Justia Iowa Supreme Court Opinion Summaries

Defendant was charged with operating while intoxicated, third offense. Defendant filed a motion to suppress evidence obtained after a police officer pulled his patrol car into Defendant’s driveway with its emergency lights flashing, approached Defendant on foot, and directed him to step down from his front porch onto the driveway. Defendant argued that the officer’s conduct amounted to an unlawful seizure. The district court denied the motion to suppress, concluding that no seizure occurred. The court of appeals affirmed. The Supreme Court reversed, holding that Defendant was seized within the meaning of the Fourth Amendment when the officer directed Defendant to step off the front porch and onto the driveway. Remanded. View "State v. White" on Justia Law

This petition for injunctive relief and writ of mandamus challenged the Governor’s item veto of appropriations intended to fund the Mount Pleasant and Clarinda Mental Health Institutes. The AFSCME Iowa Council 61 president and twenty state legislators brought suit against the Governor, alleging that the Iowa Code mandates the existence of the Mount Pleasant and Clarinda Mental Health Institutes and their continued operation. The district court granted summary judgment to the Governor and dismissed the petition. The Supreme Court affirmed, holding (1) the appeal was timely, and the issue of the Governor’s veto was not moot; and (2) the Governor’s exercise of his item veto of appropriations for the mental health institutes at issue did not exceed the scope of his constitutional authority. View "Homan v. Branstad" on Justia Law

Kelli Jo Griffin was convicted for the crime of delivery of a controlled substance. Griffin later registered to vote and cast a provision ballot in a municipal election. The county auditor concluded that Griffin was not eligible to vote due to her felony conviction and rejected her ballot. Griffin filed a petition asking the district court to declare that her felony conviction did not disqualify her from voting under the Iowa Constitution. The district court denied relief. At issue on appeal was whether the felony crime of delivery of a controlled substance is an “infamous crime” under the voter disqualification provision of the Iowa Constitution. The Supreme Court affirmed, holding that the Constitution permits persons convicted of a felony to be disqualified from voting in Iowa until pardoned or otherwise restored to the rights of citizenship. View "Griffin v. Pate" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The court of appeals reversed, concluding (1) the State violated Appellant’s Sixth Amendment right to counsel by acquiring incriminating evidence through a jailhouse informant when Defendant was represented by counsel, and the error was not harmless; and (2) the trial court’s instructions on aiding and abetting and joint criminal conduct were not supported by substantial evidence. The Supreme Court affirmed in part and vacated in part the court of appeals’ decision and reversed in part the trial court’s judgment, holding that the trial court erred in overruling Defendant’s motion to suppress as to one of the jailhouse informants. View "State v. Marshall" on Justia Law

Defendant was detained at the police station for suspicion of drunk driving but was not yet formally charged when he made a phone call with a lawyer to get advice regarding the implied-consent procedure and his decision whether to refuse a breathalyzer test. The arresting officer was present during Defendant’s phone call, which was allowed under Iowa Code 804.20. Defendant’s lawyer did not arrive in time, and Defendant submitted to the test. Defendant was subsequently charged with operating a motor vehicle while intoxicated. Defendant filed a motion to suppress the test result, arguing that he was entitled to a private phone consultation with counsel before chemical testing was conducted. The district court denied the motion, and Defendant was convicted as charged. The Supreme Court affirmed, holding (1) the right to counsel under the Iowa and United States Constitutions does not attach until formal criminal charges are filed; and (2) Defendant’s right to counsel had not attached at the time Defendant was asked to submit to the chemical breath test, and therefore, Defendant’s constitutional right to counsel was not violated. View "State v. Senn" on Justia Law

Appellant, a high school football player, was charged with possession of a firearm as a felon, carrying a weapon on school grounds, carrying a weapon, and possession of a controlled substance after the school superintendent searched Appellant’s school-issued equipment bag. The superintendent was moving the bag to the floor when he heard a “metallic sound.” Appellant filed a motion to suppress the evidence found in the bag. The district court denied the motion to suppress, concluding that, under New Jersey v. T.L.O., the search was justified at its inception and the scope of the search was reasonable. The Supreme Court affirmed, holding that the search fell within the general parameters of reasonableness as outlined in T.L.O. View "State v. Lindsey" on Justia Law

