Justia Iowa Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of voluntary manslaughter and five counts of intimidation with a dangerous weapon with intent. The Supreme Court vacated Defendant’s convictions on three counts of intimidation with a dangerous weapon with intent and affirmed his remaining convictions, holding (1) trial counsel was ineffective for failing to move for a judgment of acquittal after the verdict on the intimidation counts because the evidence did not support the verdicts that Defendant committed five separate and distinct acts of intimidation with a dangerous weapon with intent; (2) however, substantial evidence supported two separate and distinct crimes of intimidation with a dangerous weapon with intent; (3) the record was inadequate to decide Defendant’s separate allegation of ineffective assistance of counsel; and (4) the district court did not abuse its discretion in failing to admit certain photographs into evidence. Remanded. View "State v. Ross" on Justia Law

Plaintiff was terminated from his employment as dean of students and vice president of student services at the University of Iowa by the University's president, Sally Mason, after a report from the Stolar Partnership (Stolar), a law firm retained by the Board of Regents (Regents) to investigate the University's response to a sexual assault of a student athlete by other student athletes, came out highly critical of Plaintiff. Plaintiff sued the University, Mason, the Regents, and Stolar for wrongful termination and related causes of action. The district court granted summary judgment for Defendants on all claims. The Supreme Court affirmed, holding that the district court did not err (1) in denying Plaintiff's motion to compel discovery of written communications between Stolar and the Regents based on its finding that the attorney-client privilege protected the communications from disclosure; and (2) in granting summary judgment to Defendants on Plaintiff's various claims.View "Jones v. Univ. of Iowa" on Justia Law

After a jury trial, Defendant was convicted of six counts of child endangerment and sentenced to fifty years in prison. The victim was Defendant's seven-week-old son. The baby suffered fifteen rib fractures, a broken arm, and a permanent brain injury over a three-week period. The victim's mother (Mother) pled guilty to child endangerment. On appeal, the Supreme Court (1) vacated Defendant's convictions as to two counts for the baby's broken ribs, holding that the evidence was insufficient to sustain the convictions; (2) reversed the trial court's denial of Defendant's motion for an in camera review of Mother's mental health records under Iowa Code 622.10(4), a statute the Court upheld as constitutional; and (3) otherwise affirmed. View "State v. Neiderbach" on Justia Law

After a jury trial, Defendant was convicted of the second-degree murder of his live-in girlfriend. The Supreme Court affirmed, holding that the district court did not reversibly err by (1) failing to submit an instruction on the lesser included offense of voluntary manslaughter, as the evidence of provocation was insufficient to support admission; (2) excluding hearsay evidence relevant to Defendant's diminished-capacity defense based on his posttraumatic stress disorder, as Defendant failed to lay a foundation supporting any exception to the hearsay rule; (3) declining to obtain and review the victim's mental health records for exculpatory information; and (4) denying Defendant's motion for a new trial. View "State v. Thompson" on Justia Law

Following a jury trial, Defendant, a juvenile, was convicted of first-degree murder and mandatorily sentenced to life without parole. Defendant subsequently pursued numerous postconviction relief actions, including an application to correct his sentence. After the Supreme Court remanded the case to the district court to consider the constitutionality of Defendant's sentence, the U.S. Supreme Court decided Miller v. Alabama, which held that the constitution prohibited a sentencing scheme mandating life in prison without possibility of parole for juvenile offenders. Before Defendant's hearing, the Governor commuted Defendant's sentence to life with no possibility for parole for sixty years. At the hearing before the district court, Defendant argued he should still be resentenced under Miller. The district court (1) concluded that the Governor exceeded his authority by commuting Defendant's sentence because the commutation circumvented the individualized sentencing required under Miller, and (2) resentenced Defendant to life in prison with the possibility of parole after twenty-five years. The Supreme Court affirmed, holding (1) Defendant's commuted sentence still amounted to cruel and unusual punishment; and (2) consequently, the district court properly resentenced Defendant in light of Miller.View "State v. Ragland" on Justia Law

