Justia Iowa Supreme Court Opinion Summaries

Defendant was charged with operating while intoxicated, first offense. Defendant moved to suppress the evidence against her, arguing that the stop of her vehicle was made without probable cause or reasonable suspicion and that the implied consent statute was violated when the transporting deputy failed to administer a blood or urine test instead of insisting on a breath test after acquiring reasonable grounds to believe Defendant was impaired by a prescription drug. The district court overruled the motions to suppress and found Defendant guilty of the charge. The Supreme Court affirmed, holding (1) the investigatory stop of the vehicle did not violate the Fourth Amendment to the United States Constitution or Iowa Const. art. I, VIII; and (2) the legislature did not intend for the implied consent law to mandate a blood or urine test under the circumstances of this case but only intended to impose the implied consent penalty of license revocation for drivers suspected of driving under the influence of drugs other than alcohol who refuse to submit to a urine or blood test when requested by a law enforcement officer. View "State v. McIver" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree and other criminal offenses. The Supreme Court affirmed, holding (1) Defendant failed to preserve for appeal his argument that an instruction given to the jury that it may not consider a lesser offense unless it unanimously found Defendant not guilty of the greater offense was a misstatement of the law; (2) certain instructions concerning the various inferences and conclusions the jury was permitted to draw did not constitute reversible error; and (3) Defendant was not denied effective assistance of counsel for failing to argue that the contested instructions were improper. View "State v. Ambrose" on Justia Law

Defendant was in custody of a residential facility commonly referred to as a halfway house when he was charged with knowingly possessing marijuana on the grounds of a facility “under the management of the department of corrections” pursuant to Iowa Code 719.7(3)(c). After a jury trial, Defendant was convicted. Defendant appealed, arguing that his trial counsel provided ineffective assistance for specifically failing to assert that the evidence was insufficient to establish that the residential facility was an institution under the management of the Department of Corrections (Department). The Supreme Court reversed, holding that defense counsel was ineffective as a result of his failure to assert that there was insufficient evidence to show the residential facility was an institution under the management of the Department, and Defendant was prejudiced by the failure to his counsel to assert the claim. View "State v. Halverson" on Justia Law

Defendant was charged with four counts of unintentionally causing serious injury by intoxicated use of a motor vehicle. Before trial, the State moved to allow three out-of-state victims of the car accident and three lab analysts employed by the State to testify remotely via two-way videoconferencing technology rather than physically appearing in court. After a hearing, the district court granted the State’s motion for distance testimony. Defendant appealed, arguing that the trial court’s decision to permit the State’s witnesses to testify remotely violated his Sixth Amendment right to be confronted with the witnesses against him. The Supreme Court reversed, holding (1) before permitting a witness to testify via two-way videoconference, a court must make a case-specific determination that the denial of the defendant’s confrontation right is necessary to further an important public interest; and (2) applying this standard to the instant case, the district court erred in allowing the videoconference testimony. View "State v. Rogerson" on Justia Law

The State charged Defendant, a probationer, with burglary and theft after police officers conducted a warrantless search of Defendant’s home. Defendant filed a motion to suppress contending that the search warrant was invalid because it inaccurately described the house to be searched and because an alteration of the warrant based upon a verbal conversation with the issuing judge violated the statutory requirement that search warrant applications be in writing. The district court overruled the motion to suppress, concluding that the search warrant was inadequate but that the warrant was valid because the search was within the contemplation of the probation agreement. The court of appeals affirmed, concluding that the search of the probationer based upon reasonable suspicion of criminal activity and based upon the limited scope of the search was valid under the search and seizure provision of Iowa Const. art I, 8. The Supreme Court reversed, holding that, in accordance with State v. Cullison, the search of Defendant’s home by general law enforcement authorities was unlawful under the Iowa Constitution because the search was based on an invalid warrant. View "State v. Short" on Justia Law

When he was seventeen years old, Appellant committed the crime of first-degree robbery. Appellant was sentenced to a term of imprisonment not to exceed twenty-five years. Appellant was sentenced under a statute that required him to serve at least seventy percent of his sentence before he was eligible for parole. Appellant appealed, arguing that his sentence constituted cruel and unusual punishment. The Supreme Court vacated the sentence and remanded to the district court for resentencing, holding that, for the reasons express in State v. Lyle, filed on this same date, the mandatory sentence violated the prohibition against cruel and unusual punishment under the Iowa Constitution. View "State v. Taylor" on Justia Law

Appellant was a seventeen-year-old high school student when he took a small plastic bag containing marijuana from a fellow student outside the high school. After a jury trial, Appellant was convicted of robbery in the second degree. Appellant was prosecuted as an adult and was sentenced under a statute that required the imposition of a mandatory seven-year minimum sentence of imprisonment. Appellant appealed, arguing that the mandatory minimum was unconstitutional as applied to him. During the pendency of the appeal, the United States decided Miller v. Alabama. The court of appeals affirmed the sentence. The Supreme Court granted review to consider whether Appellant’s sentence was constitutional in light of the cases the Court handed down subsequent to Miller. The Supreme Court vacated the sentence and remanded for resentencing, holding that a statute mandating a sentence of incarceration in a prison for juvenile offenders with no opportunity for parole until a minimum period of time has been served is unconstitutional under the Iowa Constitution. View "State v. Lyle" on Justia Law

Plaintiffs, fourteen African-Americans, brought a class action suit against the State, including thirty-seven different executive branch departments, under the Federal Civil Rights Act and the Iowa Civil Rights Act. In their complaint, Plaintiffs alleged that the State unlawfully discriminates against African Americans in employment. The district court entered judgment in favor of the State. The Supreme Court affirmed, holding that Plaintiffs did not meet their burden of establishing that the underlying documents did not provide sufficient information to allow employment practices to be separated for meaningful statistical analysis, and therefore, Defendant was entitled to summary judgment under the Iowa Civil Rights Act.View "Pippen v. State" on Justia Law

Aaron Cannon, a student at Palmer College of Chiropractic, was blind and requested that Palmer make accommodations for his visual disability. Palmer denied the request, explaining that it could not provide the proposed accommodations and curricular modifications because they would fundamentally alter its educational program. Cannon eventually withdrew from the program. Cannon filed a complaint with the Davenport Civil Rights Commission, arguing that Palmer had discriminated against him on the basis of his disability. The Commission granted relief, finding that Palmer had failed to comply with the applicable federal and state disability laws. The district court reversed. The Supreme Court reversed, holding that the Commission did not erroneously interpret or irrationally apply the applicable law in concluding that Palmer failed to establish that Cannon’s suggested accommodations would fundamentally alter its curriculum. View "Palmer College of Chiropractic v. Davenport Civil Rights Comm’n" on Justia Law

John Goodpaster worked as a customer service manager for Schwan’s Home Service, Inc., the largest home delivery frozen foods company in the nation, at Schwan’s Des Moines location. Goodpaster’s duty was to sell and deliver company products, and a basic requirement of Goodpaster’s job was that he drive a commercial vehicle. When Goodpaster began experiencing medical problems, his sales began to decrease, and he was eventually terminated. Goodpaster sued Schwan’s under the Iowa Civil Rights Act (ICRA) for disability discrimination and retaliation, claiming his employment was terminated because he had multiple sclerosis. The district court granted summary judgment in favor of Schwan’s. The Supreme Court reversed, holding (1) multiple sclerosis is a disability contemplated by the ICRA; and (2) a genuine issue of material fact existed regarding whether Goodpaster was qualified to perform the essential functions of his position. Remanded. View "Goodpaster v. Schwan’s Home Serv., Inc." on Justia Law