Justia Iowa Supreme Court Opinion Summaries

The Supreme Court reversed the ruling of the district court finding Iowa Code 815.1(4)(c) to be unconstitutional, holding that the State is not constitutionally required to provide ancillary services to an indigent defendant represented by private counsel if funds available to the counsel can reasonably be expected to cover the services.In 2019, the General Assembly enacted section 815.1, thereby changing the process by which an indigent defendant can obtain state funding for investigation costs when the defendant chooses to be represented by privately-retained counsel. The district court found section 815.1 unconstitutional under the Sixth Amendment, severed section 815.1(4)(c) from the statute, and granted Defendant's request for ancillary services at state expenses. The Supreme Court reversed, holding that the State is constitutionally permitted to consider the funds available to a retained attorney in determining whether it is required to provide state funding for ancillary services. View "Amaya v. State Public Defender" on Justia Law

The Supreme Court affirmed Defendant's convictions for drug- and firearm-related offenses, holding that the district court did not abuse its discretion by granting defense counsel's motion to withdraw and did not err in concluding that Defendant knowingly, voluntarily, and intelligently waived his right to counsel.The district court granted defense counsel's motion to withdraw from representation of Defendant approximately three weeks before Defendant's speedy trial expiration date. Although the district court offered to appoint another attorney to represent Defendant, Defendant demanded that he represent himself with the assistance of standby counsel. After conducting colloquies the district court allowed Defendant to proceed pro se with the assistance of standby counsel. The Supreme Court affirmed Defendant's convictions, holding that the district court (1) did not abuse its discretion by granting defense counsel’s motion to withdraw based on defense counsel’s statements that professional considerations required termination of the representation; and (2) correctly concluded that Defendant knowingly, intelligently, and voluntarily waived his right to counsel after engaging in a thorough colloquy. View "State v. Miller" on Justia Law

Vangen was convicted of criminal mischief in the fourth degree after the prosecution presented alternative theories to the jury—she either used a baseball bat to smash the windows of a car or she drove others to the scene and one of them smashed the windows. She argued that neither was supported by sufficient evidence, but even if one was supported, a 2019 statute requiring the jury’s general verdict to be affirmed as long as one theory was supported violates her constitutional rights (Iowa Code 814.28–prohibiting an appellate court from reversing “a verdict on the basis of a defective or insufficient theory if one or more of the theories presented . . . is sufficient to sustain the verdict on at least one count”). The Iowa Supreme Court affirmed. Both theories presented to the jury were supported by sufficient evidence, so the court declined to address the challenge to Iowa Code section 814.28. View "State of Iowa v. Vangen" on Justia Law

In 2005, Sandoval was convicted of two counts of first-degree murder and two counts of attempted murder. He was sentenced to serve concurrent terms of life imprisonment without the possibility of parole for the murder convictions and 25 years’ imprisonment for the attempted murder convictions. Sandoval unsuccessfully challenged his convictions on direct appeal and in three different applications for postconviction relief.The Iowa Supreme Court affirmed the dismissal of Sandoval’s fourth application for postconviction relief, which the district court held was barred by the three-year statute of limitations of Iowa Code section 822.3. Sandoval argued that because he was only 19 at the time he murdered two people, his mandatory life sentences without the possibility of parole violated the federal and state constitutional prohibitions against “cruel and unusual punishment.” U.S. Const. amend. VIII; Iowa Const. art. I. The court disagreed. Sandoval’s mandatory sentences of lifetime incarceration without the possibility of parole for committing these offenses are not categorically prohibited by either the Federal Constitution or the state constitution. View "Sandoval v. State of Iowa" on Justia Law

In 1994, Dorsey shot and killed a woman when he was 18 years and five days old. He was found guilty of murder in the first degree and was sentenced to a mandatory term of life in prison without the possibility of parole.In Dorsey’s fifth attempt to obtain post-conviction relief, the Iowa Supreme Court affirmed his sentence, rejecting Dorsey’s argument that the sentence violates his state constitutional right to be free from “cruel and unusual punishment.” He argued the state constitution prohibits imposing a mandatory punishment on a young adult offender and instead requires the district court to hold an individualized sentencing hearing before imposing any sentence and that his life sentence without the possibility of parole is grossly disproportionate to the crime. Considerations of efficiency and certainty require a bright line separating adults from juveniles. There is nothing unique about the facts of this case that raise an inference of gross disproportionality. Dorsey’s willful, deliberate, and premeditated murder of an unarmed woman in her own home justifies the most severe sentence allowed under our law. View "Dorsey v. State of Iowa" on Justia Law

