Justia Iowa Supreme Court Opinion Summaries

Defendant was charged with and found guilty of driving under revocation. Defendant appealed, arguing that the district court’s admission of a certified abstract of his driving record and affidavits of the mailing of suspension notices violated his rights under the Confrontation Clauses of the United States and Iowa Constitutions. The court of appeals concluded that the admission of the disputed documents did not violate the Confrontation Clauses. The Supreme Court affirmed, holding (1) the admission of the certified abstract of Defendant’s driving record did not violate the Confrontation Clauses; and (2) the admission of the affidavits of the mailing of suspension notices violated the Confrontation Clauses, but their admission into evidence was harmless error. View "State v. Kennedy" on Justia Law

Plaintiff filed suit against the Defendants, county and municipal officials, alleging that he was wrongfully assaulted and arrested by certain law enforcement officers and deputies. The district court concluded that Defendants were entitled to immunity because they were acting on behalf of the state in an official capacity and that the Iowa Tort Claims Act (ITCA) barred Plaintiff's claims for assault, battery, false arrest, and malicious prosecution. The Supreme Court reversed, holding that any immunity conferred by the ITCA did not protect Defendants from being sued under the Iowa Municipal Tort Claims Act (IMTCA), which applies to political subdivisions and their employees, and that the IMTCA does not bar claims for assault, battery, false arrest, and malicious prosecution. Remanded.View "Thomas v. Gavin" on Justia Law

Police officers stopped Defendant’s vehicle after discovering that the vehicle’s license plate frame covered up the county name on the license plate, which the officers believed violated Iowa Code 321.37(3). As a result of the stop, Defendant was charged with possession with intent to deliver crack cocaine, a drug tax stamp violation, and driving under suspension. A district court judge denied Defendant’s motion to suppress, concluding that the license plate frame violation gave no reason to stop Defendant but that the stop was lawful based on a reasonable suspicion of drug dealing. A different judge who presided at trial upheld the stop based on the license plate violation alone. After a jury trial, Defendant was found guilty as charged. The court of appeals affirmed, which held that the traffic stop was lawful based on reasonable suspicion of drug dealing without deciding the license plate issue. The Supreme Court affirmed the conviction without reaching the issue of whether the traffic stop was lawful based on reasonable suspicion of drug dealing, holding that a license plate frame that covers up the county name violates Iowa Code 321.37(3) and provides a valid basis for a traffic stop. View "State v. Harrison" on Justia Law

After taking self-care leave under the Family and Medical Leave Act (FMLA), Plaintiff was terminated from her employment with the State. A jury found the State terminated Plaintiff in violation of her rights under the FMLA. The district court awarded Plaintiff money damages and ordered the State to reinstate Plaintiff to her former position. The State appealed and successfully requested a stay of Plaintiff’s reinstatement pending the outcome of the appeal. The Supreme Court subsequently held that sovereign immunity precluded Plaintiff’s judgment for money damages against the State. On remand, the district court once again ordered Plaintiff reinstated and awarded lost wages and benefits from the date of the original reinstatement order, concluding that the State had waived its sovereign immunity by seeking a stay of the reinstatement order and promising to pay Plaintiff’s interim wages and benefits if the Court affirmed the original order. The Supreme Court affirmed, holding (1) Plaintiff’s pleadings were sufficient to preserve her right to Ex parte Young remedies, and the parties litigated the reinstatement remedy by consent; and (2) the Eleventh Amendment to the U.S. Constitution does not bar an award of wages and benefits for the period during which a reinstatement order was stayed. View "Lee v. State" on Justia Law

After a jury trial, Defendant was convicted of voluntary manslaughter and five counts of intimidation with a dangerous weapon with intent. The Supreme Court vacated Defendant’s convictions on three counts of intimidation with a dangerous weapon with intent and affirmed his remaining convictions, holding (1) trial counsel was ineffective for failing to move for a judgment of acquittal after the verdict on the intimidation counts because the evidence did not support the verdicts that Defendant committed five separate and distinct acts of intimidation with a dangerous weapon with intent; (2) however, substantial evidence supported two separate and distinct crimes of intimidation with a dangerous weapon with intent; (3) the record was inadequate to decide Defendant’s separate allegation of ineffective assistance of counsel; and (4) the district court did not abuse its discretion in failing to admit certain photographs into evidence. Remanded. View "State v. Ross" on Justia Law

