Justia Iowa Supreme Court Opinion Summaries

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 affirmed the judgment of the district court dismissing Appellant's cause of action for unjust enrichment against the State, holding that the district court correctly dismissed the matter as an unlawful collateral attack on Appellant's criminal conviction.Appellant pleaded guilty to speeding in a construction zone. Appellant later filed a lawsuit challenging the authority of Iowa Department of Transportation (IDOT) officers to issue traffic citations and contesting the payments the State collected from fines resulting from convictions on unauthorized IDOT-issued citations. The district court held (1) the IDOT officers, at the time, lacked authority to stop Defendant's vehicle; and (2) Appellant's unjust enrichment claim was an improper collateral attack on his conviction, warranting dismissal. The Supreme Court affirmed, holding that the district court correctly concluded that Appellant's unjust enrichment claim was an improper collateral attack on his speeding ticket conviction. View "Rilea v. State" on Justia Law

The Supreme Court affirmed Defendant's prison sentence, holding that Defendant forfeited any rights to enforce the plea agreement in this case when he breached it.The plea agreement provided that Defendant would plead guilty to third-degree burglary, be released with supervision until sentencing, and be free to argue for probation at sentencing. Defendant, however, absconded after the plea hearing and failed to appear for the sentencing hearing. Defendant was arrested approximately seven months later. Defendant's counsel sought a suspended sentence and probation, and the State advocated for a term of imprisonment. The district court sentenced Defendant to an indeterminate term of imprisonment not to exceed five years. The Supreme Court affirmed, holding that the State did not breach the plea agreement in this case. View "State v. Jordan" 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

The Supreme Court dismissed Defendant's appeal challenging his guilty plea to theft in the second degree, holding that Defendant's challenge to the constitutionality of new legislation limiting his ability to appeal was unavailing.The legislation at issue limits the ability of a defendant to appeal as a matter of right from a conviction following a guilty plea and directs that ineffective assistance of counsel claims be presented and resolved in the first instance in postconviction relief proceedings. On appeal from his conviction of theft in the second degree Defendant argued that the new legislation violated his right to equal protection of then laws and the separation of powers doctrine. The Supreme Court affirmed, holding that Defendant's constitutional challenges failed. View "State v. Tucker" on Justia Law

The Supreme Court vacated the judgment of the district court sentencing Defendant to consecutive sentences of incarceration in connection with his plea of guilty to possession of a controlled substance, third or subsequent offense, and driving while barred, holding that the district court improperly speculated that Defendant was working under the influence.The district court accepted Defendant's guilty pleas and proceeded to a sentencing hearing. The district court sentenced Defendant to consecutive sentences of incarceration not to exceed two years for both charges after noting that it was not safe for Defendant to be working in a day care center if he was under the influence. The court of appeals affirmed. The Supreme Court vacated the sentence, holding that the district court's speculation about Defendant working under the influence was improper based on the information it had before it. View "State v. Fetner" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the determination of the district court that evidence of approximately twenty instances of Defendant's cell phone use while in a vehicle over an approximately three-year period was inadmissible as habit evidence.Plaintiff was riding his bicycle when he was struck with the vehicle driven by Defendant. Plaintiff filed a negligence petition against Defendant. Before trial, Defendant filed a motion in liming asking the district court to prevent Plaintiff from making any argument that she had a habit of driving while distracted. The district court refused to admit evidence of Defendant's cell phone use while driving to prove a habit. The jury returned a verdict for Defendant. The court of appeals affirmed. The Supreme Court affirmed, holding that proffered specific instances of Defendant's cell phone use while driving were not numerous enough to constitute habit evidence. View "Holmes v. Pomeroy" on Justia Law