Justia Iowa Supreme Court Opinion Summaries

Jose Aguilera was convicted of second-degree murder. In his second application for postconviction relief, Aguilera contended that he was denied due process when the prosecution failed to turn over an Iowa Division of Criminal Investigation file containing several witness statements prior to Aguilera's initial trial. The district court found the material was suppressed and that it was favorable but that it was not material to the issue of guilt and dismissed the application. The court of appeals affirmed. The Supreme Court vacated the court of appeals and reversed the district court, holding that because the suppressed, favorable statements that were not turned over by the State had a reasonable probability of impacting the outcome of the trial, a Brady violation occurred, and Aguilera's due process rights were violated. Remanded. View "Aguilera v. State" on Justia Law

Matthew Elliott was found guilty by a jury of willful injury causing serious injury and child endangerment resulting in death. The court of appeals affirmed. At issue on appeal was whether the district court erred in allowing hearsay testimony from a detective when it allowed the detective to testify about a certain interview. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the district court, holding that the disputed testimony was hearsay, and the error was not harmless because the improper admission of the hearsay evidence was prejudicial to Elliott's substantive rights. Remanded for a new trial. View "State v. Elliott" on Justia Law

Stevie Harrington was sentenced to forty years incarceration after he pled guilty to and was convicted of several drug-related offenses. His sentence included a mandatory sentence enhancement for being in the immediate possession of a firearm. The court of appeals remanded for resentencing, concluding that there was insufficient evidence to support the sentencing enhancement and the district court had relief on improper factors for imposing sentence. On resentencing, the district court sentenced Harrington to a total of thirty years. The sentences included two sentence enhancements that the district court did not apply in Harrington's original sentence. Harrington appealed, contending that, although his overall sentence decreased, because the district court applied the new sentencing enhancements, he was entitled to a presumption of judicial vindictiveness under North Carolina v. Pearce. The court of appeals affirmed. The Supreme Court affirmed, holding that because Harrington received a shorter overall sentence on resentencing for his convictions, the presumption of judicial vindictiveness did not apply. View "State v. Harrington" on Justia Law

Randall Pals' vehicle was searched during a traffic stop to investigate an ongoing minor infraction of a municipal ordinance. The police officer discovered marijuana. Pals moved to suppress the evidence, challenging the legality of the traffic stop and search. The district court denied the motion, and Pals was convicted of possession of a controlled substance. The court of appeals affirmed. The Supreme Court vacated the court of appeals and reversed the district court, holding that the district court erred by refusing to grant Pals' suppression motion where (1) the police officer had probable cause to believe that Pals was committing an ongoing civil offense, and therefore, the initial traffic stop was legal; but (2) pursuant to an application of the Iowa version of the U.S. Supreme Court's Schneckloth v. Bustamonte totality of the circumstances test, Pals' consent to search his vehicle was not voluntarily under the Iowa Constitution. Remanded. View "State v. Pals" on Justia Law

Homeowners filed suit against Contractor, asserting claims for defamation and illegal collection practices. After a trial, the jury rejected Homeowners' claims and awarded Contractor damages for its breach of contract counterclaim. Homeowners filed a motion for a new trial, arguing that Contractor committed misconduct by giving false testimony and fabricating an exhibit in order to support that testimony. Homeowners recognized the flaws in the exhibit before the case was submitted to the jury, but instead of alerting the court, decided to argue those flaws to the jury during the rebuttal stage of closing argument. The district court granted the motion. The court of appeals reversed the district court's order granting a new trial. The Supreme Court affirmed, holding that the district court abused its discretion in granting a new trial where (1) the district court did not lack authority to grant a new trial simply because the objection to the exhibit could have been raised earlier and was not; but (2) considering all the circumstances, including the absence of real misconduct or prejudice and Homeowners' decision to wait until rebuttal argument to bring forward its concerns, the district court abused its discretion in granting a new trial. View "Loehr v. Mettille" on Justia Law

