Justia Iowa Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress and convicting him of possession of methamphetamine, second offense, holding that law enforcement acted reasonably under the Fourth Amendment and Iowa Const. art. I, 8 by ordering Defendant out of the vehicle.Defendant was the passenger in a vehicle that was stopped for speeding. Officers asked Defendant to exit the vehicle in order to facilitate the lawful arrest of the back-seat passenger. Officers then asked if they could check Defendant for weapons. The officer's pat-down revealed a methamphetamine pipe and a baggie containing methamphetamine. Defendant moved to suppress the evidence obtained after the exit order, which the district court denied. The Supreme Court affirmed, holding (1) Defendant's consent was voluntary based on the totality of the circumstances; and (2) the Iowa Constitution does no require that subjects of a search must be informed of their right to decline the search in order for their consent to be voluntary. View "State v. Hauge" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court denying Defendant's motion to suppress and convicting him of being a felon in possession of a firearm, holding that there was no error in the denial of the motion to suppress.Defendant was a passenger in a Lyft vehicle that was stopped for traffic violations. The officers recognized Defendant from past eluding incidents and ordered him out of the vehicle to conduct a pat-down for weapons. Defendant moved to suppress the evidence, arguing that the officer lacked reasonable and articulable facts to justify ordering him out of the vehicle and patting him down. The district court denied the motion to suppress, and the court of appeals affirmed. The Supreme Court affirmed, holding that the officer had reasonable suspicion to justify ordering Defendant out of the vehicle and subsequently patting him down for weapons. View "State v. Williams" on Justia Law

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In this criminal action, the Supreme Court affirmed the ruling of the district court on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury, holding that Defendant's conviction of second-degree murder stands.On appeal, Defendant, an African-American, argued that his right to an impartial jury under the United States Constitution had been violated because his jury pool contained only two African-Americans, one of whom was later excused. The Supreme Court made refinements to how a defendant must prove a fair-cross-section constitutional violation and remanded the case to give Defendant an opportunity to develop his impartial-jury arguments. On remand, the district court rejected Defendant's further-developed claims. The Supreme Court affirmed, holding that the district court did not err in ruling on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury. View "State v. Williams" on Justia Law

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In this criminal action, the Supreme Court affirmed the ruling of the district court on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury, holding that Defendant's conviction of two counts of murder in the first degree and one count of attempted murder stands.On appeal, Defendant, an African-American, argued that his right to an impartial jury under the United States Constitution had been violated because, although his jury pool contained five African-Americans, the jury that decided his case contained no African-Americans. The Supreme Court made refinements to how a defendant must prove a fair-cross-section constitutional violation and remanded the case to give Defendant an opportunity to develop his impartial-jury arguments. On remand, the district court rejected Defendant's further-developed claims. The Supreme Court affirmed, holding that the district court did not err in ruling on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury. View "State v. Veal" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the district court denying Employer's motion for a new trial and motion for judgment notwithstanding the verdict following a jury trial on Employee's claims of sex and gender identity discrimination and dismissing Employee's claims against a third-party administrator on summary judgment, holding that the court erred in part.Specifically, the Supreme Court (1) reversed the district court's denial of Employer's motion for judgment notwithstanding the verdict and dismissed the jury's verdict as to Employee's sex discrimination claims, holding that the district court erred in submitting the sex discrimination claim to the jury; (2) affirmed the jury's verdicts as to employee's gender identity discrimination claims; (3) affirmed the jury's damages award in favor of Employee in the full amounts that the jury entered; and (4) affirmed the district court's grant of summary judgment in favor of Employer. View "Vroegh v. Iowa Department of Corrections" on Justia Law

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The Supreme Court affirmed Defendant's conviction, rendered after a second jury trial, of second-degree murder, holding that Defendant was not entitled to relief on her allegations of error.Over twenty-five years after the murder in this case, a woman told a cold-case investigator about a murder confession she witnessed as a girl from Defendant. Defendant was ultimately charged with and convicted of murder. The Supreme Court affirmed, holding (1) as to Defendant's argument that the prosecution failed to timely disclose that certain evidence had been determined unsuitable for standard DNA testing, Defendant could have sought DNA testing prior to trial but chose not to do so, and Defendant may still pursue specialized DNA testing in a postconviction proceeding; (2) the twenty-six year delay in prosecution did not prejudice Defendant's ability to make her case, and there was no bad faith on the part of the prosecution; (3) the district court did not err in allowing the jury to scrutinize the credibility of witnesses; and (4) there was sufficient evidence for the jury to find Defendant guilty of second-degree murder. View "State v. Cahill" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court convicting Defendant of various drug-related crimes and sentencing him to a total of forty-two years in prison, holding that the district court did not err in denying Defendant's motion to suppress.At issue on appeal was whether the grant of a search warrant to search Defendant's residence and vehicles for evidence of drug dealing had a substantial basis under the totality of the circumstances, as disclosed in the warrant application. The Supreme Court held that the magistrate's determination that the information was sufficient to justify a search warrant for the house had a substantial basis, and therefore, the district court did not err in denying Defendant's motion to suppress. View "State v. Bracy" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court convicting Defendant, following a guilty plea, of lascivious acts with a child, holding that Defendant was not entitled to relief.On appeal, Defendant argued (1) his plea counsel provided ineffective assistance in allowing him to plead guilty without first requesting a competency hearing; and (2) the district court erred by failing, sua sponte, to order a competency hearing. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Defendant's claim of ineffective assistance of counsel was not a legally sufficient reason that could serve as "good cause" to establish a statutory right to appeal; and (2) the district court did not err by failing, sua sponte, to order a competency hearing. View "State v. Newman" on Justia Law

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The Supreme Court affirmed Defendant's plea-based conviction for a drug offense, a class "C" felony, holding that Defendant's challenges to the validity of his plea were unavailing.At issue was this Court's supervisory orders promulgated in response to the COVID-19 global pandemic temporarily allowing written pleas. On appeal, Defendant argued that the rules of criminal procedure, precedent, and due process required an in-person plea colloquy in open court and that the supervisory orders violated due process and separation of powers principles. The Supreme Court affirmed, holding (1) Defendant met the good cause requirement by presenting questions of first impression as the the validity of this Court's supervisory orders and Defendant's written guilty plea to a felony; but (2) this Court's supervisory orders are lawful exercises of this Court's constitutional and inherent authority during the pandemic. View "State v. Basquin" on Justia Law

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The Supreme Court affirmed the judgment of the district court granting the governor's request to dismiss this lawsuit challenging the Governor's August 2020 public health disaster proclamation that temporarily required taverns and bars in six counties to close, holding that this case was moot.Six establishments brought this action seeking an injunction that would block the order of Governor Kimberly K. Reynolds, which was issued during the COVID-19 pandemic, on the grounds that it exceeded her statutory and constitutional authority. After the Governor rescinded her order, the district court granted the Governor's request to dismiss the lawsuit as moot. The Supreme Court affirmed, holding that this case was moot and that no mootness exception applied. View "Riley Drive Entertainment I, Inc. v. Reynolds" on Justia Law