Justia Iowa Supreme Court Opinion Summaries

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

Under the Iowa Constitution, a community caretaking seizure of a vehicle must be undertaken for genuine community caretaking purposes. In this case, a law enforcement officer was justified under the “community caretaking function” exception to the warrant requirement of the Fourth Amendment and Iowa Const. art. I, 8 when he pulled behind a vehicle stopped by the side of a highway after 1 a.m. with its brake lights engaged and activated his emergency lights.Defendant was charged with operating while intoxicated, first offense. Defendant moved to suppress the evidence obtained as a result of the stop of his vehicle, arguing that the stop of his vehicle and person was unconstitutional. The trial court denied the motion. The Supreme Court affirmed, holding that the conduct of the deputy in this case was not unconstitutional because the officer acted out of a genuine community caretaking motivation. View "State v. Coffman" on Justia Law

The Supreme Court reversed and remanded the case to the district court for further proceedings, holding that because the district court did not make specific findings of fact relative to any plaintiff when concluding that Iowa Code 657.11(2), as applied to Plaintiffs, violated Iowa Const. art. I, 1, the issue could not be resolved on this record.Plaintiffs, the owners and/or residents of real estate located near the confined animal feeding operations (CAFOs), brought this action claiming that Defendants were negligent in their operation of the CAFOs and that the CAFOs constituted a nuisance, entitling Plaintiffs to damages. Defendants filed a motion for summary judgment on the nuisance claims, asserting that section 657.11(2) barred the claims because Plaintiffs could not meet the requirements under the statute to recover the requested special damages against the CAFOs. The district court denied the motion, finding that section 657.11(2) was unconstitutional as applied to Plaintiffs because it denied Plaintiffs access to a remedy for their alleged injuries. The Supreme Court reversed and remanded with directions that the district court engage in a fact-based analysis by applying the three-prong test set forth Gacke v. Pork Xtra, LLC, 684 N.W.2d 168 (Iowa 2004). View "Honomichl v. Valley View Swine, LLC" on Justia Law

Defendant was entitled to a new trial after the State limited his access to his personal funds by freezing his assets prior to trial.Defendant was convicted of attempted murder and willful injury causing serious injury. Before trial, the trial court granted the State’s application for an order freezing all of Defendant’s assets. The order granting the freeze did not cite any authority or legal basis for the asset freeze. After Defendant’s convictions were affirmed on appeal he filed a postconviction relief (PCR) application arguing that the order freezing his assets was illegal and imposed for an improper purpose. Defendant also argued that the asset freeze adversely impacted his ability to defend himself by, among other things, inhibiting his ability to select his counsel of choice. The PCR court denied relief, and the court of appeals affirmed. The Supreme Court reversed and remanded for a new trial, holding (1) the asset freeze was unlawful; (2) defense counsel’s failure to properly challenge the freeze breached an essential duty; and (3) the consequences of the asset freeze violated Defendant’s constitutional right to be master of his defense, a structural error. View "Krogmann v. State" on Justia Law

Assertion of the Fifth Amendment privilege against self-incrimination excuses compliance with forfeiture threshold pleading requirements in Iowa Code 809A.13(4)(d), such as identifying the source of cash.Claimants’ property was seized after a drug interdiction traffic stop. The State sought forfeiture of the impounded vehicle and money discovered in a hidden compartment after issuance of a search warrant. Claimants sought return of the cash and vehicle but their pleadings omitted information required by section 809A.13(4)(d). The district court dismissed the driver’s claims for noncompliance with the statute’s pleading requirements. Following months of litigation, the State consented to return of the vehicle to the owner. The district court denied the owner’s claim for attorney fees. The Supreme Court remanded, holding (1) the district court erred by failing to rule on Claimants’ motions to suppress before adjudicating the forfeiture claims and erred by overruling Fifth Amendment objections to the pleading requirements; and (2) the vehicle owner was a prevailing party entitled to recover his reasonable attorney fees under the forfeiture statute. View "In re Property Seized from Jean Carlos Herrera and Fernando Rodriguez" on Justia Law