Defendant was charged with one count of driving while barred and one count of prostitution. Defendant filed a motion to dismiss, asserting that the state failed to try her case within ninety days of filing the trial information. After a hearing, the district court ruled that Defendant waived speedy trial. The trial court subsequently found Defendant guilty. Defendant appealed, arguing that the State failed to bring her to trial within the speedy trial deadline, that she did not waive her speedy trial rights, that there was not good cause for the delay, and that she timely asserted her speedy trial rights. The Supreme Court reversed, holding (1) the State did not meet its burden of showing good cause for the delay; and (2) the State did not meet its burden in showing that Defendant waived her right to a speedy trial. Remanded for dismissal of all charges. View "State v. Taylor" on Justia Law

After a jury trial, Defendant was found guilty of involuntary manslaughter by commission of public offense and child endangerment resulting in death. The trial court merged the sentences for the charges under the one-homicide rule and imposed a mandatory indeterminate fifty-year sentence. The court of appeals affirmed. The Supreme Court affirmed in part and vacated in part the decision of the court of appeals, holding (1) the district court did not err in denying Defendant’s motion to suppress; but (2) trial counsel was ineffective for failing to move for a judgment of acquittal on the child endangerment conviction under the theory that Defendant used unreasonable force that resulted in bodily injuries to the victim. Remanded for a new trial. View "State v. Schlitter" on Justia Law

David Taft, Jr. was convicted in 1987 for lascivious acts with a minor. He received one two-year and two five-year sentences. The sentences were ordered to be served concurrently. Taft was discharged in 1991. He was arrested for reoffending one week later with two more children. He was convicted and served a sentence of incarceration until discharged on January 10, 2005. On March 30, 2005, district court proceedings were initiated to commit Taft as a sexually violent predator under the Commitment of Sexually Violent Predators Act, Iowa Code chapter 229A (2005). The jury found Taft suffered from a mental abnormality that made it more likely than not that he would reoffend. Taft was committed to the Civil Commitment Unit for Sexual Offenders (CCUSO). In this case, the issue presented for the Iowa Supreme Court's review was the constitutionality of statutory conditions on the suitability of a civilly committed sexually violent predator for the transitional release program. As part of an annual review, the district court denied a final hearing for discharge or suitability for placement in a transitional release program to Taft based in part on his failure to fulfill statutory criteria for a finding of suitability for a transitional release program. Taft challenged two of the criteria as violating his due process rights and denying him equal protection under the Iowa and United States Constitutions. The Supreme Court concluded the issues were not ripe for consideration under the posture of this case. Therefore the Court affirmed the district court's order. View "Taft v. District Court" on Justia Law

In 2012, seventeen-year-old appellant Isaiah Sweet shot and killed Richard and Janet Sweet. Richard and Janet had cared for Sweet since he was four years old, as his biological mother was unable to do. Richard was Sweet’s biological grandfather. Richard and Janet had been married for thirty years. Sweet was arrested three days after the murder. After being given Miranda warnings, Sweet described events leading to the murders, the details of the murders themselves, and his activities in the days after the murders. Sweet was charged and convicted on first-degree murder charges. While his maturity was debatable, the district court stressed that the crimes were premeditated. The district court felt that Sweet's proffered expert's characterization of Sweet’s possibility of rehabilitation as "mixed" was overly optimistic. Further, the district court found Sweet’s case was the rare case in which a sentence of life without the possibility of parole was warranted, as the murders were horrific and showed utter lack of humanity. The district court concluded that Sweet was currently, and will continue to be, a threat to society and that the interests of justice and community safety outweighed mitigating factors. Sweet was sentenced to life without the possibility of parole. The Supreme Court reversed and remanded for resentencing, finding that a sentence of life without the possibility of parole for a juvenile offender violated article I, section 17 of the Iowa Constitution. View "Iowa v. Sweet" on Justia Law