The Supreme Court affirmed Defendant's conviction of possession of a controlled substance under Iowa Code 124.401(5), holding that there was no error in the proceedings below.When Defendant was pulled over by an Iowa trooper for speeding she provided the trooper with a current Patient Medical Marijuana Registry Identification Card issued by the Arizona Department of Health Services, which allowed her to legally purchase and possess a limited amount of marijuana for medical use in Arizona. The registry card required a written certification completed by a licensed Arizona physician, but the certification was not provided to the trooper. On appeal from her convictions, Defendant challenged the district court's determination that the registry card and written certification were not a valid prescription or order and barring their admissions during trial. The Supreme Court affirmed, holding (1) the district court properly excluded from evidence the registry card and written certification because they were not a valid prescription or order; and (2) Defendant was not entitled to relief on her remaining allegations of error. View "State v. Middlekauff" on Justia Law

The Supreme Court affirmed the decision of the court of appeals and the district court judgment convicting Defendant of murder in the first degree, holding that a verdict-urging instruction did not improperly coerce the jury verdict.Specifically, the Supreme Court held (1) a jury instruction that explains reasonable doubt in terms of "hesitate to act" is legally adequate, but because the inclusion of "hesitate to act" language was not legally required in this case the district court did not abuse its discretion by refusing to add the discretionary instruction; and (2) the verdict-urging instruction given in this case lacked content that this Court had previously disapproved of, but the jury was not improperly coerced by the court's verdict-urging instruction. View "State v. Davis" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the order of the district court granting Defendant's motion to suppress evidence of drugs seized following a pat-down, holding that law enforcement's conclusion that Defendant possessed drugs met the bar to establish probable cause.The district court concluded that the officer's inability to discern the type of the drugs in the packaging before removing them from Defendant's pocket required suppression of the evidence. The court of appeals reversed, determining that the evidence was sufficient under the plain-feel exception to the warrant requirement that Defendant believed the package contained heroin, powder cocaine, or crack cocaine, despite not knowing which one. The Supreme Court affirmed, holding that the evidence established probable cause for the officer to have arrested Defendant for drug possession. View "State v. Hunt" on Justia Law

The Supreme Court reversed Defendant's conviction and sentence for ongoing criminal conduct and Defendant's conviction for robbery in the first degree, holding that Defendant's conduct did not satisfy the requirements for ongoing criminal conduct.Defendant was indicted for his participation in a three-week crime spree that involved using a torch to cut into an ATM, robbing a bank, and using the proceeds to buy and subsequently sell marijuana. Defendant was convicted of first-degree robbery and ongoing criminal conduct and sentenced to twenty-five years on each. The Supreme Court vacated the convictions at issue, holding (1) the State presented insufficient evidence to establish the continuing basis element of the ongoing criminal conduct charge; and (2) Defendant's conviction for robbery in the first degree is vacated and the case remanded for entry of judgment and sentencing for robbery in the second degree. View "State v. Crawford" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting and sentencing Defendant but remanded for entry of a nun pro tune order to correct the fine suspended in the written sentencing order to the amount orally pronounced at the sentencing hearing.Pursuant to a plea agreement, Defendant pleaded guilty to several drug offenses. The district court imposed a thirty-year prison sentence with the mandatory minimum reduced by Defendant's guilty plea. On appeal, Defendant argued that the district court failed to consider its discretion for a lower mandatory minimum sentence under Iowa Code 124.413(3) and that there was a discrepancy between the fine stated orally at sentencing and in the written order. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion by imposing the agreed-upon prison sentence; and (2) the fine should be reset through a nunc pro tunc order on remand. View "State v. Wilbourn" on Justia Law