Justia Iowa Supreme Court Opinion Summaries

At issue in this appeal was the constitutionality of the statutory framework under which Iowa taxes the delivery of natural gas at variable tax rates depending on volume and the taxpayer’s geographic location within the state. Plaintiff filed with the Iowa Department of Revenue a claim for a refund of replacement tax Plaintiff paid for certain tax years, asserting that the replacement tax in Iowa Code 437A.5(2) violates the federal Equal Protection Clause, Iowa Const. art. I, 6, and the dormant Commerce Clause because it is based on the natural gas competitive service area in which a taxpayer is located. An administrative law judge denied Plaintiff’s refund claims and rejected the constitutional challenges to the replacement tax. The district court also denied each of Plaintiff’s constitutional challenges. The Supreme Court affirmed, holding (1) a rational basis exists for the variable excise tax imposed on the delivery of natural gas under section 437A.5, and therefore, Plaintiff failed to establish a violation of the Fourteenth Amendment or Iowa Const. art. I, 6; and (2) the natural gas delivery tax framework does not violate the dormant Commerce Clause. View "LSCP, LLLP v. Kay-Decker" on Justia Law

Defendant was charged with theft in the third degree based on her current crime and two prior theft convictions. Defendant moved to strike her 2003 conviction of theft in the third degree as a basis to support the charge of third-degree theft, asserting that the conviction was constitutionally infirm because she was not represented by counsel when she pled guilty and served a term of incarceration. In fact, Defendant was held in jail for one day prior to her initial appearance and then, upon pleading guilty, was sentenced to one day in jail, with credit for time served. The district court denied the motion, concluding that Defendant’s situation was not one in which she faced the possibility of imprisonment requiring the appointment of counsel. Defendant was subsequently found guilty of theft in the third degree. The Supreme Court reversed, holding (1) under the right to counsel provision under Iowa Const. art. I, 10, a misdemeanor defendant has a right to counsel when the defendant faces the possibility of imprisonment; and (2) because Defendant was not provided the assistance of counsel and the State stipulated there was not a valid waiver, the 2003 misdemeanor conviction could not be used as a predicate offense to enhance a later punishment. Remanded. View "State v. Young" on Justia Law

In 2001, Calvin Matlock was confined to the Civil Commitment Unit for Sexual Offenders (CCUSO). In 2013, the district court found the State failed to meet its burden to prove Matlock’s mental abnormality made him likely to engage in predatory acts that constitute sexually violent offenses if discharged. The court then ordered Matlock released with supervision. Matlock appealed, arguing that, once the court found he no suffered from a mental abnormality that made him likely to engage in acts of sexual violence, release with supervision violated his due process rights. The Supreme Court (1) affirmed the part of the district court judgment releasing Matlock with supervision, holding the statutory scheme found in Iowa Code 299A did not violate the Due Process Clauses of the state or federal Constitutions so long as Matlock continued to suffer from a mental abnormality and the testimony supports the need for supervision upon release; but (2) remanded for a determination that the State proved the terms of supervision were consistent with due process principles, holding that the record was insufficient for the Court to determine whether the specific release conditions ordered by the district court comported with Matlock’s due process rights. View "In re Detention of Matlock" on Justia Law

After the State withdrew its first plea offer and proposed a second, less favorable plea offer, Defendant accepted the second plea offer and pleaded guilty to second-degree burglary and assault with intent to commit sexual abuse not resulting in injury. The district court imposed an indeterminate term of imprisonment not to exceed fourteen years. Defendant filed this petition for postconviction relief asserting several claims of ineffective assistance of counsel. Specifically, Defendant claimed that he received ineffective assistance as a result of counsel’s failure to accurately inform him of the terms and potential sentencing outcomes of the State’s first plea offer. The district court denied the petition on all grounds. The Supreme Court affirmed, holding (1) counsel may have failed to perform an essential duty when he did not accurately inform Defendant of the exact terms and sentencing outcomes of the first plea offer, but (2) because Defendant did not show he would have accepted the first plea offer had counsel accurately informed him of its exact terms and potential sentencing outcomes, Defendant failed to establish the necessary prejudice to succeed on his ineffective assistance of counsel claim. View "Dempsey v. State" on Justia Law

