Articles Posted in Constitutional Law

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The Supreme Court reversed the judgment of the trial court convicting Defendant of operating while intoxicated (OWI), holding that the stop of the van in which Defendant was a passenger violated Iowa Const. art. I, section 8. After responding to a dispatch report of a vehicle in a roadside ditch, officers saw a van pass by on the road. Discovering that the van’s license plate was registered to another member of the same household that the vehicle in the ditch had been registered to, the officers followed the van and pulled it over. The driver of the car that had gone into the ditch was riding as a passenger in the van. That person, Defendant, was convicted of OWI. Defendant appealed the denial of his motion to suppress, arguing that the stop of the van was not permissible under the community caretaking doctrine. The Supreme Court agreed and reversed Defendant’s conviction and sentence, holding that the community caretaking exception did not apply under article I, section 8. View "State v. Smith" on Justia Law

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In this case challenging an automated traffic enforcement (ATE) program implemented by the City of Des Moines and its private contractor, Gatso USA, Inc., the Supreme Court reversed in part and affirmed in part the district court’s judgment, holding that the district court (1) erred in finding that the City’s ATE ordinance violated procedural due process; (2) properly granted Defendants’ motion to dismiss on grounds of preemption; (3) did not err in granting summary judgment to Gatso on Plaintiffs’ unjust enrichment claims; (4) erred in dismissing Plaintiffs’ equal protection, substantive due process, and privileges and immunities claims; and (5) erred in holding that there was no action for damages under the Iowa Constitution. Further, in light of the changed posture of the case, the Supreme Court vacated the district court’s order on unjust enrichment and the order on class certification and remanded for further consideration. View "Weizberg v. City of Des Moines" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the district court granting summary judgment in favor of Defendants on Plaintiffs’ class-action petition claiming that an automated traffic enforcement system (ATE) as implemented by Defendants violated the due process, privileges and immunities, and equal protection clauses of the Iowa Constitution. Specifically, hte Supreme Court held (1) the ATE system does not infringe on a fundamental right to intrastate travel; (2) the ATE system does not violate substantive due process; (3) the district court properly granted summary judgment on Plaintiffs’ equal protection and privileges and immunities claims; (4) the provisions of the ordinance that purportedly impose liability on a protesting vehicle owner under certain circumstances are irreconcilable with the provisions of Iowa Code 364.22 and are thus preempted; (5) the process outlined in the ATE ordinance complies with due process; (6) Plaintiffs’ unlawful delegation claims failed; and (7) because the district court’s judgment on the issue of preemption is reversed, the court’s judgment on unjust enrichment must be vacated and remanded for further consideration in light of the changed posture of the case. View "Behm v. City of Cedar Rapids" on Justia Law

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The Supreme Court affirmed the judgment of the district court and the decision of the court of appeals concluding that Appellant violated the ordinance established by City of Cedar Rapids regarding the operation of an automated traffic enforcement (ATE) system. A magistrate found clear and convincing evidence that Appellant violated the ATE ordinance while speeding where the ATE system was operating. The district court affirmed. The Supreme Court affirmed, holding (1) substantial evidence supported that Cedar Rapids established that Appellant was speeding in violation of the ordinance by clear, satisfactory, and convincing evidence; (2) Appellant was not entitled to relief as to her arguments raised with respect to equal protection, privileges and immunities, and substantive due process; and (3) there was no unlawful delegation in this case. View "City of Cedar Rapids v. Leaf" on Justia Law

Posted in: Constitutional Law

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The Supreme Court answered a question asked by the federal district court as to whether a defendant can raise a defense of qualified immunity to an individual’s claim for damages in violation of Iowa Const. art. I, 1 and 8. The operator of an ATV was arrested then released based on the finding that his conduct was not prohibited by law. Thereafter, the ATV operator brought suit against the city and the police officers under article I, sections 1 and 8 of the Iowa Constitution. The case was removed to federal court, which granted summary judgment to Defendants. The federal district court then certified a question of law to the Supreme Court. The Supreme Court answered that a defendant who pleads and proves as an affirmative defense that the defendant exercised all due care to conform with the requirements of the law is entitled to qualified immunity on an individual’s claim for damages in violation of article I, sections 1 and 8 of the Iowa Constitution. View "Baldwin v. City of Estherville, Iowa" on Justia Law

