Justia Iowa Supreme Court Opinion Summaries

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

At issue here was sex offenders serving prison time on a "revocation of release" from a "special sentence" under Iowa Code 903B.2 and whether the maximum time incarcerated was reduced by "earned-time credit" or "jail-time credit." Kris Kolzow began serving his ten-year special sentence released on parole. A parole violation prompted his detention for five and one-half months awaiting a parole-revocation hearing. The administrative parole judge ordered Kolzow to prison "to serve a period not greater than two years" as required by section 903B.2. The Iowa Department of Corrections (IDOC) refused to shorten Kolzow's prison time with earned-time credit or jail-time credit. The district court ruled that both credits applied to reduce the maximum two-year period served in prison on the revocation of release. The Supreme Court affirmed the ruling awarding Kolzow jail-time credit and reversed the ruling awarding him earned-time credit, holding (1) IDOC need not apply earned-time credit to shorten the period incarcerated on a revocation of release; and (2) an offender serving a special sentence under section 903B.2 is entitled to jail-time credit against the maximum periods for revocation of release for each day he is detained awaiting his parole-revocation hearing. View "Kolzow v. State" on Justia Law

Roger Ennenga was arrested for failing to stop his vehicle when police attempted to pull him over and for possession of methamphetamine. The State failed to file a trial information within forty-five days, and Ennenga's counsel did not file a motion to dismiss. Thereafter, Ennenga's counsel allowed him to plead guilty. At issue before the Supreme Court on Ennenga's application for postconviction relief was whether an indictment must be filed in order to be "found" for the purposes of Iowa R. Crim. P. 2.33, which requires the court to dismiss a prosecution if an indictment or trial information is not "found" within forty-five days of the defendant's arrest, and whether failing to ensure an indictment is timely filed amounts to the breach of an essential duty by an accused's counsel. The Court reversed the district court, holding that counsel breached an essential duty in failing to file a motion to dismiss the untimely trial information, and that counsel's failure resulted in prejudice to Ennenga by his plea of guilty. Remanded. View "Ennenga v. State" on Justia Law

After a jury trial, Defendant Kenneth Madsen was convicted of two counts of sexual abuse in the second degree and one count of lascivious acts with a child. Madsen appealed, arguing (1) the district court erred in failing to suppress his confessions because his confessions were involuntary under the constitutional totality-of-the-circumstances test due to the detective's threat to make him late for work and promise that if Madsen confessed he could keep his name out of the newspaper and put the matter behind him; and (2) his counsel was ineffective for not attempting to suppress his confession under the common law evidentiary test for promises of leniency. The Supreme Court affirmed in part and reversed in part, holding (1) Madsen's trial counsel breached an essential duty by failing to move to suppress Madsen's confessions under the evidentiary test; (2) the interrogating officer made promises of leniency that required suppression of part of Madsen's confession, but Madsen's self-incriminating statements made before those promises remained admissible; and (3) Madsen was entitled to a new trial on one count of second-degree sexual abuse, but his two remaining convictions were affirmed based on lack of prejudice. View "State v. Madsen" on Justia Law

Plaintiffs, students or parents of students who attended Iowa public schools, filed a petition contending that Iowa's educational system was inadequate and urging the courts to impose additional public school standards, stating that such action was both constitutionally and statutorily required. Plaintiffs named as defendants the State, Governor, Department of Education, and Director of the Department. The district court dismissed Plaintiffs' petition, concluding (1) Plaintiffs had stated claims for relief under the equal protection and due process clauses, but their constitutional claims presented a nonjusticiable political question; and (2) their statutory claim under Iowa Code 256.37 failed because that provision did not afford a private right of action. The Supreme Court affirmed, holding (1) Plaintiffs' challenges were properly directed to Plaintiffs' elected representatives, rather than the courts; but (2) Plaintiffs did not state claims for relief under the Iowa Constitution or section 256.37. View "King v. State" on Justia Law

Defendant Anthony Polk confessed in a jailhouse interview to firing his handgun at the scene of a gang-related shooting that left two men with gunshot wounds. Polk filed a motion to suppress his conviction, contending that the interrogating police officer baited him into talking after Polk had invoked his Fifth Amendment right to remain silent and made improper promises of leniency that suggested by talking to police Polk could get a better deal and spend less time away from his children. The district court denied Polk's motion and convicted Polk of several weapon-related crimes. The Supreme Court reversed Polk's convictions and sentences, holding that the interrogating officer's promises of leniency rendered Polk's confession inadmissible, and therefore, the district court erred in denying Polk's motion to suppress. View "State v. Polk" on Justia Law

Petitioner, a juvenile offender whom the State tried as an adult, brought a postconviction relief action claiming that his conviction for first-degree murder should be overturned and that his sentence was illegal because it amounted to cruel and unusual punishment under the state and federal Constitutions. The district court dismissed both claims. The court of appeals affirmed, holding that Petitioner made the same claims in the past, and thus, the law of the case doctrine precluded the court from revisiting them. The Supreme Court vacated the decision of the court of appeals and reversed in part the judgment of the district court, holding (1) the law of the case doctrine precluded Petitioner from attacking his conviction for first-degree murder; but (2) the doctrine did not preclude Petitioner from attacking his sentence as illegal because the controlling authority regarding cruel and unusual punishment had changed since his original appeal regarding the issue, and the three-year limitation period for bringing a postconviction relief action did not prohibit a challenge to an illegal sentence. Remanded. View "State v. Ragland" on Justia Law