Plaintiff was terminated from his employment as dean of students and vice president of student services at the University of Iowa by the University's president, Sally Mason, after a report from the Stolar Partnership (Stolar), a law firm retained by the Board of Regents (Regents) to investigate the University's response to a sexual assault of a student athlete by other student athletes, came out highly critical of Plaintiff. Plaintiff sued the University, Mason, the Regents, and Stolar for wrongful termination and related causes of action. The district court granted summary judgment for Defendants on all claims. The Supreme Court affirmed, holding that the district court did not err (1) in denying Plaintiff's motion to compel discovery of written communications between Stolar and the Regents based on its finding that the attorney-client privilege protected the communications from disclosure; and (2) in granting summary judgment to Defendants on Plaintiff's various claims.View "Jones v. Univ. of Iowa" on Justia Law

After a jury trial, Defendant was convicted of six counts of child endangerment and sentenced to fifty years in prison. The victim was Defendant's seven-week-old son. The baby suffered fifteen rib fractures, a broken arm, and a permanent brain injury over a three-week period. The victim's mother (Mother) pled guilty to child endangerment. On appeal, the Supreme Court (1) vacated Defendant's convictions as to two counts for the baby's broken ribs, holding that the evidence was insufficient to sustain the convictions; (2) reversed the trial court's denial of Defendant's motion for an in camera review of Mother's mental health records under Iowa Code 622.10(4), a statute the Court upheld as constitutional; and (3) otherwise affirmed. View "State v. Neiderbach" on Justia Law

After a jury trial, Defendant was convicted of the second-degree murder of his live-in girlfriend. The Supreme Court affirmed, holding that the district court did not reversibly err by (1) failing to submit an instruction on the lesser included offense of voluntary manslaughter, as the evidence of provocation was insufficient to support admission; (2) excluding hearsay evidence relevant to Defendant's diminished-capacity defense based on his posttraumatic stress disorder, as Defendant failed to lay a foundation supporting any exception to the hearsay rule; (3) declining to obtain and review the victim's mental health records for exculpatory information; and (4) denying Defendant's motion for a new trial. View "State v. Thompson" on Justia Law

Following a jury trial, Defendant, a juvenile, was convicted of first-degree murder and mandatorily sentenced to life without parole. Defendant subsequently pursued numerous postconviction relief actions, including an application to correct his sentence. After the Supreme Court remanded the case to the district court to consider the constitutionality of Defendant's sentence, the U.S. Supreme Court decided Miller v. Alabama, which held that the constitution prohibited a sentencing scheme mandating life in prison without possibility of parole for juvenile offenders. Before Defendant's hearing, the Governor commuted Defendant's sentence to life with no possibility for parole for sixty years. At the hearing before the district court, Defendant argued he should still be resentenced under Miller. The district court (1) concluded that the Governor exceeded his authority by commuting Defendant's sentence because the commutation circumvented the individualized sentencing required under Miller, and (2) resentenced Defendant to life in prison with the possibility of parole after twenty-five years. The Supreme Court affirmed, holding (1) Defendant's commuted sentence still amounted to cruel and unusual punishment; and (2) consequently, the district court properly resentenced Defendant in light of Miller.View "State v. Ragland" on Justia Law

After a jury trial, seventeen-year-old Defendant was convicted of two counts of first-degree robbery and two counts of first-degree burglary. The district court imposed a fifty-year sentence, of which Defendant was required to serve thirty-five years, at which point she would become eligible for parole. The Supreme Court vacated Defendant's sentence, holding (1) Defendant's sentence of a minimum of thirty-five years without the possibility of parole for the crimes involved in this case violated the core teachings of Miller v. Alabama; and (2) an individualized sentencing hearing was required in this case. Remanded. View "State v. Pearson" on Justia Law