The Iowa Department of Economic Development (IDED) and Ghost Player, LLC executed a contract for tax credits under which Ghost Player believed it would receive certain tax credits for a documentary film it produced. CH Investors, LLC was a third-party beneficiary to the contract. The IDED declined to issue the contracted tax credit for some of the investments and expenditures of Ghost Player. Ghost Player and CH Investors subsequently filed a breach of contract action against the IDED. The district court dismissed the action on the grounds that Ghost Player failed to exhaust its remedies under the Iowa Administrative Procedure Act. The Supreme Court affirmed, holding that the district court (1) was without authority to hear the case because the IDED actions in this case required Ghost Player to exhaust its administrative remedies prior to filing a case in district court; and (2) correctly found the process used by the IDED in processing the claim did not offend due process principles under the State or the Federal Constitutions. View "Ghost Player, LLC v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of sexual abuse in the second degree and one count of lascivious acts with a child. Defendant appealed, arguing, among other things, that trial counsel was ineffective in failing to object to a lascivious-acts jury instruction that he claimed was not supported by sufficient evidence. The court of appeals affirmed. The Supreme Court addressed only Defendant’s claim regarding counsel’s response to the lascivious-acts instruction and let the court of appeals’ affirmance on the remaining issues stand as the final decision of the Court. The Supreme Court affirmed, holding that Defendant failed to establish that he suffered prejudice as a result of counsel’s failure to object to the lascivious-acts instruction, and therefore, his ineffective-assistance-of-counsel claim must fail. View "State v. Thorndike" on Justia Law

In 2011, the City of Sioux City enacted an automatic traffic enforcement (ATE) ordinance. In 2012, a vehicle registered to Appellant was detected by ATE equipment traveling at an excessive speed. As a result, the City issued a citation to Appellant. Appellant moved to dismiss the citation on constitutional grounds, claiming enforcement of the ordinance violated the due process clauses of the Iowa and U.S. Constitutions, the inalienable rights clause of the Iowa Constitution, and the Iowa municipal home rule amendment. The magistrate entered an order finding Defendant liable for the violation. The district court affirmed. The Supreme Court affirmed, holding that the ATE ordinance is not unconstitutional. View "City of Sioux City v. Jacobsma" on Justia Law

After a jury trial, Defendant was convicted of domestic abuse assault causing bodily injury. The Supreme Court vacated the judgment of the court of appeals and affirmed, holding (1) trial counsel was not ineffective in failing to object on Confrontation Clause grounds to the testimony of a law enforcement officer regarding the complaining witness’s out-of-court statements; and (2) the record was insufficient to determine whether trial counsel should have objected to and move to strike as hearsay the officer’s unsolicited testimony regarding another witness’s out-of-court statement. View "State v. Tomkins" on Justia Law

After a jury trial, Defendant was found guilty of first-degree arson. On appeal, Defendant requested a judgment of acquittal or, alternatively, a new trial, claiming that the evidence was insufficient to support the conviction and that his pretrial counsel operated under a conflict of interest due to his representation of a prosecution witness. The court of appeals reversed, holding that Defendant’s pretrial counsel’s conflict of interest required reversal of Defendant’s conviction. The Supreme Court vacated the decision of the court of appeals and affirmed the district court’s judgment of conviction and sentence, holding that, where the district court replaced the conflicted defense attorney with a conflict-free attorney more than three months before trial, and there was no showing that the previous conflict had ongoing adverse effects on the representation, a new trial was not required. View "State v. Vaughan" on Justia Law

Plaintiff, individually, and on behalf of her children, sued two physicians for medical malpractice. During the ensuing trial, one of the jurors fainted while she was sitting in her chair in the jury box. One of the defendant physicians immediately rose to assist the juror, after which the juror recovered and was excused. Plaintiffs moved for a mistrial, which the trial court denied. The jury subsequently returned verdicts for the physicians. The court of appeals reversed and ordered a new trial as to both physicians. The physician who did not help the ailing juror sought further review. The Supreme Court reversed the court of appeals as to the appellant, holding that the district court did not abuse its discretion when it allowed the jury verdict to stand as to the physician who had not rendered medical assistance because nothing in that physician’s behavior during the incident could have “engendered any particular good will in her favor.” Remanded. View "Jack v. Booth" on Justia Law