Justia Iowa Supreme Court Opinion Summaries

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

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

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

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

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

In this employment discrimination case, prejudicial errors in four jury instructions required a new trial.Plaintiff filed claims against her former employer, alleging sexual harassment and retaliation under the Iowa Civil Rights Act (ICRA). The jury returned a verdict for Plaintiff on both counts and awarded damages in the amount of $1.4 million. Employer then filed a motion for new trial, which the district court denied. The Supreme Court reversed, holding (1) workers may bring a direct-liability negligence claim under the ICRA against an employer for supervisor harassment, but the plaintiff must prove that the employe knew or should have known of the harassment and failed to take prompt and appropriate remedial action to end it; (2) the district court did not abuse its discretion in admitting expert testimony on legal standards; but (3) the district court misinstructed the jury in four jury instructions, necessitating a new trial. View "Haskenhoff v. Homeland Energy Solutions, LLC" on Justia Law

Iowa Const. art. I, section 17 does not categorically prohibit a district court form sentencing a juvenile offender to a minimum term of incarceration without the possibility of parole, provided that the court only imposes the sentence after a complete and careful consideration of the relevant mitigating factors of youth.Defendant, who was a juvenile at the time of his offense, was resentenced to a minimum term of incarceration of seventeen and one-half years for sexual abuse in the second degree. Defendant appealed, arguing that any minimum term of incarceration without the possibility of parole is unconstitutional. The court of appeals affirmed the sentence. The Supreme Court remanded for resentencing, holding that, while the Iowa Constitution does not require abandonment of the practice at issue, the district court abused its discretion in this case by imposing a sentence of incarceration without parole eligibility. View "State v. Roby" on Justia Law

Defendant did not have a right to counsel under Iowa Const. art. I, section 10 when he voluntarily participated in a noncustodial police interview under the supervision of an Iowa county attorney even though the State’s criminal investigation was focusing on Defendant as the primary suspect at the time.Defendant was found guilty of murder in the first degree. During trial, the district court instructed the jury that it could infer Defendant acted with malice aforethought from his use of a baseball bat. The jury found Defendant killed the victim without justification and with malice aforethought. The court of appeals affirmed the judgment and sentence. The Supreme Court affirmed, holding (1) the level of prosecutorial involvement at the time of the interview did not create a prosecution or case that would trigger the right to counsel under article I, section 10; and (2) the jury could properly infer malice aforethought from Defendant’s use of a deadly weapon even though Defendant did not bring the weapon to the encounter. View "State v. Green" on Justia Law

The Supreme Court held that Defendant must be allowed to withdraw his plea of guilty to a criminal offense because Defendant would not have accepted the plea agreement if he had been provided the effective assistance of counsel to which he was constitutionally entitled.Defendant, who entered the United States without examination by the Department of Homeland Security, pleaded guilty to aggravated misdemeanor forgery. Based on this conviction, he was removed from the United States to Mexico. After Defendant returned to the United States he filed for postconviction relief, asserting that he was denied the effective assistance of counsel because counsel did not advise him pleading guilty to an aggravated felony has severe immigration consequences. The district court agreed and vacated Defendant’s conviction. The court of appeals reversed. The Supreme Court vacated the court of appeals, affirmed the district court, and remanded to allow Defendant to withdraw his plea and stand for trial, holding that counsel provided constitutionally deficient performance, and this deficiency resulted in prejudice. View "Diaz v. State" on Justia Law

The Supreme Court reversed Defendant’s conviction for domestic abuse assault, third offense, and remanded this case for a new trial, holding that Defendant received ineffective assistance of counsel because his trial counsel failed to request a jury instruction defining “household member.” The court thus vacated the decision of the court of appeals, which affirmed the conviction over a dissent. The majority concluded that defense counsel had breached an essential duty by failing to request the definition instruction but that Defendant failed to show prejudice because the State had presented sufficient evidence of cohabitation. The Supreme Court held (1) because the central issue at trial was whether Defendant and the victim had been cohabitating, the jury should have been given the definition instruction, which accurately set forth the factors bearing on that issue; and (2) therefore, defense counsel’s failure to request the instruction was prejudicial, necessitating a new trial. View "State v. Virgil" on Justia Law