Justia Iowa Supreme Court Opinion Summaries

The case involves a challenge to an Iowa law that prohibits abortions after a fetal heartbeat is detected. The plaintiffs, Planned Parenthood of the Heartland, Inc., Emma Goldman Clinic, and Sarah Traxler, filed a lawsuit against the defendants, Kim Reynolds and the Iowa Board of Medicine, arguing that the law is unconstitutional. The district court granted a temporary injunction, blocking the enforcement of the law.The district court's decision was based on the application of the "undue burden" test, concluding that the plaintiffs were likely to succeed in their constitutional substantive due process challenge. The defendants appealed, arguing that the district court applied the wrong constitutional test and that the court should instead review the abortion restriction under the less demanding "rational basis" test.The Supreme Court of Iowa reversed the district court's decision. The court held that abortion is not a fundamental right under the Iowa Constitution and that abortion restrictions alleged to violate the due process clause are subject to the rational basis test. Applying this test, the court concluded that the fetal heartbeat statute is rationally related to the state’s legitimate interest in protecting unborn life. The court remanded the case for further proceedings, instructing the district court to dissolve the temporary injunction blocking enforcement of the fetal heartbeat statute. View "Planned Parenthood of the Heartland, Inc. v. Reynolds ex rel. State of Iowa" on Justia Law

Nathan Olsen, convicted of a sex offense in Wisconsin in 2009, moved to Iowa where he was required to register as a sex offender. After serving a prison sentence for an unrelated crime, Olsen moved to Illinois where he was not required to register. He wished to return to Iowa, but doing so would require him to register again. Olsen filed an application in the district court to modify his status as a sex offender and the registration requirements that would apply to him in Iowa before he moved back. The district court dismissed his application, and the court of appeals affirmed the dismissal.The district court and the court of appeals both concluded that Olsen's claim was not ripe for adjudication because his application sought to modify a "hypothetical" registration requirement predicated on his potential future return to Iowa. Olsen argued that the statute permitting only those who currently live, work, or attend school in Iowa the opportunity to modify their sex offender registration requirements unlawfully discriminates against nonresidents in violation of the Privileges and Immunities Clauses of the Iowa and United States Constitutions.The Supreme Court of Iowa found that the residency restriction imposed by the statute prohibits nonresidents from seeking the same fundamental privilege to access Iowa’s courts that a resident receives. However, the court was unable to evaluate the State’s justification for treating residents and nonresidents differently due to lack of evidence. Therefore, the court remanded the case for the parties to present evidence and for the district court to rule on Olsen’s constitutional challenge in light of that evidence. The court also rejected the State's argument that Olsen was not eligible for modification because five years hadn’t passed from the date of commencement of his requirement to register. View "Olsen v. State of Iowa" on Justia Law

The case involves a defendant who appealed the denial of her motion to suppress evidence obtained from a traffic stop, a dog sniff of her vehicle, and a search of her purse. The defendant was driving slower than the speed limit, causing traffic issues, and crossed the centerline multiple times. The officer, suspecting drug-related activity due to the defendant's history of drug offenses, initiated a traffic stop and requested a K-9 unit. The dog sniffed the exterior of the vehicle, occasionally touching it with its paws, and alerted to the presence of drugs. A subsequent search of the vehicle and the defendant's purse revealed methamphetamine and related paraphernalia.The defendant argued that the traffic stop was unjustified, the dog sniff constituted an unconstitutional search because the dog touched the exterior of her vehicle, and the search of her purse was unlawful. The district court denied the motions to suppress, and the defendant was found guilty on three counts.The Supreme Court of Iowa affirmed the lower court's decision. The court held that the traffic stop was justified due to the defendant's driving behavior. It also ruled that the dog sniff did not violate the Fourth Amendment or the Iowa Constitution, as the dog was in a place where police had a right to be and the sniff only revealed the presence or absence of contraband. The court did not rule on the legality of the purse search, as the defendant failed to properly raise and preserve the issue for appeal. View "State of Iowa v. Bauler" on Justia Law

The case involves Derek White, who was charged with child neglect or abuse and child endangerment causing bodily injury. The charges stemmed from the discovery of extensive bruising on a two-year-old child, D.C., who lived with White and several other children. During the trial, two of White's sons, J.W. and M.W., testified against him. However, they were allowed to testify from outside the courtroom via a one-way closed-circuit television system, which meant that they could not see White while they testified against him. White argued that this procedure violated his right of confrontation under the Iowa Constitution.The Iowa District Court for Osceola County rejected White's constitutional arguments and allowed the testimony of J.W. and M.W. via the one-way closed-circuit television system. The jury found White guilty as charged. On appeal, the Iowa Court of Appeals affirmed White's convictions. White then sought further review from the Supreme Court of Iowa.The Supreme Court of Iowa held that the procedure used for the testimony of J.W. and M.W. violated White's right of confrontation under the Iowa Constitution. The court reasoned that face-to-face confrontation requires that trial witnesses must be both visible to the accused and also able to see the accused. Therefore, when the witness and the accused are prevented from seeing each other, there can be no face-to-face confrontation, and the Iowa Constitution is not satisfied. The court reversed White's convictions and remanded the case for a new trial. View "State of Iowa v. White" on Justia Law