After a jury trial, seventeen-year-old Defendant was convicted of two counts of first-degree robbery and two counts of first-degree burglary. The district court imposed a fifty-year sentence, of which Defendant was required to serve thirty-five years, at which point she would become eligible for parole. The Supreme Court vacated Defendant's sentence, holding (1) Defendant's sentence of a minimum of thirty-five years without the possibility of parole for the crimes involved in this case violated the core teachings of Miller v. Alabama; and (2) an individualized sentencing hearing was required in this case. Remanded. View "State v. Pearson" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to second-degree murder and first-degree robbery. Defendant was sixteen years old at the time he committed the offenses. The district court imposed a seventy-five-year aggregate sentence, of which Defendant was required to serve 52.5 years. Defendant's alleged actions took place before the Supreme Court's decision in Miller v. Alabama. On appeal, the Supreme Court affirmed Defendant's convictions but vacated his sentence, holding (1) Defendant's 52.5-year minimum prison term triggered the protections to be afforded under Miller - namely, an individualized sentencing hearing to determine the issue of parole eligibility; and (2) a district court must recognize and apply the core teachings of Roper v. Simmons, Graham v. Florida, and Miller in making sentencing decisions for long prison terms involving juveniles. Remanded.View "State v. Null" on Justia Law

As a condition of her employment, Employee signed an agreement to arbitrate claims with Employer. Employee later filed a complaint with the Iowa Civil Rights Commission (ICRC), alleging that Employer had discriminated against her because of her pregnancy. The ICRC subsequently filed a statement of charges with the Iowa Department of Inspections and Appeals (DIA). Employer filed a motion to dismiss the ICRC’s charges or, in the alternative, compel arbitration. The DIA denied Employer’s motion on the ground that ICRC was not a party to the arbitration agreement and, consequently, not bound by it. On judicial review, the district court remanded instructions for the ICRC to dismiss the matter pending arbitration by the parties, concluding that the Federal Arbitration Act (FAA) preempted state law. The Supreme Court reversed, holding the FAA did not require arbitration of this proceeding because it was brought by an entity that was not bound to arbitrate under generally applicable principles of contract law, where the ICRC was not a party to the agreement and its interest was not derivative of Employee’s. View "Rent-A-Center, Inc. v. Iowa Civil Rights Comm’n" on Justia Law

After a jury trial, Defendant was convicted of kidnapping in the first degree, among other charges. Defendant was a juvenile at the time of the kidnapping. The district court sentenced Defendant to life imprisonment without the possibility of parole for the kidnapping conviction. After the U.S. Supreme Court decided Graham v. Florida, Defendant filed a motion to correct an illegal sentence on the kidnapping conviction, contending that his sentence violated the Eighth Amendment of the U.S. Constitution. The district court agreed that the sentence was unconstitutional and corrected Defendant’s conviction to life in prison with immediate parole eligibility. Defendant appealed, claiming, inter alia, that his sentence was unconstitutional under both the U.S. and the Iowa Constitutions. The court of appeals affirmed Defendant’s conviction and sentence as corrected. The Supreme Court conditionally affirmed, holding that Defendant’s sentence was constitutional under the U.S. Constitution. Because Defendant’s claims that his sentence was illegal under the Iowa Constitution were not fully developed, the Court did not reach those claims. Remanded. View "State v. Hoeck" on Justia Law

Dentist fired his long-time female dental assistant (Employee) at the request of his wife after she discovered Dentist and Employee had been texting. Wife claimed Employee "was a big threat" to the marriage. Employee subsequently brought this action against Dentist, alleging that he discriminated against her on the basis of sex. The district court granted summary judgment for Dentist, concluding that Employee was not fired because of her gender but because she was a threat to Dentist's marriage. The Supreme Court affirmed, holding that Dentist did not engage in unlawful gender discrimination in violation of the Iowa Civil Rights Act when he fired Employee at the request of his wife.View "Nelson v. Knight" on Justia Law