Appellant Deng Kon Tong was convicted of being a felon in possession of a firearm in violation of Iowa Code 724.26. The court of appeals affirmed. Appellant appealed, claiming the district court erred in denying his motion to dismiss the charge because he had not been convicted of any felony at the time he allegedly possessed the firearm. Although Tong had pled guilty to a felony earlier the same year he was convicted in the instant case, he received a deferred judgment and a term of probation that had not been revoked. The Supreme Court affirmed, holding that the wording of section 724.26 indicated that the legislature intended the term "convicted of a felony," as used in that statute, to include a deferred judgment where Appellant had not successfully completed the term of his probation. View "State v. Tong" on Justia Law

Based on his guilty plea, Orlando Rodriguez was convicted for reckless vehicular homicide for an incident in which Rodriguez was an active participant in a drive-away theft of gasoline. Rodriguez was not driving the car when the accident occurred. Rodriguez appealed, claiming (1) he received ineffective assistance of counsel because there was no factual basis to support his plea; and (2) the district court imposed an illegal sentence by levying a $125 law enforcement initiative surcharge. The court of appeals affirmed Rodriguez's conviction but vacated his sentence with respect to the surcharge. The Supreme Court affirmed, holding (1) a passenger can be responsible as a party to the crime under a joint criminal conduct theory; (2) this case had a factual basis to support Rodriguez's plea, and Rodriguez's counsel was not ineffective for failing to challenge it; and (3) the district court had no statutory authority to apply a fine for a law enforcement initiative surcharge to vehicular homicide. View "State v. Rodriguez" on Justia Law

Appellant David Daughenbaugh pled guilty to criminal charges in exchange for the State's promise not to oppose Appellant's request for a deferred judgment. The district court accepted Appellant's request for a deferred judgment, placed him on supervised probation, and imposed civil penalties. Appellant subsequently filed an application for postconviction relief, alleging ineffective assistance of counsel. The State filed a motion for summary judgment, asserting that Appellant had not been "convicted" for purposes of postconviction relief. The district court held (1) Appellant was entitled to file a claim for postconviction relief because Appellant's guilty pleas amounted to convictions even though he received a deferred judgment; and (2) counsel was not ineffective. The Supreme Court affirmed but for different reasons, holding (1) a guilty plea pursuant to a deferred judgment is not a "conviction" under Iowa's postconviction statute; and (2) therefore, Appellant was not entitled to postconviction relief. View "Daughenbaugh v. State" on Justia Law

Following a jury trial, Robert Krogmann was convicted for attempted murder and willful injury. On appeal, Krogmann contended that (1) the district court erred in granting the State's pretrial request to freeze all his personal assets and requiring that he apply to the court for permission to use those assets for his legal defense, and (2) the prosecutor committed reversible misconduct by asking an inflammatory question at trial. The Supreme Court affirmed, holding (1) while the Court had concerns about the propriety of the asset freeze, Krogmann failed to preserve error on this issue; and (2) error was not preserved as to the incident of asserted prosecutorial misconduct, and this incident would not have amounted to reversible error in any event. View "State v. Krogmann" on Justia Law

Defendant Carson Walker was charged with operating a motor vehicle while intoxicated (OWI). After he was arrested, Walker requested to speak to his lawyer. While consulting, Walker and his lawyer talked through an intercom in a booth separated by a glass partition and were monitored by a police video camera. After conferring with his lawyer, Walker took a breath test, which measured Walker's blood level at more than double the legal limit. At trial, Walker moved to suppress the breath-test results based on the alleged violation under Iowa Code 804.20 to "see and consult confidentially" with his attorney "alone and in private." The district court granted the motion. On interlocutory appeal, the court of appeals reversed. The Supreme Court vacated the court of appeals and affirmed the district court's ruling suppressing the breath-test results, holding that the police violated Walker's section 804.20 rights by restricting his attorney conference to the booth with the glass partition under videotaped surveillance. View "State v. Walker" on Justia Law