Justia Iowa Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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The Supreme Court reversed the district court's ruling granting Defendant's motion to suppress statements she made during a custodial interview, holding that some deception by law enforcement in this case did not exceed what the legal system tolerates.Defendant's husband died of strangulation after being zip-tied in a chair in his residence. Defendant claimed that her husband had tied himself up. During an interview at the police station, police officers told Defendant falsely that doctors were still working to save her husband's life. An hour and half into the interview the officers corrected their deception. The officers also made various reassurances and suggestions to the woman. The trial court granted Defendant's motion to suppress. The Supreme Court reversed, holding (1) the officers' lie about whether her husband had been pronounced dead did not affect Defendant's essentially knowing and voluntary waiver of her Miranda rights; and (2) the officers' expressions of sympathy did not amount either to express or implied promises of leniency that would create a fair risk of a false confession. View "State v. Park" on Justia Law

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The Supreme Court held that In re T.H., 913 N.W.2d 578 (Iowa 2018) applies only to juvenile sex offenders whose cases are prosecuted and resolved in juvenile court and declined Defendant's invitation to apply its holding to a juvenile offender who is prosecuted and convicted in district court.At age seventeen, Defendant confessed to sexually abusing three children. Defendant was convicted on four class B felony counts and, at age twenty, was sentenced to terms of imprisonment. The court suspended the prison sentences, placed Defendant on probation, and imposed the special sentence of lifetime parole applicable to class B felonies under Iowa Code section 903B.1. The court further required Defendant to register as a sex offender under Iowa Code 692A.103(1). Defendant appealed, arguing that it is unconstitutional under In re T.H. to require a juvenile to register as a sex offender. The Supreme Court reversed in part, holding (1) In re T.H. does not apply to juvenile sex offenders prosecuted in district court; (2) registration under chapter 692A is not part of the "sentence" that can be suspended under section 901.5(13); and (3) Iowa Code 901.5(13) allowsed the district court to suspend Defendant's Iowa Code 903B.1 special sentence in whole or in part. View "State v. Hess" on Justia Law

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The Supreme Court reversed Defendant's conviction for second-degree sexual abuse, holding that Defendant's constitutional right to a public trial was violated when the trial court closed his trial during the COVID-19 pandemic.Defendant was set to stand trial on felony charges in March 2020, but his trial was repeatedly rescheduled due to COVID. The district court ultimately concluded that allowing anyone in to attend Defendant's trial, including his family and friends, violated COVID protocols previously set by the Supreme Court. The district court also rejected the option of live-streaming the trial. The jury subsequently convicted Defendant of second-degree sexual abuse. The Supreme Court reversed, holding that the district court's exclusion of all members of the public from Defendant's trial violated Defendant's constitutional rights, requiring a new trial. View "State v. Brimmer" on Justia Law

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The Supreme Court affirmed the judgment of the district court in favor of the State, the Iowa Department of Corrections, and the director of the Iowa Department of Corrections (collectively, Defendants) and against Plaintiff on his claims of employment discrimination, holding that Plaintiff's constitutional claims failed.Plaintiff sued Defendants under the Iowa Civil Rights Act. On the morning of trial, Plaintiff objected to the composition of the jury venire, arguing that the jury venire did not represent a fair cross section of the community. The district court denied the challenge, ruling that the fair-cross-section requirement does not apply to civil jury trials. Thereafter, the jury found that Plaintiff failed to prove any of his claims. On appeal, Plaintiff argued that the Fifth and Seventh Amendments of the United States Constitution require that civil juries be drawn from a fair cross section of the community. The Supreme Court affirmed, holding that Plaintiff's federal claims failed. View "Savala v. State" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction for possession of a controlled substance with intent to deliver, holding that Iowa R. Evid. 5.106 and the common law doctrine of completeness cannot trump Iowa R. Evid. 5.402.Specifically, the Supreme Court held (1) Defendant's right to a jury drawn from a fair cross section of the community under Iowa Const. art. I, 10 was not violated; (2) Defendant's claims of ineffective assistance of counsel were not properly before the Court and must be raised in the first instance on postconviction review; (3) the district court did not abuse its discretion in excluding certain documents proffered by Defendant as a discovery sanction; (4) the district court did not abuse its discretion in showing the jury an abbreviated version of a law enforcement officer's bodycam video; and (5) the evidence was sufficient to support the convictions. View "State v. Tucker" on Justia Law