Posted in: Constitutional Law

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The Supreme Court held that Division I of Senate File 471 (the Act), which creates new prerequisites for physicians performing an abortion, violates both the due process and equal protection clauses of the Iowa Constitution because its restrictions on women are not narrowly tailored to serve a compelling interest of the State. The district court held that the Act, which includes a mandatory seventy-two-hour waiting period between informational and procedure appointments, did not violate the Iowa Constitution. The Supreme Court reversed, holding that the “seventy-two hour[]” waiting requirement of the Act violates the right to equal protection and due process under the Iowa Constitution. View "Planned Parenthood of the Heartland v. Reynolds ex rel. State" on Justia Law

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At issue was whether the three-year statute of limitations in Iowa Code 822.3 applies where a postconviction relief (PCR) petitioner files an untimely second petition for PCR alleging that counsel for his timely filed first petition for PCR was ineffective. The district court concluded that the second petition’s allegations of ineffective assistance of postconviction counsel were not grounds to avoid the three-year statutory bar. The court of appeals affirmed, citing the Supreme Court’s decision in Dible v. State, 557 N.W.2d 881, 883, 886 (Iowa 1996). The Supreme Court qualified Dible and held that where a PCR petition alleging ineffective assistance of trial counsel has been timely filed per section 822.3 and there is a successive PCR petition alleging that postconvcition counsel was ineffective in presenting the ineffective-assistance-of-trial-counsel claim, the timing of the filing of the second PCR petition relates back to the timing of the filing of the original PCR petition for purposes of Iowa Code section 822.3 if the successive PCR petition is filed promptly after the conclusion of the first PCR petition. The Court therefore vacated the court of appeals and reversed the decision of the district court and remanded the case. View "Allison v. State" on Justia Law

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The Supreme Court adopted a tighter legal framework for warrantless inventory searches and seizures of automobiles under Iowa Const. art. I, 8 than provided under the recent precedents of the United States Supreme Court. In his challenge to the search and seizure provision of article I, section 8 of the Iowa Constitution Defendant noted that a number of state courts have rejected the approach of the United States Supreme Court - which generally provides that warrantless inventory searches of automobiles are permissible if they are conducted pursuant to law enforcement policies that govern the decision to impound the vehicle and the nature and scope of any subsequent search - in favor of a more restrictive approach that sharply limits warrantless searches and seizures of automobiles. The Supreme Court ultimately held (1) the police should advise the owner or operator of the vehicle of the options to impoundment, and when impoundment is necessary, personal items may be retrieved from the vehicle, and if the vehicle is impounded, containers found within the vehicle will not be opened but stored for safekeeping as a unit unless the owner or operator directs otherwise; and (2) the impoundment and search in this case was outside the bounds of any constitutionally permissible local impoundment and inventory policy. View "State v. Ingram" on Justia Law

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The Supreme Court declined to hold that the felony-murder rule violates due process under the Iowa or United States Constitution when it is applied to juvenile offenders pursuant to a theory of aiding and abetting. Defendant was a juvenile and unarmed when he participated in a marijuana robbery. A coparticipant, who had brought a gun to the crime, killed the robbery victim. Defendant was convicted of first-degree murder and sentenced to life imprisonment with immediate parole eligibility. The Supreme Court affirmed the conviction and sentence, holding (1) applying the felony-murder rule to juvenile offenders based on a theory of aiding and abetting is constitutional; (2) Defendant’s sentence did not constitute cruel and unusual punishment, either categorically or as applied to Defendant; (3) the trial court provided the jury with proper instructions regarding the types of assault required to establish the forcible felony robbery element of felony murder; and (4) the record was inadequate for the Court to address some of Defendant’s claims of ineffective assistance of counsel, and the remainder of Defendant’s ineffective assistance of counsel claims were without merit. View "State v. Harrison" on Justia Law

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The Supreme Court declined to hold that the felony-murder rule violates due process under the Iowa or United States Constitution when it is applied to juvenile offenders pursuant to a theory of aiding and abetting. Defendant was a juvenile and unarmed when he participated in a marijuana robbery. A coparticipant, who had brought a gun to the crime, killed the robbery victim. Defendant was convicted of first-degree murder and sentenced to life imprisonment with immediate parole eligibility. The Supreme Court affirmed the conviction and sentence, holding (1) applying the felony-murder rule to juvenile offenders based on a theory of aiding and abetting is constitutional; (2) Defendant’s sentence did not constitute cruel and unusual punishment, either categorically or as applied to Defendant; (3) the trial court provided the jury with proper instructions regarding the types of assault required to establish the forcible felony robbery element of felony murder; and (4) the record was inadequate for the Court to address some of Defendant’s claims of ineffective assistance of counsel, and the remainder of Defendant’s ineffective assistance of counsel claims were without merit. View "State v. Harrison" on Justia Law