Justia Iowa Supreme Court Opinion Summaries

Benjamin Trane established a private therapeutic boarding school for troubled youth, which was shut down after a police raid. Trane was charged with sexual abuse of a minor, sexual exploitation by a counselor or therapist, and child endangerment. The first two charges involved an underage female victim, while the third charge involved two boys placed in isolation rooms. A jury found Trane guilty on all counts. On direct appeal, the Iowa Supreme Court conditionally affirmed his convictions but remanded for a hearing on a rape shield issue, preserving his ineffective-assistance-of-counsel claims for postconviction relief (PCR) proceedings.In the Iowa District Court for Lee (South) County, Trane alleged ineffective assistance of trial counsel for failing to move to sever the child endangerment count and for not objecting to the marshaling instruction on that count. The district court rejected the severance claim, finding Trane made an informed decision to forego a motion for severance to avoid delay. However, the court ordered a new trial on the child endangerment charge, finding that the marshaling instruction allowed a nonunanimous verdict, thereby prejudicing Trane.The Iowa Supreme Court reviewed the case de novo. The court affirmed the district court's finding that Trane chose to forego a motion to sever the child endangerment count. However, the court reversed the district court's order for a new trial on the child endangerment charge. The court agreed that the marshaling instruction was erroneous but found no prejudice because both child victims were similarly situated, and there was no reasonable probability that jurors did not find Trane guilty of endangering both children. Thus, the court affirmed the denial of relief on the severance claim and reversed the order for a new trial on the child endangerment charge. View "Trane v. State of Iowa" on Justia Law

An officer on patrol stopped a vehicle for a traffic infraction after receiving information that the vehicle’s occupants might have been involved in a drug sale. After initially interacting with the driver, the officer waited for backup before removing the occupants and conducting a search with a drug-sniffing dog, which led to the discovery of a gun. The passenger, Tyre Brown, admitted ownership of the gun and was charged with unlawful possession of a firearm. Brown argued that the officer unlawfully prolonged the stop beyond the time necessary to address the traffic infraction, violating his constitutional rights.The Iowa District Court for Polk County denied Brown’s motion to suppress the evidence obtained from the search. Brown was found guilty after stipulating to a trial on the minutes of testimony. Brown appealed the denial of his motion to suppress, and the Iowa Court of Appeals affirmed the district court’s ruling. The court of appeals concluded that the extension of the stop was permissible under the shared-knowledge doctrine and that the officer had smelled marijuana, justifying further investigation.The Iowa Supreme Court reviewed the case and affirmed the lower courts' decisions. The court held that the shared-knowledge doctrine allowed the officer to act on information provided by another officer who had observed a potential drug transaction, thus justifying the extension of the stop. The court found that the extension of the stop to investigate for drugs did not violate Brown’s constitutional rights. Consequently, the district court’s ruling denying Brown’s motion to suppress was affirmed. View "State of Iowa v. Brown" on Justia Law

Isaiah Duffield was required to register as a sex offender due to a juvenile adjudication for sexual abuse. In April 2022, he was charged with sexual abuse in the third degree, second or subsequent offense, and failure to comply with the sex offender registry. After the charges were severed and amended, Duffield entered a guilty plea to the lesser offense of failure to register, an aggravated misdemeanor. The district court sentenced him to a term of incarceration not to exceed two years and a fine of $1,025, which was suspended. The court ordered the sentence to be served consecutively to a sentence in a separate sexual abuse case.Duffield appealed to the Iowa Court of Appeals, arguing that the district court abused its discretion in imposing the $1,025 fine and failed to state its reasons for imposing consecutive sentences. The court of appeals upheld the fine, reasoning it was within the statutory range and Duffield did not establish any irregularity. However, the court agreed that the district court erred in failing to state reasons for consecutive sentences and remanded the case to a different judge to decide whether the sentences should be served concurrently or consecutively.The Iowa Supreme Court reviewed the case and focused on the consecutive sentencing issue. The court held that the district court erred in failing to state its reasons for imposing consecutive sentences. The court vacated Duffield’s sentence and remanded the case for a plenary resentencing hearing, emphasizing that the resentencing should not be limited to the consecutive sentencing issue alone. The court also concluded that resentencing before a different judge was not required, as there was no taint in the sentencing process. The decision of the court of appeals was vacated, the conviction was affirmed, the sentence was vacated, and the case was remanded for resentencing. View "State of Iowa v. Duffield" on Justia Law

