Justia Iowa Supreme Court Opinion Summaries

The Supreme Court conditionally affirmed Defendant's convictions of three misdemeanor drug offenses and remanded this case for further proceedings, holding that remand was required for the district court to apply the standard set forth in State v. Wright, 961 N.W.2d 396 (Iowa 2021).Last term, in Wright, the Supreme Court held that law enforcement officers conducted an unconstitutional seizure and search when they seized and searched garbage bags left out for collection without first obtaining a warrant. In the instant case, Defendant argued that a sheriff's deputy violated his constitutional rights by seizing and searching his trash without first obtaining a warrant. The Supreme Court conditionally affirmed Defendant's convictions and remanded the case for the district court to hold a hearing on Defendant's motion to suppress evidence without consideration of the evidence obtained during the trash pull. View "State v. Kuuttila" on Justia Law

The Supreme Court reversed the order of the district court striking down sections 99 and 100 of House File 766, which added funding conditions prohibiting abortion providers from participating in two federally funded educational grant programs directed at reducing teenage pregnancy and promoting abstinence, holding that any conditions premised on providing abortions cannot be considered unconstitutional.Planned Parenthood of the Heartland (PPH) was a former grantee of both grants and, upon the passage of sections 99 and 100, became ineligible to receive funding. PPH brought a declaratory judgment action arguing that the Act violated its rights to equal protection, due process, free speech, and free association under the Iowa Constitution. The district court granted summary judgment for PPH and enjoined enforcement of the legislative enactments. The Supreme Court affirmed, holding (1) the conditions were rationally related to the classification selected by the general assembly; and (2) where abortion providers have no constitutional right to perform abortions, the unconstitutional conditions doctrine did not prohibit the State form barring abortion providers from receiving the funding at issue. View "Planned Parenthood of the Heartland, Inc. v. Reynolds" on Justia Law

The Supreme Court reversed the judgment of the district court concluding that Employer discriminated against Employee by firing him when he sought a reasonable accommodation for a disability, holding that Defendants were entitled to judgment as a matter of law on each of Employee's disability discrimination claims except his claims for failure to accommodate and retaliation based on his request for a sign language interpreter.Employee, who had a preexisting hearing impairment, continued to work while rehabilitating from a workplace injury, and Employer assisted the rehabilitation by providing light-duty work. When a disagreement arose as to whether Employee was entitled to a specific work restriction, Employee was fired. A jury awarded Employee damages after finding that Employer discriminated against him when Employee sought a reasonable accommodation for a disability. The Supreme Court reversed, holding (1) to the extent Plaintiff's disability claims were based on the workplace injury, Plaintiff's failure to identify a job he could perform apart from the temporary light-duty work defeated his claims; and (2) Employer was entitled to a new trial on Employee's disability claims stemming from his request for a sign language interpreter. View "Rumsey v. Woodgrain Millwork, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court and the decision of the court of appeals rejecting a sex offender's challenge to two aspects of his lifetime special parole sentence, holding that there was no error.Defendant pled guilty to one count each of sexual abuse in the third degree, lascivious acts with a child, and indecent contact with a child. Following the revocation of his parole, Defendant returned to prison and filed this application for post conviction relief claiming that his plea counsel his ineffectively for failing adequately to inform him of the rules and requirements of his special sentence. The district court denied the application. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Defendant's plea counsel was not constitutionally ineffective; and (2) Defendant's claim that the parole and ex-offender-treatment-program rules were unconstitutional as applied to him was unavailing. View "Doss v. State" on Justia Law

The Supreme Court conditionally affirmed Defendant's drug-related convictions, second offense, holding that, consistent with this Court's opinion in State v. Wright, __ N.W.2d __ (Iowa 2021), filed today, law enforcement officers conducted an unreasonable seizure and search when they seized and searched garbage bags left out for collection without first obtaining a warrant.On appeal, Defendant argued that two sheriff's deputies violated his federal and state constitutional rights to be free from unreasonable searches and seizures when they seized and searched a trash bag outside Defendant's residence without first obtaining a warrant. The Supreme Court agreed, holding that remand was required in order for the district court to hold a hearing on Defendant's motion to suppress evidence without consideration of the evidence and information obtained during a trash pull used to support their warrant application. View "State v. Hahn" on Justia Law

