Justia Iowa Supreme Court Opinion Summaries

In this case, the Supreme Court considered whether an internal audit created by Broadlawns Medical Center as a result of the theft of drugs by an employee was a public record under the Iowa Open Records Act. The district court concluded that, because the internal audit was provided to the Iowa Board of Pharmacy in order to assist in its investigation of licensing matters arising from the theft, the internal audit amounted to investigative materials in the hands of a licensing board under Iowa Code 272C.6(4) and was not subject to disclosure. The Supreme Court (1) reversed the judgment of the district court holding that the internal audit was not subject to disclosure, as the internal pharmacy audit was a public record, not a confidential record, and other statutory exceptions asserted to prevent public disclosure were inapplicable; and (2) affirmed the rulings of the district court that the plaintiff failed to establish the basis for nondisclosure under Iowa Code 22.7(61). View "Hall v. Broadlawns Med. Ctr." on Justia Law

This case was remanded to the district court for determination of whether a class should be certified and for determination of what, if any, part of the City's franchise fees for gas and electricity services are related to its administrative expenses in exercising its police power. The district court certified a class, found the franchise fees cannot exceed $1,575,194 per year for the electric utility and $1,574,046 for the gas utility, entered judgment in favor of the certified class against the City in the amount by which such fees exceeded that amount for an approximately ten-year period, and retained jurisdiction to determine the amount of money to be refunded to members of the class. The Supreme Court affirmed the judgment as modified, concluding that certain amounts allocated or not allocated by the district court as proper components of the franchise fees should be modified. Remanded. View "Kragnes v. City of Des Moines" on Justia Law

Rachel Overbay, the driver of a vehicle, was involved in an accident and transferred to the hospital. A law enforcement officer requested a blood sample from Overbay. Overbay, however, was incorrectly informed that her refusal of the requested chemical test would automatically lead to revocation of her driving privileges. In fact, Overbay's refusal of the blood test would not have been deemed final but would have led to her being offered a different chemical test. Overbay agreed to provide the blood sample, and the results showed a blood alcohol content of more than twice the legal limit. The State subsequently charged Overbay with operating a motor vehicle while under the influence of alcohol. The district court granted Overbay's motion to suppress, finding that Overbay's consent to the blood test was not voluntary because it was based on misleading information. The court of appeals affirmed. The Supreme Court vacated the court of appeals and reversed the district court, holding that consistent with precedent, inaccurate information does not render a driver's consent involuntary when the record indicates that the inaccuracy did not affect the driver's decision. Remanded. View "State v. Overbay" on Justia Law

Members of the Old Order Groffdale Conference Mennonite Church are forbideen from driving tractors unless their wheels are equipped with steel cleats. A Mitchell County road protection ordinance forbade driving such vehicles on the highways. Matthew Zimmerman was cited for operating his tractor in violation of the ordinance. Zimmerman moved to dismiss the citation on the ground that his federal and state constitutional rights to free exercise of religion had been violated. The district court overruled Zimmerman's motion to dismiss, concluding that the ordinance (1) was both neutral and generally applicable, and (2) survived strict scrutiny. The Supreme Court reversed, holding that the ordinance as applied to church members violated the free exercise clause of the First Amendment where the ordinance (1) was not of general applicability because it contained exemptions that were inconsistent with its stated purpose of protecting Mitchell County's roads, and (2) did not survive strict scrutiny because it was not the least restrictive means of serving what was claimed to be a compelling governmental interest in road protection. Remanded for an order of dismissal. View "Mitchell County v. Zimmerman" on Justia Law

Defendant Jerin Mootz was convicted for assault on a police officer resulting in bodily injury. During voir dire, Mootz sought to use a peremptory challenge to remove a Hispanic juror. The district court found Mootz was using his strikes in a racially discriminatory manner, denied the strike, and seated the juror. The court of appeals affirmed the conviction, finding that the district court erred in refusing to allow the strike of the potential juror, but that Mootz had not shown that the error prejudiced him. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the district court, holding (1) the trial court erred when it prohibited Mootz from using his peremptory challenge to remove the juror; (2) Mootz, or any other similarly situated defendant, was not required to show actual prejudice in order to reverse his conviction; and (3) automatic reversal is required whenever a defendant is denied the use of a peremptory challenge based on an erroneous interpretation of Batson v. Kentucky and its progeny and the objectionable juror is improperly seated. View "State v. Mootz" on Justia Law