Shannon Hightower pleaded guilty to dependent adult abuse and theft in the second degree. She later appealed, arguing that there were defects in her guilty plea, her sentencing, and the conditions set for her appeal bond. Hightower also contended that Iowa Code section 814.29, which regulates judicial review of challenges to a guilty plea, was unconstitutional.The district court had found Hightower guilty based on her plea and sentenced her to concurrent prison terms. One of the court's reasons for the sentence was Hightower's failure to pay restitution prior to sentencing. After sentencing, Hightower filed a motion asking the court to order a stay of the sentence and to set a hearing to review concerns about her guilty plea. Alternatively, she asked the court to set an appropriate appeal bond. The court denied Hightower's request for a hearing about her guilty plea and set an appeal bond in the amount of $17,000 cash only.The Supreme Court of Iowa found that Hightower's guilty plea was defective due to the absence of an accurate advisory as to the maximum punishment she faced by pleading guilty. However, the court concluded that section 814.29 prevented it from vacating Hightower's plea. The court also agreed with Hightower that resentencing was required because the district court relied on an improper sentencing factor. Furthermore, the court agreed with Hightower that the district court erred by ordering unauthorized forfeiture requirements for Hightower’s appeal bond. The court affirmed Hightower’s conviction, vacated her sentence, and reversed the forfeiture requirements. The case was remanded for resentencing and for lawful disbursement of funds paid for Hightower’s release during the appeal. View "State of Iowa v. Hightower" on Justia Law

The case revolves around Lasondra Johnson, who was charged with first-degree murder following a series of events that led to her shooting and killing Jada YoungMills. Johnson claimed she acted in self-defense, invoking Iowa's "stand your ground" law, which negates the requirement to retreat before using force if one is lawfully present and not engaged in illegal activity. The jury acquitted Johnson of first-degree murder but found her guilty of the lesser charge of assault causing serious injury. Johnson appealed, arguing that the district court incorrectly instructed the jury on the stand-your-ground defense and a related instruction on the presumed reasonableness of using deadly force.The Iowa Court of Appeals affirmed Johnson's conviction but reversed the restitution order. Johnson sought further review, arguing that the jury instructions were misleading and confusing because there was no evidence to support an instruction to the jury that she was engaged in a separate illegal activity—assault—at the time of the shooting. She also argued that the district court imposed an unconstitutional restitution award against her and erred in relying on improper considerations and by applying a fixed sentencing policy.The Supreme Court of Iowa found that the jury instructions were indeed misleading and confusing. The court noted that the instructions allowed the jury to consider the shooting itself as an assault, which would defeat Johnson's justification defense. This interpretation would effectively nullify the stand-your-ground statute, as every use of deadly force could be considered an assault. The court concluded that the jury instructions failed to convey the law in such a way that the jury had a clear understanding of Johnson's justification defense. As a result, the court reversed Johnson's conviction, vacated the sentence, and remanded the case for a new trial. View "State v. Johnson" on Justia Law

The case revolves around Abel Gomez Medina, who was convicted of sexual abuse and indecent contact with a minor. The minor, identified as Dorothy, was his stepdaughter. She reported the abuse to her school counselor, stating that it had been ongoing since she was eleven years old. Dorothy's stepbrother, Frank, also testified that he had witnessed inappropriate behavior between Medina and Dorothy. The defense presented witnesses who claimed they had never seen anything inappropriate between Medina and Dorothy.Prior to the trial, the State moved to permit Dorothy and Frank to testify via closed-circuit television, citing the potential trauma caused by in-person testimony. The district court granted this for Dorothy but denied it for Frank. During the trial, Dorothy turned eighteen and Medina objected to her continuing to testify via closed-circuit television, arguing that the statute permitting such testimony only applied to minors. The district court overruled this objection, citing a different paragraph of the statute that allowed for closed-circuit testimony for victims or witnesses with mental illnesses, regardless of age.Medina appealed his conviction, arguing that allowing Dorothy to testify via closed-circuit television violated both the Iowa Code and the Confrontation Clause of the United States Constitution. The court of appeals affirmed Medina's convictions, holding that permitting Dorothy’s closed-circuit testimony satisfied constitutional requirements while she was a minor, and that by meeting the requirements under Iowa Code after she turned eighteen, Medina’s claim of a Confrontation Clause violation similarly failed. Medina then filed an application for further review of the court of appeals ruling, which was granted by the Supreme Court of Iowa.The Supreme Court of Iowa affirmed the decisions of the lower courts. It concluded that Medina had failed to preserve error on his Confrontation Clause argument concerning Dorothy’s testimony after she turned eighteen. The court also found that the district court had properly applied the statute to permit Dorothy’s closed-circuit testimony, based on the evidence presented at the pretrial hearing. The court let the court of appeals decision stand on Medina's arguments that the district court abused its discretion by allowing the prosecutor to comment during closing argument and by excluding 911 call logs. View "State v. Medina" on Justia Law