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The Supreme Court reversed the order of the district court granting Defendant's motion to suppress his breath test because no interpreter was available and the advisory was read to him in English, holding that the police officer discharged his duty by making all reasonable efforts to obtain a Tigrinya interpreter before reading the advisory to Defendant in English.Defendant was from Eritrea, and his primary language was Tigrinya. Defendant, who was pulled over for traffic violations, agreed to do a preliminary breath test, which came back over the legal limit. He was then arrested and transported to a law enforcement center. The arresting officer contacted a commercial service known as Language Line to obtain an on-demand Tigrinya interpreter for the implied consent advisory, but not such interpreter was available. The officer then read Defendant the advisory. Defendant was subsequently charged with operating while intoxicated second offense. Defendant moved to suppress the evidence of his blood alcohol content from the DataMaster test on the grounds that he did not give consent. The district court sustained the motion. The Supreme Court reversed, holding that the officer complied with Iowa Code 321J.8 by making reasonable efforts and using reasonable methods to convey to Defendant the implied consent advisory. View "State v. Baraki" on Justia Law

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The Supreme Court upheld Defendant's convictions and sentences for several drug offenses and other misdemeanors, holding that the trial court did not err in denying Defendant's motion to suppress or in denying Defendant's retained attorney's requests to enter limited appearances.On appeal, Defendant argued, among other things, that the district court erred in denying his motion to suppress because the arresting officer's recollection that Defendant had a driving status of "barred" as of several months before did not amount to a reasonable suspicion to justify a traffic stop. The Supreme Court affirmed, holding (1) while the officer's information about Defendant's driver's license status was several months old, it gave the officer reasonable suspicion to justify stopping Defendant's vehicle; and (2) if a constitutional right to have a retained attorney enter a limited appearance exists, it is subject to reasonable regulation by the district court, and the district court in this case did not abuse its discretion in denying Defendant's requested limited appearances. View "State v. Sallis" on Justia Law

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The Supreme Court affirmed the decision of the district court entering summary judgment in favor of Defendants and dismissing Plaintiff's action with prejudice, holding that Defendant was not entitled to relief on any of his claims of error.Plaintiff sued a neighboring confined animal feeding operation (CAFO) alleging common law nuisance, trespass, and drainage law violations. Defendants moved for summary judgment based on the statutory immunity in Iowa Code 657.11. Plaintiff, relying on , argued that section 657.11, as applied, violated the Iowa Constitution's inalienable rights clause. The district court granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding (1) the three-part test set forth in Gacke is overruled; (2) under rational basis review, Plaintiff's constitutional challenge to section 657.11 was unavailing; (2) Plaintiff failed to preserve error on his takings claim; and (3) as to Plaintiff's trespass and drainage claims Plaintiff failed to generate a question of fact precluding summary judgment on statutory nuisance immunity or causation. View "Garrison v. New Fashion Pork LLP" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree murder arising from events in 1990 after his fourth trial, held almost thirty years after the crime, holding that Defendant was not entitled to relief on any of his claims of error.On appeal, Defendant argued that his conviction must be reversed due to juror misconduct, the improper admission of certain testimony, the erroneous exclusion of hearsay evidence, and a violation of due process. The Supreme Court disagreed and affirmed his conviction, holding that none of Defendant's allegations of error warranted reversal of his convictions. View "State v. Liggins" on Justia Law

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The Supreme Court reversed the ruling of the district court finding Iowa Code 815.1(4)(c) to be unconstitutional, holding that the State is not constitutionally required to provide ancillary services to an indigent defendant represented by private counsel if funds available to the counsel can reasonably be expected to cover the services.In 2019, the General Assembly enacted section 815.1, thereby changing the process by which an indigent defendant can obtain state funding for investigation costs when the defendant chooses to be represented by privately-retained counsel. The district court found section 815.1 unconstitutional under the Sixth Amendment, severed section 815.1(4)(c) from the statute, and granted Defendant's request for ancillary services at state expenses. The Supreme Court reversed, holding that the State is constitutionally permitted to consider the funds available to a retained attorney in determining whether it is required to provide state funding for ancillary services. View "Amaya v. State Public Defender" on Justia Law