Robert Lowe was charged with several criminal counts related to Lowe's alleged manufacture of methamphetamine. Lowe moved to certain suppress statements he made to the police. The district court granted the motion, determining that because the statements had been made in response to a promise of leniency they were rendered involuntary. The Supreme Court affirmed, holding (1) the consent that led to the search of the premises was proper and the motion to suppress the physical evidence obtained as a result of the search was properly denied; and (2) when police reinitiated questioning of Lowe after he requested an attorney, they violated his constitutional rights under Miranda, and because there was not sufficient exigency to justify such questioning, the public safety exception to Miranda did not apply under the facts of this case. Therefore, Lowe's statements were properly suppressed. View "State v. Lowe" on Justia Law

After his vehicle collided with and killed a bicyclist, Defendant was convicted of homicide by vehicle, operating while intoxicated, and leaving the scene of an accident. The court of appeals affirmed his convictions but remanded for a sentencing correction. The Supreme Court granted further review to determine whether the State must prove in a prosecution under Iowa Code 707.6A(1) that Defendant's intoxication was a proximate cause of the victim's death and, if so, whether Defendant's trial counsel was ineffective for failing to raise the issue below. The Supreme Court affirmed the conviction, holding (1) the State must prove Defendant's intoxicated driving caused the victim's death to sustain a conviction for homicide by vehicle; and (2) the record was not adequate to determine whether Defendant's trial counsel was ineffective in failing to raise the causation issue, and therefore, the claim of ineffective assistance of counsel was preserved for postconviction proceedings. View "State v. Adams" on Justia Law

Dennis Richards was convicted of second-degree murder and second-degree arson for strangling his ex-wife to death and setting her house on fire. The court of appeals reversed and remanded for a new trial after concluding that Richards should have been allowed to call a physical therapist in his defense even though the witness had been disclosed a day late. The Supreme Court vacated the decision of the court of appeals and affirmed Richards' convictions, holding that even if the district court erred in excluding the therapist, any error was harmless in light of the overwhelming evidence of Richards' guilt. View "State v. Richards" on Justia Law

Lee Breuer was the apparent driver in a one-car accident. Breuer and the passenger were transported to the hospital, where a deputy sheriff asked Breuer to provide a breath test. Breuer refused. An officer then obtained a warrant authorizing withdrawal of a blood specimen from Breuer. Before the officer arrived at the hospital with the warrant, the deputy sheriff advised Bruer that his blood would be withdrawn by force if necessary, and Breuer acquiesced to a blood draw. The passenger in Breuer's vehicle subsequently died as a result of injuries sustained in the accident. The State charged Breuer with homicide by vehicle. Breuer filed a motion to suppress the results of the blood draw, which the district court denied. The court of appeals affirmed. The Supreme Court affirmed, holding that neither the state or federal constitution required the search warrant to be physically present before the search could begin. View "State v. Breuer" on Justia Law

The Iowa Right to Life Committee (IRTL) filed a complaint in the U.S. district court, alleging, inter alia, that Iowa's campaign finance laws unconstitutionally imposed political committee status on corporations whose major purpose was something other than nominating or electing candidates. The district court certified two questions to the Supreme Court. At issue before the Court was whether a corporation must form a political committee under Iowa law if it wants to spend more than $750 advocating the election or defeat of Iowa candidates. The Court answered that a corporation like IRTL may engage in express advocacy without forming a political committee because a corporation making independent expenditures aggregating over $750 in a calendar year becomes an "independent expenditure committee" within the meaning of Iowa Code 68A.404 but not a "political committee" within the meaning of Iowa Code 68A.102(18) or a "permanent organization" within the meaning of Iowa Code 68A.402(9). View "Iowa Right to Life Comm., Inc. v. Tooker" on Justia Law