Lukouxs Brown was charged with first-degree murder after allegedly killing a coworker. Before his arraignment, his counsel observed signs of mental illness, including hearing voices and a history of schizophrenia. The district court found probable cause to believe Brown was not competent to stand trial and ordered a psychiatric evaluation. Dr. Arnold Andersen diagnosed Brown with a schizophrenia-like disorder and substance abuse disorders, concluding he was not competent but could potentially be restored to competency. Brown was committed to the Iowa Medical and Classification Center (IMCC) for treatment.After eight months of treatment, Dr. Andersen reported that Brown remained incompetent and unlikely to be restored to competency within a reasonable time. The district court, however, allowed the State to obtain a separate psychiatric evaluation, which concluded that Brown was competent. The district court found Brown competent to stand trial and reinstated the criminal proceedings. Brown filed an interlocutory appeal, arguing the district court erred in its competency determination and in allowing the State to obtain a separate evaluation.The Iowa Court of Appeals reviewed the case de novo, found Brown was not competent, and remanded the case for further treatment. The State sought further review, challenging the standard of review and the district court's decision to allow a separate evaluation. The Iowa Supreme Court reaffirmed the de novo standard of review for competency determinations, emphasizing the protection of constitutional rights. The court also held that Iowa Code does not permit separate psychiatric evaluations at the dispositional phase of competency proceedings. The court vacated the Court of Appeals decision, reversed the district court order, and remanded the case for further proceedings consistent with its opinion. View "State of Iowa v. Brown" on Justia Law

Alison Dorsey ran an in-home daycare in Cass County, Iowa. In 2019, an eleven-week-old baby at her daycare died, leading to Dorsey being charged with first-degree murder and child endangerment resulting in death. Her first trial in Cass County ended in a hung jury. The State then requested a change of venue, which the district court granted, moving the second trial to Pottawattamie County. Dorsey was subsequently convicted of second-degree murder and child endangerment resulting in death.The Iowa District Court for Cass County initially handled the case, where the first trial ended in a mistrial due to a hung jury. Following this, the State filed a motion to change the venue, citing concerns about pretrial publicity and the difficulty of seating an impartial jury in Cass County. The district court granted the motion, and the second trial was held in Pottawattamie County, where Dorsey was convicted. Dorsey appealed the decision, challenging the change of venue among other issues.The Iowa Supreme Court reviewed the case and concluded that the district court abused its discretion by granting the State's motion for a change of venue without attempting to seat a second jury in Cass County. The court emphasized that the district court should have used the voir dire process to assess potential juror bias before deciding to move the trial. The court found that the pretrial publicity was not sufficiently pervasive or inflammatory to justify the venue change without this step. Consequently, the Iowa Supreme Court reversed Dorsey's conviction and remanded the case for a new trial in Cass County. View "State of Iowa v. Dorsey" on Justia Law

Artell Young, a federal supervised releasee, was subject to a search condition allowing federal probation officers to search his person, vehicle, or home upon reasonable suspicion of contraband or release condition violations. After receiving information that Young was dealing drugs and possessing a firearm, federal probation officers searched his home, finding small amounts of crack cocaine, powdered cocaine, and marijuana. The federal authorities turned the case over to Iowa authorities, leading to Young's conviction on several drug offenses.In the Iowa District Court for Polk County, Young moved to suppress the evidence from the search, arguing it violated the Fourth Amendment and article I, section 8 of the Iowa Constitution. The district court upheld the search, citing the "special needs" exception under both the Fourth Amendment and article I, section 8. The court also noted that the search was conducted by federal officers under federal standards, thus not subject to Iowa constitutional standards. Young was convicted by a jury of three counts of possession of a controlled substance and sentenced to six years in prison.The Iowa Supreme Court reviewed the case, focusing on whether the search violated article I, section 8 of the Iowa Constitution. The court held that the constitutionality of the search should be evaluated by the law of the sovereign that conducted the search—in this case, federal law. The court affirmed the district court's decision, concluding that the search was lawful under federal standards and that the evidence obtained was admissible in the state prosecution. The court rejected Young's claim of an illegal search and affirmed his convictions. View "State of Iowa v. Young" on Justia Law

On the night of October 9, 2021, Wichang Chawech was at a bar in Des Moines with friends. After altercations between his friends and other patrons, Chawech pulled out a 9 mm pistol and fired a shot, grazing a man's jaw and fatally wounding a woman. Chawech was charged with first-degree murder, attempted murder, willful injury causing serious injury, and intimidation with a dangerous weapon. He pleaded not guilty and raised defenses of justification, self-defense, and defense of others. The jury found him guilty of lesser included offenses for the first two counts and the charged offenses for the latter two counts. They also found that he was in possession of a dangerous weapon during the offenses.The Iowa District Court for Polk County sentenced Chawech to consecutive terms for counts I, III, and IV, totaling twenty-two years, with a mandatory minimum of ten years due to the dangerous weapon enhancement under Iowa Code section 902.7. The court ordered the sentence for count II to run concurrently. Chawech appealed, arguing insufficient evidence, improper merger of counts II and III, and an illegal mandatory minimum sentence due to the enhancement not being charged in the trial information.The Iowa Court of Appeals affirmed the convictions and sentences, except for agreeing that counts II and III should merge. They vacated the sentence for count II and remanded for an appropriate order. Chawech sought further review, focusing on the sufficiency of evidence and the mandatory minimum sentence.The Iowa Supreme Court reviewed the case, focusing on the mandatory minimum sentence. They concluded that the challenge to the sentencing enhancement was an illegal-sentence challenge, not subject to error preservation principles. However, they found that the trial information and jury instructions met the requirements of Iowa Rule of Criminal Procedure 2.6(6) and the U.S. Constitution. Thus, the mandatory minimum sentence was upheld. The court affirmed the decision of the Court of Appeals in part, vacated in part, and remanded the case for further proceedings consistent with their opinion. View "State of Iowa v. Chawech" on Justia Law

