Articles Posted in Constitutional Law

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The claims brought by the City of Eagle Grove alleging two properties owned by Cahalan Investments, LLC were abandoned and in an advanced state if disrepair and praying for a transfer of ownership from Cahalan to the City under Iowa Code 657A.10A fit within the public-nuisance exception recognized in Lucas v. South Carolina Coastal Council, 505 U.S. 1003 (Iowa 1992), and did not result in a taking requiring compensation to Cahalan. The district court dismissed the City’s petitions seeking ownership of the properties at issue in this case, concluding that the transfer of ownership without just compensation to Cahalan would constitute an unconstitutional taking. The Supreme Court reversed, holding that transfer of title to the two properties under section 657A.10A would not constitute a taking under the circumstances presented in this case, and therefore, there was no constitutional requirement of just compensation. View "City of Eagle Grove, Iowa v. Cahalan Investments, LLC" on Justia Law

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The Supreme Court reversed the judgment of the district court denying Defendant’s motion to suppress evidence obtained after an officer stopped his vehicle for being on a county access road after hours. The district court determined that Defendant violated Iowa Code 350.5 by entering the county access area after hours, regardless of whether there was a sign posted to identify the county access area or the park hours. The Supreme Court disagreed, holding (1) the officer did not have probable cause or reasonable suspicion to stop Defendant’s vehicle when it was on the county access road after hours because, without a proper posting of the closing time, the officer did not have probable cause or reasonable suspicion to stop Defendant; and (2) therefore, the district court should have suppressed any drug evidence found in Defendant’s vehicle. View "State v. Scheffert" on Justia Law

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Iowa may constitutionally deny an inheritance tax exemption for bequests to stepchildren when the marriage between parent and stepparent was dissolved before the stepparent’s death, while granting an exemption when the marriage was not dissolved. The Supreme Court affirmed the judgment of the district court affirming the administrative ruling of the Iowa Department of Revenue denying an estate’s request for a tax refund. An administrative law judge rejected the decedent’s stepchildren’s protest challenging the denial of the tax refund on the ground that Iowa Code 450.1(1)(e)’s classification of stepchildren violated their equal protection rights under Iowa Const. art. I, 6. The district court affirmed the Department’s decision. The Supreme Court affirmed, holding that section 450.1(1)(e) does not violate article I, section 6 of the Iowa Constitution because a rational basis exists for the legislature to exclude stepchildren postdivorce from the inheritance tax exemption for surviving spouses lineal descendants, lineal ascendants, and other stepchildren. View "Tyler v. Iowa Department of Revenue" on Justia Law

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Defendant was not entitled to an automatic new trial after the district court, over Defendant’s objection, required a standby interpreter for his jury trial. Defendant requested, and was provided, an interpreter for all of his pretrial hearings. Defendant sought to waive the interpreter for his jury trial, however. The district court nevertheless ordered a standby interpreter to sit in the gallery translating through a wireless earpiece Defendant could remove at his option. Defendant waived the jury and, after a bench trial, was convicted of selling cocaine. The Supreme Court affirmed, holding (1) Defendant had a right to waive the interpreter, but the district court did not abuse its discretion by ordering a standby interpreter over Defendant’s objection; and (2) the record was inadequate to review Defendant’s claim that his counsel was ineffective in waiving the jury. View "State v. Garcia" on Justia Law

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The Supreme Court decided not to abandon the automobile exception to the search warrant requirement under Iowa Const. art. I, 8 despite technological advances enabling police to obtain warrants from the scene of a traffic stop. Defendant was convicted of possession with intent to deliver. Defendant appealed the denial of his motion to suppress, arguing that the warrantless search of his vehicle violated the Iowa Constitution because police can now obtain warrants electronically from the side of the road. The Supreme Court elected to retain the automobile exception, consistent with precedent, federal caselaw, and the overwhelming majority of other states. The court thus affirmed Defendant’s conviction. View "State v. Storm" on Justia Law

