Justia Iowa Supreme Court Opinion Summaries

In 1995, Appellant was convicted of first-degree armed robbery. In 2011, the governor commuted Appellant's sentence. Thereafter, Appellant filed an application for postconviction relief seeking recalculation of his earned time to comply with the governor's commutation of the mandatory minimum portion of his sentence. Specifically, Appellant contended that with the mandatory minimum portion of his sentence removed he was entitled to accumulate earned time at a faster rate than had been available to him under the original sentence, which included a mandatory minimum term of incarceration. If his earned time were calculated at the accelerated rate, Appellant contended he would be entitled to an immediate release. The district court denied his application. The Supreme Court (1) affirmed the district court's determination that the governor's commutation order did not entitle Appellant to an immediate discharge; but (2) reversed the part of the district court's ruling that the commutation had no effect on the rate of Appellant's accumulation of earned time and the resulting tentative discharge, as the legal effect of the governor's commutation order changed the rate at which Appellant could accumulate earned time from the date of the commutation forward. Remanded. View "Lowery v. State" on Justia Law

The district court found Defendant guilty of fraudulent practice in the third degree for possessing 218 packs of cigarettes lacking tax stamps. At issue on appeal was whether "the amount of money or value of property or service involved" in this crime was the amount of the unpaid tax or, rather, the value of the cigarettes. Defendant contended the degree of the crime should be based on the unpaid cigarette tax, which was insufficient to convict her of third-degree fraudulent practice. The district court determined the degree of fraudulent practice was based on the value of the cigarettes, not the amount of the unpaid tax. The court of appeals affirmed. The Supreme Court affirmed, holding that, under Iowa Code 453A.36, the possession of unstamped cigarettes was the fraudulent practice, not the unpaid tax, and therefore, the district court correctly entered judgment against Defendant for third-degree fraudulent practice. View "State v. Messer" on Justia Law

Appellant was convicted of first-degree in murder in 2005. In 2009, Appellant filed an application for postconviction relief alleging his trial was ineffective for (1) failing to raise the defense of temporary insanity or diminished capacity, and (2) failing to adequately support the request for bifurcation of his trial. Appellant also asserted his appellate counsel on direct appeal was ineffective for failing to appeal the trial court's denial of his request for bifurcation. The postconviction court denied Appellant's application. The court of appeals affirmed, finding that the postconviction court did not rule on Appellant's specific claims, and Appellant failed to preserve error by filing a subsequent motion under Iowa R. Civ. P. 1.904. The Supreme Court affirmed the denial of Appellant's application for postconviction relief, holding (1) the postconviction court did rule on Appellant's claims, and the claims were properly preserved for appeal; but (2) Appellant's claims lacked merit. View "Lamasters v. State" on Justia Law

The operator of an establishment offering nude and seminude dance performances sought an injunction restraining a city from enforcing its ordinance regulating nude and seminude dancing. The district court found that state law did not preempt the ordinance and that the ordinance was constitutional. The Supreme Court reversed the judgment of the district court, holding that state law preempts enforcement of the ordinance because the ordinance attempts to regulate nude dancing, and therefore, the ordinance is unenforceable against the establishment. Remanded to the district court with instructions to enter an order enjoining the city from enforcing its ordinance against the establishment. View "Mall Real Estate, LLC v. City of Hamburg" on Justia Law

Defendant was charged with murder in the first degree. Defendant provided notice he would be relying on the defense of insanity to the charge. The jury rejected the insanity defense and found Defendant guilty of first-degree murder. The district court sentenced Defendant to life in prison without the possibility of parole and ordered him to pay restitution for his attorney and expert witness fees. The court of appeals affirmed the conviction and restitution orders. Defendant appealed, claiming (1) the instructions given by the district court did not accurately define insanity, and (2) his own instruction should have been given. The Supreme Court affirmed, holding (1) the instructions given by the district court, when read as a whole, fairly and accurately advised the jury of the legal standard it was to apply to Defendant's insanity defense; and (2) due process under the Iowa Constitution does not require the district court to inform the jury of the consequences of a not-guilty-by-reason-of-insanity verdict under the facts of this case. View "State v. Becker " on Justia Law

