Justia Iowa Supreme Court Opinion Summaries

Plaintiffs initiated suit in federal district court against Defendant, their former employer, alleging employment discrimination. Plaintiff’s complaint included claims that Defendant had violated Iowa Code 216.6A, Iowa’s equal pay law. Defendants moved for partial summary judgment, arguing that Plaintiffs’ claims under section 216.6A should be dismissed to the extent that they arose before the effective date of that provision. After hearing oral arguments, the district court certified two questions to the Supreme Court to clarify Iowa law with respect to wage discrimination claims. The Supreme Court answered (1) section 216.6A applies on a prospective basis only to conduct occurring after its effective date; and (2) plaintiffs may recover damages for wage discrimination under the preexisting law, Iowa Code 216.6, and recoverable damages for loss of income are based on discriminatory wage payments that occurred within 300 days before the plaintiff filed a complaint with the civil rights commission. View "Dindinger v. AllSteel, Inc." on Justia Law

After a jury trial, Defendant was convicted of two counts of sexual abuse in the second degree and one count of lascivious acts with a child. Defendant appealed, arguing, among other things, that trial counsel was ineffective in failing to object to a lascivious-acts jury instruction that he claimed was not supported by sufficient evidence. The court of appeals affirmed. The Supreme Court addressed only Defendant’s claim regarding counsel’s response to the lascivious-acts instruction and let the court of appeals’ affirmance on the remaining issues stand as the final decision of the Court. The Supreme Court affirmed, holding that Defendant failed to establish that he suffered prejudice as a result of counsel’s failure to object to the lascivious-acts instruction, and therefore, his ineffective-assistance-of-counsel claim must fail. View "State v. Thorndike" on Justia Law

In 2011, the City of Sioux City enacted an automatic traffic enforcement (ATE) ordinance. In 2012, a vehicle registered to Appellant was detected by ATE equipment traveling at an excessive speed. As a result, the City issued a citation to Appellant. Appellant moved to dismiss the citation on constitutional grounds, claiming enforcement of the ordinance violated the due process clauses of the Iowa and U.S. Constitutions, the inalienable rights clause of the Iowa Constitution, and the Iowa municipal home rule amendment. The magistrate entered an order finding Defendant liable for the violation. The district court affirmed. The Supreme Court affirmed, holding that the ATE ordinance is not unconstitutional. View "City of Sioux City v. Jacobsma" on Justia Law

After a jury trial, Defendant was convicted of domestic abuse assault causing bodily injury. The Supreme Court vacated the judgment of the court of appeals and affirmed, holding (1) trial counsel was not ineffective in failing to object on Confrontation Clause grounds to the testimony of a law enforcement officer regarding the complaining witness’s out-of-court statements; and (2) the record was insufficient to determine whether trial counsel should have objected to and move to strike as hearsay the officer’s unsolicited testimony regarding another witness’s out-of-court statement. View "State v. Tomkins" on Justia Law

After a jury trial, Defendant was found guilty of first-degree arson. On appeal, Defendant requested a judgment of acquittal or, alternatively, a new trial, claiming that the evidence was insufficient to support the conviction and that his pretrial counsel operated under a conflict of interest due to his representation of a prosecution witness. The court of appeals reversed, holding that Defendant’s pretrial counsel’s conflict of interest required reversal of Defendant’s conviction. The Supreme Court vacated the decision of the court of appeals and affirmed the district court’s judgment of conviction and sentence, holding that, where the district court replaced the conflicted defense attorney with a conflict-free attorney more than three months before trial, and there was no showing that the previous conflict had ongoing adverse effects on the representation, a new trial was not required. View "State v. Vaughan" on Justia Law

Plaintiff, individually, and on behalf of her children, sued two physicians for medical malpractice. During the ensuing trial, one of the jurors fainted while she was sitting in her chair in the jury box. One of the defendant physicians immediately rose to assist the juror, after which the juror recovered and was excused. Plaintiffs moved for a mistrial, which the trial court denied. The jury subsequently returned verdicts for the physicians. The court of appeals reversed and ordered a new trial as to both physicians. The physician who did not help the ailing juror sought further review. The Supreme Court reversed the court of appeals as to the appellant, holding that the district court did not abuse its discretion when it allowed the jury verdict to stand as to the physician who had not rendered medical assistance because nothing in that physician’s behavior during the incident could have “engendered any particular good will in her favor.” Remanded. View "Jack v. Booth" on Justia Law

After a jury trial, Defendant was convicted of possession of a controlled substance and introduction of a controlled substance into a detention facility. Defendant appealed, arguing that the district court entered an illegal sentence because the offenses of introduction and possession merged into a single offense by operation of Iowa’s merger statute. The court of appeals concluded that the offenses did not merge. The Supreme Court affirmed, holding that neither the merger statute nor double jeopardy principles formed a basis for reversing Defendant’s possession conviction and that the crimes may be simultaneously charged in one criminal prosecution. View "State v. Stewart" on Justia Law

Defendant was charged with operating while intoxicated, first offense. Defendant moved to suppress the evidence against her, arguing that the stop of her vehicle was made without probable cause or reasonable suspicion and that the implied consent statute was violated when the transporting deputy failed to administer a blood or urine test instead of insisting on a breath test after acquiring reasonable grounds to believe Defendant was impaired by a prescription drug. The district court overruled the motions to suppress and found Defendant guilty of the charge. The Supreme Court affirmed, holding (1) the investigatory stop of the vehicle did not violate the Fourth Amendment to the United States Constitution or Iowa Const. art. I, VIII; and (2) the legislature did not intend for the implied consent law to mandate a blood or urine test under the circumstances of this case but only intended to impose the implied consent penalty of license revocation for drivers suspected of driving under the influence of drugs other than alcohol who refuse to submit to a urine or blood test when requested by a law enforcement officer. View "State v. McIver" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree and other criminal offenses. The Supreme Court affirmed, holding (1) Defendant failed to preserve for appeal his argument that an instruction given to the jury that it may not consider a lesser offense unless it unanimously found Defendant not guilty of the greater offense was a misstatement of the law; (2) certain instructions concerning the various inferences and conclusions the jury was permitted to draw did not constitute reversible error; and (3) Defendant was not denied effective assistance of counsel for failing to argue that the contested instructions were improper. View "State v. Ambrose" on Justia Law

Defendant was in custody of a residential facility commonly referred to as a halfway house when he was charged with knowingly possessing marijuana on the grounds of a facility “under the management of the department of corrections” pursuant to Iowa Code 719.7(3)(c). After a jury trial, Defendant was convicted. Defendant appealed, arguing that his trial counsel provided ineffective assistance for specifically failing to assert that the evidence was insufficient to establish that the residential facility was an institution under the management of the Department of Corrections (Department). The Supreme Court reversed, holding that defense counsel was ineffective as a result of his failure to assert that there was insufficient evidence to show the residential facility was an institution under the management of the Department, and Defendant was prejudiced by the failure to his counsel to assert the claim. View "State v. Halverson" on Justia Law