Justia Iowa Supreme Court Opinion Summaries

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

Defendant pleaded guilty to attempted murder and was sentenced to twenty-five years in prison. Defendant appealed, claiming his counsel provided ineffective assistance because counsel permitted him to plead guilty without an established factual basis for each element of the crime. The court of appeals vacated Defendant's conviction and sentence and remanded the case, concluding that the guilty plea colloquy failed to establish a factual basis for the underlying charge. The Supreme Court vacated the court of appeals' decision and affirmed the conviction and sentence of the district court, holding that the minutes of testimony provided an adequate factual basis to support Defendant's guilty plea. View "State v. Finney" on Justia Law

Plaintiff was a construction supply business that entered into a dispute with City over a project upgrading City's wastewater treatment facility. After City excluded Plaintiff from its list of preapproved material suppliers, Plaintiff filed this action seeking a declaration that City's preapproval process violated Iowa's public construction bidding statute and constitutional guarantees of equal protection and due process. In addition, Plaintiff sought relief under the Open Records Act, claiming that City's significant delay in responding to Plaintiff's open records request violated the Open Records Act. The district court rejected each of Plaintiff's claims. The Supreme Court (1) affirmed the judgment dismissing Plaintiff's public biding and constitutional claims, as (i) Plaintiff lacked standing to challenge City's preapproval process, and (ii) Plaintiff's constitutional claims failed on the merits; and (2) reversed the district court's ruling denying Plaintiff relief under the open records law, as City's substantial and inadequately explained delay in responding to Plaintiff's open records request violated the law. View "Horsfield Materials, Inc. v. City of Dyersville" on Justia Law

In an underlying termination of parental rights proceeding, the juvenile court concluded that while Mother, who was indigent, did not qualify for appointed counsel under Iowa Code 600A.6A, payment of the attorney’s fees at public expense was constitutionally required. The court subsequently appointed an attorney to represent Mother in the proceeding, and ultimately, Mother’s parental rights were terminated. The juvenile court ordered the State Public Defender to pay for the court-appointed counsel, but the Defender denied payment on the ground that the fees did not qualify for payment from the indigent defense fund. The appointed attorney sought judicial review, and the juvenile court subsequently ordered the Iowa Department of Management to pay the fees. The Defender and Department appealed the juvenile court’s appointment of counsel at public expense. The Supreme Court treated the appeal as a petition for an original writ of certiorari, which it granted as to the Department. The Court then annulled the writ, concluding that the juvenile court correctly appointed counsel at public expense to represent Mother in the contested termination proceeding under chapter 600A. View "Crowell v. State Pub. Defender" on Justia Law