The Supreme Court rejected Defendant's constitutional challenge to Iowa Code 321J.16 and joining the majority of courts holding that it is not an unconstitutional penalty to admit into evidence Defendant's refusal to submit to a breath test, holding that the best course is to overrule State v. Pettijohn, 899 N.W.2d 1, 38-39 (Iowa 2017).After denying Defendant's motion in liming to exclude evidence of her refusal to submit to a breathalyzer test Defendant was convicted of driving while intoxicated. On appeal, Defendant challenged the constitutionality of section 321J.16, which allows into evidence a defendant's test refusal. Specifically, Defendant argued that Pettijohn, which held that a search warrant was required for a breathalyzer test of an intoxicated boater, should be extended to drunken driving cases. The Supreme Court (1) overruled Pettijohn and held that search warrants are not required for breathalyzer tests of either boaters or drivers when law enforcement has probable cause to believe that intoxicated boating or driving has occurred; and (2) it is not an unconstitutional penalty to admit into evidence a defendant's refusal to submit to a breath test. View "State v. Kilby" on Justia Law

The Supreme Court conditionally affirmed Defendant's convictions and remanded for the district court to hold a hearing on Defendant's motion to suppress evidence, holding that the peace officer in this case conducted an unreasonable search and seizure by taking a citizen's opaque trash bags left outside for collection, opening the trash bags, and rummaging through the papers and effects contained therein.Despite an ordinance making it unlawful for any person to take solid waste placed out for collection, Officer Brandon Heinz, without probable cause or warrant, took Defendant's garbage bags and searched through them during the dark of night. Heinz subsequently applied for and was granted a search warrant based on the evidence obtained from the warrantless seizure and search of Defendant's trash bags. Defendant was subsequently charged with several drug-related counts. The district court denied Defendant's motion to suppress, and Defendant was found guilty. The court of appeals affirmed. The Supreme Court held that Heinz conducted an unreasonable search and seizure in violation of Iowa Const. art. I, 8 and that remand was required for a suppression hearing without consideration of the evidence obtained during the trash pulls used to support the warrant application. View "State v. Wright" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for operating while intoxicated on two alternative theories, holding that neither Iowa law nor the Iowa Constitution guarantee a suspected drunk driver the right to a private phone consultation with counsel before deciding whether to take a blood alcohol test.On appeal, Defendant challenged the denial of his motion to suppress, arguing that the officials at the jail where he was detained impermissibly refused to allow him a private, unrecorded conversation with his attorney. The Supreme Court affirmed, holding (1) Iowa Code 804.20 does not provide the detainee a right to a private and confidential telephone consultation; and (2) the Iowa Constitution does not provide a detainee with a right to a confidential telephone conversation. View "State v. Sewell" on Justia Law

The Supreme Court dismissed Defendant's appeal challenging the factual basis supporting his guilty plea to a drug offense, holding that Defendant failed to establish good cause to pursue a direct appeal as a matter of right.Defendant pled guilty to three drug-related offenses and was sentenced to an indeterminate term of incarceration. On appeal, Defendant argued (1) there was not a factual basis supporting one of his convictions; (2) his counsel provided constitutionally ineffective assistance; and (3) Iowa Code section 814.6 and 814.7 are unconstitutional. The Supreme Court dismissed the appeal, holding (1) section 814.6(1)(a)(3) is constitutional and governs this appeal; and (2) Defendant did not establish good cause to pursue this appeal as a matter of right. View "State v. Treptow" on Justia Law

The Supreme Court reversed Defendant's conviction of operating while intoxicated (OWI), holding that Mitchell v. Wisconsin, 588 U.S. __, __, 139 S. Ct. 2525 (2019) (plurality opinion), applies to cases of suspected driving while under the influence of controlled substances, in addition to alcohol-related cases.Defendant caused an accident while driving recklessly. Defendant, who was injured, was taken to the hospital strongly smelling of marijuana. A police officer dispatched to the hospital performed a blood test of Defendant, who was sedated, after a medical professional certified that Defendant was unable to consent or refuse blood testing. Defendant filed a motion to suppress the testing, but the motion was overruled. Defendant appealed, arguing that the warrantless blood draw violated Iowa Code 321J.7, the Fourth Amendment to the federal Constitution, and Iowa Const. art. I, 8. The Supreme Court reversed, holding (1) the State complied with section 321J.7; (2) because the parties did not have an opportunity to make a record under the Mitchell standard, the case must be remanded; and (3) article I, section 8 does not provide greater protection from warrantless blood draws than the Mitchell standard. View "State v. McGee" on Justia Law