John Feller was charged in 2011 with lascivious acts with a child and third-degree sexual abuse after his stepdaughter reported abuse. He pleaded guilty to two counts of lascivious acts with a child and was sentenced to concurrent five-year prison terms, a ten-year special sentence, and required to register as a sex offender. Initially, he was informed he needed to register for ten years, but later was told he had to register for life due to a procedural error resulting in two separate case numbers.The Iowa District Court for Dubuque County denied Feller's application to modify his sex offender registration requirements, citing his decision to testify by affidavit, his courtroom demeanor, and letters he sent to his daughter. The Iowa Court of Appeals affirmed this decision.The Iowa Supreme Court reviewed the case and found that the district court abused its discretion by considering improper factors, such as Feller's choice to testify by affidavit and his demeanor. The court noted that Feller had completed sex offender treatment, had no criminal charges since his release, and was evaluated as a low risk to reoffend. The court also found that the letters Feller sent to his daughter, which were sent with permission, did not indicate a risk of reoffense.The Iowa Supreme Court vacated the decision of the Court of Appeals, reversed the district court's judgment, and remanded the case for an order granting Feller's application to end his lifetime registration. The court emphasized that Feller's successful adjustment to the community and low risk of reoffense did not justify the continuation of his registration requirements. View "Feller v. State" on Justia Law

A police officer initiated a traffic stop of Ashlee Mumford because the vehicle's license plate was obscured by dirt and grime. During the stop, a drug detection dog conducted a sniff around the vehicle, briefly touching the passenger door and momentarily breaking the plane of the passenger window. The dog alerted to the presence of controlled substances, leading to a search that uncovered methamphetamine in the glove compartment and marijuana and a methamphetamine pipe in Mumford's purse. Mumford was arrested and charged with possession of methamphetamine, marijuana, and drug paraphernalia. She was acquitted of methamphetamine possession but convicted of marijuana and drug paraphernalia possession.In the Iowa District Court for Madison County, Mumford moved to suppress the evidence obtained from the traffic stop, arguing it violated her constitutional rights against unreasonable searches and seizures. The district court denied her motion, concluding the traffic stop was supported by probable cause and the use of the drug detection dog did not violate the Federal or State Constitution. Mumford was convicted of possession of marijuana and drug paraphernalia following a bench trial.The Iowa Supreme Court reviewed the case and affirmed the district court's decision. The court held that the traffic stop was supported by probable cause due to the obscured license plate, and the use of the drug detection dog did not constitute an unlawful search. The court also found sufficient evidence to support Mumford's conviction for possession of marijuana, rejecting her argument that lab testing was required to prove the substance was marijuana. The court concluded that the district court did not err in denying Mumford's motion to suppress evidence or her motion in arrest of judgment. View "State v. Mumford" on Justia Law

Jeffrey Flynn was stopped by Dubuque County Deputy Sheriff Rob Freund for speeding. Freund suspected Flynn was intoxicated after smelling alcohol and hearing Flynn admit to drinking. Flynn performed poorly on field sobriety tests and a preliminary breath test indicated a blood alcohol concentration above the legal limit. Flynn was arrested for operating a motor vehicle while intoxicated (OWI) and transported to the law enforcement center. Freund requested Flynn submit to a chemical breath test without providing a written request or advising Flynn of the consequences of refusal or submission. The test showed a blood alcohol concentration of .110, and Flynn was charged with OWI first offense.The Iowa District Court for Dubuque County granted Flynn’s motion to suppress the chemical breath test evidence. The court reasoned that the statutory requirements for a written request and advisories were mandatory and not followed by Freund. The court concluded that the failure to comply with these requirements rendered the test results inadmissible.The Iowa Supreme Court reviewed the case and affirmed the district court’s decision. The court held that the implied consent statute requires a peace officer to make a written request and provide advisories when requesting a motorist to submit to a chemical test under certain conditions, which were present in this case. The court rejected the State’s argument that the statute was not invoked and that actual consent was sufficient. The court concluded that the failure to follow the statutory procedures rendered the chemical breath test results incompetent for prosecution purposes. The case was remanded for further proceedings consistent with this opinion. View "State of Iowa v. Flynn" on Justia Law