The Supreme Court reversed the district court’s decision granting postconviction relief to Defendant on his claim that he had received ineffective assistance of counsel from an immigration attorney when he tried to get a driver’s license, holding that no right to counsel had attached when Defendant went to the driver’s license station.Defendant’s visit to the driver’s license station triggered a criminal investigation and ultimately a conviction for a previously committed fraudulent practice. The district court set aside Defendant’s guilty plea and sentence, holding that Defendant’s counsel, who was representing Defendant in a pending federal immigration case, breached his essential duty to provide necessary advice to Defendant. The Supreme Court reversed, holding that neither the right to counsel under Iowa Const. art. I, 10, nor the United States Constitution Sixth Amendment right to counsel had attached at the time Defendant’s attorney advised Defendant regarding getting a driver’s license, as this was before any investigation or criminal proceedings had begun. View "Hernandez-Ruiz v. State" on Justia Law

At issue was whether the district court erred in not ordering a competency examination and in excluding evidence when Defendant’s lawyer moved midtrial for the examination of Defendant, who, among other things, stated that she wanted to stab her lawyer in the neck and wanted to kill him.Defendant was charged with willful injury causing bodily injury. During trial, the district court excluded evidence relating to the victim’s prior threatening behavior and her convictions for two assaults and an escape as more prejudicial than probative. Also during trial, Defendant’s attorney moved for a competency examination of Defendant, stating that Defendant was incapable of aiding him in her defense due to Defendant’s paranoid schizophrenia. The district court denied the motion, and Defendant was convicted. The Supreme Court reversed, holding (1) the district court was presented with sufficient reason to order a competency evaluation under Iowa Code 812.3; and (2) the district court properly excluded the challenged evidence about the victim as being substantially more prejudicial than probative. View "State v. Einfeldt" on Justia Law

In this appeal, Appellant, who at age thirteen shot and killed his mother, raised challenges to Iowa’s youthful offender laws. Specifically, he argued (1) Iowa Code 232.45(7)(a) does not provide statutory authority to try a thirteen-year-old as a youthful offender, (2) Iowa Code 232.45(7) and Iowa Code 907.3A constitute unconstitutional cruel and unusual punishment, and (3) the sentencing court abused its discretion by incarcerating him. The Supreme Court affirmed Appellant’s conviction as a youthful offender and his fifty-year indeterminate sentence with immediate parole eligibility, holding that the district court did not abuse its discretion in sentencing Appellant to a prison term rather than releasing him on probation or placing him in a transitional facility based on an individualized assessment of Defendant under a constitutional statutory scheme. View "State v. Crooks" on Justia Law

After Defendant’s initial sentence was voided for illegality, the district court resentenced Defendant to a new term of imprisonment. The district court originally suspended Defendant’s prison sentence and instead ordered a five-year term of probation. Upon resentencing, the court refused to credit the time Defendant spent on probation pursuant to the initial sentence against the new term of imprisonment. The Supreme Court held that the failure to award credit for the time spent on probation violated Defendant’s constitutional right to be free from double jeopardy under the Fifth Amendment. The court held that all time Defendant spent on probation pursuant to the voided sentence must be fully credited against a corrected sentence of incarceration because, when an initial sentence is voided for illegality, any punishments already endured must be credited against the corrected sentence. The dissent disagreed, arguing that probation should not be equated with punishment in the same way incarceration is considered for double jeopardy purposes. View "State v. Jepsen" on Justia Law

The Supreme Court affirmed Defendant’s conviction for failure to comply with the sex offender registry but vacated the district court sentence, which included sentencing enhancements, and remanded for further sentencing proceedings. The court held (1) despite the legislature’s ambiguous language in Iowa Code 692A.105, the legislature intended for registered sex offenders to provide notification of a change to temporary lodgings within five business days of that change; (2) the evidence was sufficient to show Defendant failed to comply with section 692A.105; (3) the district court properly instructed the jury regarding the applicable law; (4) any alleged prosecutorial misconduct did not prejudice Defendant; (5) Defendant’s stipulations to the sentencing enhancements were meaningless without a factual basis establishing whether he was represented by counsel for his prior convictions, and therefore, the case should be remanded to establish a factual basis on this sentencing issue; and (6) Defendant’s remaining claims of ineffective assistance of counsel failed. View "State v. Coleman" on Justia Law