The case involves a convicted felon, Adam Aaron Rhodes, who was charged with possession of a firearm, a muzzleloader replica of an antique firearm, in violation of Iowa Code section 724.26(1). Rhodes argued that his muzzleloader, used to kill a deer, was not a firearm within the meaning of the statute because it was a replica of an antique firearm, which is excluded from the statutory definition of "offensive weapon," and federal law excludes such muzzleloaders from the federal definition of "firearm."The district court disagreed with Rhodes, finding him guilty of possessing a "firearm" under the common meaning of the term and the court's precedent. The court defined a "firearm" broadly to include "any instrument which will or is designed to discharge a projectile by the force of a chemical explosive such as gun powder." The court also rejected several affirmative defenses raised by Rhodes, including a void for vagueness constitutional challenge. Rhodes was sentenced to probation for a period not to exceed five years.On appeal, the Supreme Court of Iowa affirmed the district court's judgment. The court held that Rhodes's muzzleloader falls within the meaning of "firearm" in section 724.26. The court reasoned that the Iowa legislature declined to enact the federal definition of "firearm" and that the court's precedents apply the common meaning of "firearm" that encompasses this muzzleloader rifle. The court also rejected Rhodes's argument that the court should follow the federal felon-in-possession statute, 18 U.S.C. § 922(g), when interpreting Iowa’s felon-in-possession statute. The court concluded that the Iowa legislature is free to adopt the federal exception for antique firearms but has not done so. View "State of Iowa v. Rhodes" on Justia Law

The Supreme Court of Iowa was asked to consider whether the Iowa Constitution supports a legislative privilege that protects legislators from compelled production of documents related to legislation. The court concluded that the Iowa Constitution does indeed contain a legislative privilege that protects legislators from compelled document production, particularly in relation to communications with third parties about the legislative process. The case arose from subpoenas served on several Iowa legislators by the League of Latin American Citizens of Iowa (LULAC). LULAC sought discovery of communications related to recent legislative changes to voting procedures. The legislators objected to the subpoenas, arguing they were protected from compelled document production by a legislative privilege under the Iowa Constitution. The court ruled that the privilege extends to communications with third parties where the communications relate directly to the legislative process of considering and enacting legislation. However, the court did not decide whether this legislative privilege was absolute or qualified, as it concluded that the requested documents were not relevant to LULAC's claims and were therefore protected by the legislative privilege, regardless of its extent. The court reversed the district court's judgment granting in part LULAC's motion to compel and remanded with instructions to quash the subpoenas. View "Smith v. Iowa District Court for Polk County" on Justia Law

In this case heard by the Supreme Court of Iowa, the defendant, Morgan Marie McMickle, was charged with operating a motor vehicle while intoxicated (OWI). McMickle was stopped by law enforcement after rear-ending another vehicle and leaving the scene. The investigating officer obtained a search warrant to collect a blood sample from McMickle for chemical testing, which showed a blood alcohol content over three times the legal limit. Additionally, McMickle repeatedly asked to speak to her lawyer but was denied. She later filed a motion to suppress evidence, arguing that the use of a search warrant instead of the statutory implied consent procedure violated her rights, and that her right to counsel was violated under Iowa Code section 804.20.The district court granted McMickle's motion, determining that the officer's use of a search warrant was not authorized, that the officer had no statutory authority to collect and test bodily specimens, and that the officer's actions violated McMickle's constitutional rights to equal protection and due process. Additionally, the court found that the officer's refusal of McMickle's requests to speak to her lawyer violated her rights under section 804.20. As a result, the court ordered the suppression of McMickle's statements and the results of the blood test.However, the Supreme Court of Iowa reversed the district court's decision. The court held that the statutory implied consent procedure was not the exclusive means by which an officer can investigate suspected OWI offenses, and that a law enforcement officer's decision to obtain and execute a search warrant did not violate a suspect's constitutional rights. The court also ruled that although McMickle's rights under section 804.20 were violated, the blood test results should not have been suppressed because they were obtained through a legally issued search warrant, independent of any violation of section 804.20. The case was remanded back to the lower court. View "State of Iowa v. McMickle" on Justia Law