Justia Iowa Supreme Court Opinion Summaries

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

Daniel Murillo, a registered sex offender, sought to modify his registry requirements under Iowa Code section 692A.128. Murillo had pleaded guilty to sexual abuse in the third degree in 2005 and was required to register as a sex offender. He completed a sex offender treatment program (SOTP) while incarcerated and received a certificate of completion in 2009. In 2022, Murillo applied to be removed from the sex offender registry, citing his completion of the SOTP and a low-risk assessment for recidivism.The Iowa District Court for Polk County denied Murillo's application, determining that he had not "successfully completed" the SOTP because he only admitted guilt to avoid a longer sentence. The court also found that Murillo posed an ongoing risk to the community. The Iowa Court of Appeals affirmed the district court's decision.The Iowa Supreme Court reviewed the case and held that the district court erred in determining that Murillo had not successfully completed the SOTP, as he had a certificate of completion from the Department of Corrections. However, the Supreme Court found that the district court did not abuse its discretion in denying Murillo's application for modification. The court concluded that the district court properly considered relevant factors, including Murillo's inconsistent admissions of guilt and the need for further treatment, in determining that he posed an ongoing risk to the community.The Iowa Supreme Court vacated the decision of the Court of Appeals but affirmed the judgment of the district court, maintaining Murillo's registration requirements. View "Murillo v. State of Iowa" on Justia Law

Chad Allen Staton was convicted by a jury of incest and sexual abuse of his daughter. He appealed his conviction, arguing that the evidence was insufficient, the district court erred by allowing his daughter to testify about a prior uncharged incident, and his right to allocute was violated when the sentencing court disallowed discussion of rejected plea offers. Staton contended that the rejected plea offers demonstrated his sincerity in professing innocence, which should mitigate his lack of remorse at sentencing.The Iowa District Court for Black Hawk County, presided over by Judge Linda M. Fangman, sentenced Staton to indeterminate prison sentences totaling forty years with a mandatory minimum of seventeen and a half years. Staton appealed, and the Iowa Court of Appeals affirmed his conviction and sentence, finding the evidence sufficient and the admission of the prior incident appropriate. The court also concluded that Staton’s right to allocute was not violated as he and his counsel had opportunities to address mitigation.The Iowa Supreme Court reviewed the case to address whether the defendant’s right to allocute was violated by disallowing discussion of rejected plea offers. The court held that the district court correctly cut off discussion of rejected plea offers during allocution, as such offers are inadmissible under Iowa Rule of Criminal Procedure 2.10(5). The court reasoned that allowing discussion of rejected plea offers could deter prosecutors from making plea offers. The court affirmed the decision of the Iowa Court of Appeals and the judgment of the district court, concluding that Staton’s right to allocute was not violated since he and his counsel were allowed to argue his professed innocence to explain his lack of remorse. View "State v. Staton" on Justia Law

Reuben Schooley was convicted of child endangerment causing bodily injury after an incident where he slapped his nine-year-old daughter, spanked her, yanked her by the shirt, and told her to leave the house. The child was found with marks on her collar and bruising on her buttocks. Schooley admitted to spanking her frequently and acknowledged that his actions were inappropriate. The jury found him guilty based on the evidence presented.The Iowa District Court for Emmet County sentenced Schooley to five years of incarceration. Schooley appealed, arguing that there was insufficient evidence to support his conviction and that his sentence was improperly influenced by a victim-impact statement from the guardian ad litem (GAL). He contended that the GAL was not authorized to provide such a statement and that it contained unproven allegations.The Iowa Supreme Court reviewed the case and found that sufficient evidence supported the jury's verdict. The court noted that the reasonableness of corporal punishment is generally a question for the jury and that the evidence showed Schooley's actions were excessive and abusive. The court also addressed Schooley's challenge to the GAL's victim-impact statement, concluding that Schooley had waived this issue by not raising it in the district court. Additionally, the court found no affirmative showing that the district court relied on improper information from the GAL's statement when sentencing Schooley.The Iowa Supreme Court affirmed Schooley's conviction and sentence, holding that the evidence was sufficient to support the jury's verdict and that the district court did not abuse its discretion in considering the GAL's statement. View "State of Iowa v. Schooley" on Justia Law

The defendant engaged in online conversations with an undercover police officer posing as a fifteen-year-old girl. He arranged to meet the girl for sex at a gas station shower room. Upon arrival, he was arrested and charged with solicitation of commercial sexual activity under Iowa Code section 710A.2A. The defendant argued that there was insufficient evidence to support the charge because he did not offer or promise anything of value in exchange for sexual activity. The district court rejected these arguments, and a jury convicted him.The Iowa District Court for Polk County denied the defendant's motion for a new trial and sentenced him to five years in prison. The Iowa Court of Appeals conditionally affirmed the conviction but remanded the case for the district court to reconsider the motion for a new trial under the correct standard. The defendant sought further review.The Iowa Supreme Court reviewed the case and found that the evidence was insufficient to show that the defendant was attempting to engage in commercial sexual activity. The court noted that while the defendant's behavior was reprehensible, he did not give or promise the undercover officer any item of value in exchange for a sex act. The court concluded that the statutory definition of "commercial sexual activity" requires an express or implied quid pro quo, which was not present in this case. Consequently, the court vacated the decision of the court of appeals, reversed the district court's judgment, and remanded the case for dismissal. View "State v. Fenton" on Justia Law

Sarah Berg, an employee at Casey’s General Store, activated three gift cards without paying for them and used one to purchase gas the next day. She was arrested for fourth-degree theft. The county attorney did not file a trial information for this charge within the required 45 days. Instead, a trial information was later filed for unauthorized use of a credit card.The Iowa District Court for Black Hawk County denied Berg’s motion to dismiss the trial information for unauthorized use of a credit card, despite the missed speedy-indictment deadline for the theft charge. Berg was found guilty following a trial on the minutes. She was sentenced to 120 days in jail (suspended), a fine (suspended), court costs, probation, and potential restitution. Berg appealed, arguing the district court erred in denying her motion to dismiss and that the evidence was insufficient to support her conviction. The Iowa Court of Appeals affirmed her conviction.The Iowa Supreme Court reviewed the case and affirmed the lower courts' decisions. The court held that fourth-degree theft and unauthorized use of a credit card are not the same offense for speedy-indictment purposes. The court reasoned that the charges relied on distinct underlying facts: the theft charge required proof of taking property valued between $300 and $750, while the unauthorized use charge required proof of using a credit card to obtain property or services. Therefore, the State was not precluded from filing the new charge after the 45-day period had elapsed. View "State of Iowa v. Berg" on Justia Law