Justia Iowa Supreme Court Opinion Summaries

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

Defendant Jesse Pearson, a seventeen-year-old, robbed and beat an elderly man. After he was apprehended, Pearson refused to waive his Miranda rights. The next morning, however, he confessed to his social worker, Marie Mahler, without his attorney present. The district court denied Pearson's motion to suppress his confession, concluding that Mahler's interview was not a custodial interrogation implicating Miranda safeguards. A jury convicted Pearson of first-degree robbery, willful injury, and going armed with intent. The court of appeals reversed Pearson's conviction on the going armed charge and otherwise affirmed. At issue on appeal was whether Pearson's confession to Mahler was admissible. The Supreme Court affirmed, holding that Mahler's interview of Pearson was not a custodial interrogation for Miranda purposes and that his confession to her was voluntary and admissible. View "State v. Pearson" on Justia Law

A jury found Defendant Robin Brubaker guilty of operating while intoxicated, fourth offense, and unlawful possession of a prescription drug. On appeal, Defendant contended that the district court erred by denying his motion to suppress evidence found in his car when officers searched it after his arrest and that his trial counsel was ineffective for failing to object specifically to the sufficiency of the evidence offered by the State regarding the charge of unlawful possession of a prescription drug. The Supreme Court reversed the judgment for unlawful possession of a prescription drug and remanded the case for dismissal of that charge, holding that trial counsel was ineffective and if counsel had made the proper object regarding the sufficiency of the evidence, the district court would have dismissed the unlawful possession charge. View "State v. Brubaker" on Justia Law

Judith Utter was charged with supplying alcohol to a person under the legal age. Utter pled guilty to the charge. Subsequently, Utter appealed, arguing her trial counsel provided ineffective assistance by failing to file a motion to dismiss the charge based on the State's violation of Iowa's speedy indictment rule. The court of appeals affirmed after analyzing the issue and preserving Utter's claim for a postconviction relief proceeding. The Supreme Court vacated the court of appeals and reversed the district court, holding (1) the State violated the speedy indictment rule by failing to indict Utter with the forty-five day window mandated by Iowa R. Crim. P. 2.33(2)(a); (2) Utter's trial counsel failed to perform an essential duty by failing to file a motion to dismiss based on the State's violation of the speedy indictment rule; and (3) Utter did not enter the plea voluntarily or intelligently as she would not have pled guilty if she had known the court was required to dismiss the information under rule 2.33(2)(a) and the State could not charge her with any other violation of Iowa Code 123.47 arising out of the underage drinking party at her home. Remanded with directions to dismiss the information. View "State v. Utter" on Justia Law