Justia Iowa Supreme Court Opinion Summaries

Following his sentencing to consecutive prison terms totaling thirty-five years, Defendant asked the Supreme Court to review the district court's determinations that the written entry of the verdict was proper, that a fork is a dangerous weapon, and that the State did not commit a Brady violation or fail to disclose newly discovered evidence, among others. The court of appeals affirmed. The Supreme Court affirmed in part and vacated in part the court of appeals, holding (1) the State did not commit a Brady violation; and (2) Iowa R. Crim. P. 2.17(2) requires a trial court to announce the verdict in a recorded proceeding in open court following a bench trial, and the district court in this case erred by not announcing the verdict in a recorded proceeding in open court. The Court found, however, that the district court cured its error and substantially complied with Rule 2.17(2) such that no remand was required. View "State v. Jones" on Justia Law

Defendant Dontay Sanford was convicted for first-degree burglary for entering the car of a victim who later died from injuries received during the encounter. Sanford was sentenced to an indeterminate term in prison not to exceed twenty-five years. Sanford appealed, claiming there was insufficient evidence that the victim's automobile was an "occupied structure," which is one of the elements of burglary. The Supreme Court affirmed the conviction, holding (1) the State produced sufficient evidence that the victim's vehicle, under the facts of this case, was an occupied structure as that term is defined under the burglary statute; and (2) Sanford's pro se claims on appeal failed. View "State v. Sanford" on Justia Law

A juvenile court terminated Father's parental rights to his two children. Father appealed, arguing, among other things, that the juvenile court violated his due process rights when it ordered him to provide a fingernail drug test after his termination trial. The court of appeals reversed, principally on the basis that there was no evidence in the record as to the reliability or the accuracy of the fingernail drug test, and that the record, including the fingernail test, lacked clear and convincing evidence to warrant termination of Father's parental rights. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment and order of the trial court, holding (1) the test did not violate Father's due process rights; (2) the evidence including the fingernail test was sufficient to warrant termination; and (3) termination was in the children's best interests. View "In re A.B." on Justia Law

After the State filed a child in need of assistance (CINA) petition, the juvenile court issued a temporary removal order removing Child from Mother's custody and placing her in foster care. Once the CINA proceeding was dismissed, Mother sued the State and two employees of the Iowa Department of Human Services (DHS) under 42 U.S.C. 1983 and the Iowa Tort Claims Act (ITCA), alleging the DHS social workers wrongfully removed Child from her custody and negligently failed to protect Child from abuse. The district court granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding (1) a social worker is entitled to absolute immunity when the social worker functions in the role of a prosecutor or ordinary witness; (2) a social worker is entitled to qualified immunity when acting in the role of a complaining witness, and for his or her investigatory acts; (3) alleged injured parties cannot maintain an action against a social worker under the ITCA where the alleged parties fail to exhaust the available administrative remedy prior to filing an action in court and where the basis of the complaint is that the social worker engaged in conduct functionally equivalent to misrepresentation or deceit. View "Minor v. State" on Justia Law

Peter Long was convicted of third-degree sexual abuse. Based on two prior convictions for lascivious acts with a child, the district court found that Long had committed a class A felony and sentenced Long to life in prison without the possibility of parole. Long appealed, claiming the district court abused its discretion when it allowed the State to reopen the record after the State had rested and after the defense had made a motion for judgment of acquittal during the enhancement trial. The court of appeals vacated the judgment and remanded the case to the district court to render a verdict on the enhancement based solely on the evidence introduced prior to the reopening of the record. The Supreme Court vacated the court of appeals and affirmed the district court, holding that the district court did not abuse its discretion in reopening the record under the circumstances of this case. View "State v. Long" on Justia Law

Donald Clark was convicted of sexual abuse in the second degree for molesting a fifth-grade student while employed as a guidance counselor at the elementary school. Clark appealed, arguing that his constitutional rights to a fair trial and due process were violated when the trial court failed to grant his request for a continuance and to allow the retaking of depositions based on the late disclosure of an e-mail written by the student. The Supreme Court affirmed Clark's conviction and sentence, holding that the district court did not violate Clark's constitutional rights or abuse its discretion when it refused to allow redepositions or grant a continuance. View "State v. Clark" on Justia Law

Sergio Perez pled guilty to a misdemeanor drug possession charge in 2000. Perez later filed an application for postconviction relief seeking to have his conviction set aside, claiming that he did not receive advice from his attorney regarding the risk of deportation before pleading guilty. The district court denied the application, and the court of appeals affirmed. At the center of this appeal was the U.S. Supreme Court's decision in Padilla v. Kentucky, which decided a criminal defendant has a right to receive advice from counsel regarding the risk of deportation before pleading guilty. The Supreme Court affirmed, holding (1) if Padilla establishes a new rule of constitutional criminal procedure, it does not apply retroactively, and Perez may not rely upon it to set aside an earlier conviction; and (2) if Padilla is not a new rule, Perez's application is time-barred because he could have filed it within three years of the date when his conviction became final and failed to do so. View "Perez v. State" on Justia Law

At issue in this employment case was whether the State was immune from claims under the self-care provision of the Family and Medical Leave Act (FMLA) in state court. The district court denied the State's posttrial motions for a judgment notwithstanding the verdict or a new trial asserting Eleventh Amendment sovereign immunity after a jury awarded damages to a state employee based on a claim for violating the FMLA. The court of appeals affirmed. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the trial court, holding (1) the cloak of immunity granted to the State precludes state employees from suing the State for monetary relief when denied self-care leave under the FMLA; (2) nevertheless, states are bound to follow the self-care provisions of the FMLA, and state employees who are wrongfully denied self-care leave are still permitted to seek injunctive relief against the responsible state official; and (3) the U.S. Department of Labor may bring actions for damages or an injunction on behalf of an employee against a state for violating the self-care provisions. Remanded. View "Lee v. State" on Justia Law

This case presented the question of whether an officer is justified in activating his emergency lights and blocking a driver into a parking space under the "community caretaking function" exception to the warrant requirement of the Fourth Amendment based solely upon his knowledge that the vehicle has just struck an object in the roadway and suffered minor damage not affecting the drivability of the car. Here the district court denied Defendant driver's motion to suppress the evidence found after the warrantless seizure of Defendant's car, and Defendant was found guilty of OWI. The Supreme Court reversed the district court, concluding that under the circumstances of this case, the community caretaking exception was inapplicable, and the seizure was impermissible. Remanded. View "State v. Kurth" on Justia Law

In this case the Supreme Court considered whether an area education agency (AEA) acted lawfully when it approved for submission to the voters a petition that proposed a consolidation of two community school districts, Preston and East Central. East Central sought to block the measure from being placed before the voters, asserting (1) the AEA approval of the petition for submission to the voters was legally flawed because the AEA failed to comply with a statutory requirement that it develop a plan for the AEA district, and (2) the AEA failed to make a required statutory finding that the consolidation proposed in the petition was in conformity with the plan. The district court rejected the claims. The Supreme Court affirmed, concluding that the AEA acted lawfully in approving submission of the petition to the voters, as (1) the AEA was not required to develop a specific plan of merger between the two school districts prior to approval of submission of a citizen petition to the voters of the districts; and (2) by approving the submission of the issue to the voters, the AEA made an implied finding that all the statutory requisites were met. View "E. Central Cmty. Sch. Dist. v. Miss. Bend Area Educ. Agency" on Justia Law