Justia Iowa Supreme Court Opinion Summaries

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

Defendant was charged with four counts of unintentionally causing serious injury by intoxicated use of a motor vehicle. Before trial, the State moved to allow three out-of-state victims of the car accident and three lab analysts employed by the State to testify remotely via two-way videoconferencing technology rather than physically appearing in court. After a hearing, the district court granted the State’s motion for distance testimony. Defendant appealed, arguing that the trial court’s decision to permit the State’s witnesses to testify remotely violated his Sixth Amendment right to be confronted with the witnesses against him. The Supreme Court reversed, holding (1) before permitting a witness to testify via two-way videoconference, a court must make a case-specific determination that the denial of the defendant’s confrontation right is necessary to further an important public interest; and (2) applying this standard to the instant case, the district court erred in allowing the videoconference testimony. View "State v. Rogerson" on Justia Law

The State charged Defendant, a probationer, with burglary and theft after police officers conducted a warrantless search of Defendant’s home. Defendant filed a motion to suppress contending that the search warrant was invalid because it inaccurately described the house to be searched and because an alteration of the warrant based upon a verbal conversation with the issuing judge violated the statutory requirement that search warrant applications be in writing. The district court overruled the motion to suppress, concluding that the search warrant was inadequate but that the warrant was valid because the search was within the contemplation of the probation agreement. The court of appeals affirmed, concluding that the search of the probationer based upon reasonable suspicion of criminal activity and based upon the limited scope of the search was valid under the search and seizure provision of Iowa Const. art I, 8. The Supreme Court reversed, holding that, in accordance with State v. Cullison, the search of Defendant’s home by general law enforcement authorities was unlawful under the Iowa Constitution because the search was based on an invalid warrant. View "State v. Short" on Justia Law

When he was seventeen years old, Appellant committed the crime of first-degree robbery. Appellant was sentenced to a term of imprisonment not to exceed twenty-five years. Appellant was sentenced under a statute that required him to serve at least seventy percent of his sentence before he was eligible for parole. Appellant appealed, arguing that his sentence constituted cruel and unusual punishment. The Supreme Court vacated the sentence and remanded to the district court for resentencing, holding that, for the reasons express in State v. Lyle, filed on this same date, the mandatory sentence violated the prohibition against cruel and unusual punishment under the Iowa Constitution. View "State v. Taylor" on Justia Law

Appellant was a seventeen-year-old high school student when he took a small plastic bag containing marijuana from a fellow student outside the high school. After a jury trial, Appellant was convicted of robbery in the second degree. Appellant was prosecuted as an adult and was sentenced under a statute that required the imposition of a mandatory seven-year minimum sentence of imprisonment. Appellant appealed, arguing that the mandatory minimum was unconstitutional as applied to him. During the pendency of the appeal, the United States decided Miller v. Alabama. The court of appeals affirmed the sentence. The Supreme Court granted review to consider whether Appellant’s sentence was constitutional in light of the cases the Court handed down subsequent to Miller. The Supreme Court vacated the sentence and remanded for resentencing, holding that a statute mandating a sentence of incarceration in a prison for juvenile offenders with no opportunity for parole until a minimum period of time has been served is unconstitutional under the Iowa Constitution. View "State v. Lyle" on Justia Law

Plaintiffs, fourteen African-Americans, brought a class action suit against the State, including thirty-seven different executive branch departments, under the Federal Civil Rights Act and the Iowa Civil Rights Act. In their complaint, Plaintiffs alleged that the State unlawfully discriminates against African Americans in employment. The district court entered judgment in favor of the State. The Supreme Court affirmed, holding that Plaintiffs did not meet their burden of establishing that the underlying documents did not provide sufficient information to allow employment practices to be separated for meaningful statistical analysis, and therefore, Defendant was entitled to summary judgment under the Iowa Civil Rights Act.View "Pippen v. State" on Justia Law