor vehicle while intoxicated. The Supreme Court affirmed, holding (1) the deputy had a reasonable suspicion that there was no working license plate light on Defendant’s vehicle; and (2) law enforcement officers are not required to explain that a purpose of the phone call is to obtain advice regarding whether to submit to a chemical test. View "State v. Lyon" on Justia Law

At issue in this appeal was the constitutionality of the statutory framework under which Iowa taxes the delivery of natural gas at variable tax rates depending on volume and the taxpayer’s geographic location within the state. Plaintiff filed with the Iowa Department of Revenue a claim for a refund of replacement tax Plaintiff paid for certain tax years, asserting that the replacement tax in Iowa Code 437A.5(2) violates the federal Equal Protection Clause, Iowa Const. art. I, 6, and the dormant Commerce Clause because it is based on the natural gas competitive service area in which a taxpayer is located. An administrative law judge denied Plaintiff’s refund claims and rejected the constitutional challenges to the replacement tax. The district court also denied each of Plaintiff’s constitutional challenges. The Supreme Court affirmed, holding (1) a rational basis exists for the variable excise tax imposed on the delivery of natural gas under section 437A.5, and therefore, Plaintiff failed to establish a violation of the Fourteenth Amendment or Iowa Const. art. I, 6; and (2) the natural gas delivery tax framework does not violate the dormant Commerce Clause. View "LSCP, LLLP v. Kay-Decker" on Justia Law

Defendant was charged with theft in the third degree based on her current crime and two prior theft convictions. Defendant moved to strike her 2003 conviction of theft in the third degree as a basis to support the charge of third-degree theft, asserting that the conviction was constitutionally infirm because she was not represented by counsel when she pled guilty and served a term of incarceration. In fact, Defendant was held in jail for one day prior to her initial appearance and then, upon pleading guilty, was sentenced to one day in jail, with credit for time served. The district court denied the motion, concluding that Defendant’s situation was not one in which she faced the possibility of imprisonment requiring the appointment of counsel. Defendant was subsequently found guilty of theft in the third degree. The Supreme Court reversed, holding (1) under the right to counsel provision under Iowa Const. art. I, 10, a misdemeanor defendant has a right to counsel when the defendant faces the possibility of imprisonment; and (2) because Defendant was not provided the assistance of counsel and the State stipulated there was not a valid waiver, the 2003 misdemeanor conviction could not be used as a predicate offense to enhance a later punishment. Remanded. View "State v. Young" on Justia Law