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In this case, the Supreme Court abandoned the exclusive use of absolute disparity as a test for jury representativeness under the Sixth Amendment and permitted absolute disparity, comparative disparity, and standard deviation analyses to be used. Defendant, a black man, was convicted by an all-white jury of one count of harassment in the first degree. On appeal, Defendant argued that the racial composition of the jury pool violated his Sixth Amendment right to an impartial jury. The Supreme Court conditionally affirmed Defendant’s conviction and remanded the case for development of the record on the Sixth Amendment challenge, holding that the district court erred as a matter of law in concluding that the absolute disparity test must be used in deciding whether the jury pool was drawn from a fair cross-section of the community. View "State v. Plain" on Justia Law

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This case involved claims brought against various state officials for damages related to public employment. Plaintiff was an Iowa Workers’ Compensation Commissioner. At issue in this interlocutory appeal were four counts alleging violation of due process and equal protection provisions of the Iowa Constitution. The district court granted summary judgment for Defendants on these claims finding that there are no private causes of action for violations of the Iowa Constitution. The Supreme Court reversed in part and affirmed in part, holding that Defendants were not entitled to summary judgment on Counts VI and VII where (1) the equal protection clause of the Iowa Constitution is self-executing; (2) classic preempt doctrine does not apply to the question of whether a Bivens-type damage remedy is available through the Iowa Constitution; and (3) the different nature of the interests protected weighs in favor of allowing a Bivens-type claim to go forward against Defendants. View "Godfrey v. State" on Justia Law

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The administration of a warrantless breath test to Defendant violated Iowa Const. art. I, 8 because the State failed to prove that Defendant voluntarily consented to the warrantless breath test and failed to prove that the breath test was justified by an exception to the warrant requirement. Defendant was convicted of operating a motorboat while under the influence. Defendant appealed the denial of his motion to suppress all evidence after an officer seized the boat he was operating, including the results of a blood test he submitted to. The Supreme Court reversed, holding (1) the law enforcement officer’s seizure of the boat Defendant was operating was constitutional because the officer had a reasonable, articulable suspicion Defendant was committing a crime; but (2) Defendant did not effectively consent to the warrantless breath test, and therefore, the admission of the breath test results violated article I, section 8. View "State v. Pettijohn" on Justia Law

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In this interlocutory review on a discovery dispute, the Supreme Court affirmed the decision of the district court ordering counsel for Defendant to provide notice to the State before serving any subpoenas duces tecum on third parties and finding that there was no statutory or constitutional authority to support Defendant’s position that he had a right to issue ex parte subpoenas duces tecum. Defendant, who was charged with child endangerment, resisted the State’s motion regulate discovery and request that the district court enter an order prohibiting Defendant from issuing ex parte subpoenas duces tecum. The district court granted the State’s motion and issued a protective order stating that Defendant was prohibited from issuing any subpoena except under certain circumstances. The Supreme Court affirmed the district court grant of the motion to regulate discovery, holding (1) the proper procedure for Defendant to use if he seeks to issues an ex parte subpoena duces tecum is to file a motion setting forth the basis for the request; and (2) there is no corresponding constitutional violation under the state or federal Constitutions. View "State v. Russell" on Justia Law

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The district court did not abuse its discretion in commencing a criminal trial on June 26 and then postponing the presentation of evidence to July 7, eight days after the June 29 expiration of the speedy trial deadline due to the unavailability of medical experts. Defendant was charged with attempted murder and other offenses. Jury selection was reset for June 26. Eleven days later, on July 7, the State called four witnesses, including a medical expert. The jury found Defendant guilty of the lesser included offenses of assault with intent to inflict serious injury, criminal trespass, and willful injury causing serious injury. The Supreme Court affirmed Defendant’s convictions and sentence, holding (1) assuming, without deciding, that the court’s use of a start-and-stop procedure to avoid the speedy trial deadline should be analyzed under the same standards as a straightforward extension of the speedy trial deadline, the trial court acted within its discretion; and (2) Defendant’s other issues on appeal were without merit. View "State v. McNeal" on Justia Law