Tenant brought claims against her landlord, the City of Dubuque, and a City official (Defendants), asserting that they unlawfully caused her eviction from her apartment. Tenant alleged, among other things, that the conduct of Defendants violated a number of her statutory rights under the Iowa Uniform Residential Landlord and Tenant Act (IURLTA). To the extent the Dubuque ordinance authorized the action of Defendants, Tenant argued the ordinance was preempted by the IURLTA. The district court concluded that Tenant was entitled to the return of her security deposit but denied all other relief. The Supreme Court affirmed in part and reversed in part, holding (1) the ordinance was not preempted by the IURLTA and there was no violation of federal law in this case; (2) the ordinance was not unconstitutionally vague and any procedural due process claim was moot; (3) the landlord violated the IURLTA when he removed the belongings of Tenant from the apartment, and landlord's withholding of Tenant's security deposit was a bad faith violation of IURLTA. Remanded. View "Lewis v. Jaeger" on Justia Law

Following his sentencing to consecutive prison terms totaling thirty-five years, Defendant asked the Supreme Court to review the district court's determinations that the written entry of the verdict was proper, that a fork is a dangerous weapon, and that the State did not commit a Brady violation or fail to disclose newly discovered evidence, among others. The court of appeals affirmed. The Supreme Court affirmed in part and vacated in part the court of appeals, holding (1) the State did not commit a Brady violation; and (2) Iowa R. Crim. P. 2.17(2) requires a trial court to announce the verdict in a recorded proceeding in open court following a bench trial, and the district court in this case erred by not announcing the verdict in a recorded proceeding in open court. The Court found, however, that the district court cured its error and substantially complied with Rule 2.17(2) such that no remand was required. View "State v. Jones" on Justia Law

Defendant Dontay Sanford was convicted for first-degree burglary for entering the car of a victim who later died from injuries received during the encounter. Sanford was sentenced to an indeterminate term in prison not to exceed twenty-five years. Sanford appealed, claiming there was insufficient evidence that the victim's automobile was an "occupied structure," which is one of the elements of burglary. The Supreme Court affirmed the conviction, holding (1) the State produced sufficient evidence that the victim's vehicle, under the facts of this case, was an occupied structure as that term is defined under the burglary statute; and (2) Sanford's pro se claims on appeal failed. View "State v. Sanford" on Justia Law

A juvenile court terminated Father's parental rights to his two children. Father appealed, arguing, among other things, that the juvenile court violated his due process rights when it ordered him to provide a fingernail drug test after his termination trial. The court of appeals reversed, principally on the basis that there was no evidence in the record as to the reliability or the accuracy of the fingernail drug test, and that the record, including the fingernail test, lacked clear and convincing evidence to warrant termination of Father's parental rights. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment and order of the trial court, holding (1) the test did not violate Father's due process rights; (2) the evidence including the fingernail test was sufficient to warrant termination; and (3) termination was in the children's best interests. View "In re A.B." on Justia Law

After the State filed a child in need of assistance (CINA) petition, the juvenile court issued a temporary removal order removing Child from Mother's custody and placing her in foster care. Once the CINA proceeding was dismissed, Mother sued the State and two employees of the Iowa Department of Human Services (DHS) under 42 U.S.C. 1983 and the Iowa Tort Claims Act (ITCA), alleging the DHS social workers wrongfully removed Child from her custody and negligently failed to protect Child from abuse. The district court granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding (1) a social worker is entitled to absolute immunity when the social worker functions in the role of a prosecutor or ordinary witness; (2) a social worker is entitled to qualified immunity when acting in the role of a complaining witness, and for his or her investigatory acts; (3) alleged injured parties cannot maintain an action against a social worker under the ITCA where the alleged parties fail to exhaust the available administrative remedy prior to filing an action in court and where the basis of the complaint is that the social worker engaged in conduct functionally equivalent to misrepresentation or deceit. View "Minor v. State" on Justia Law