Justia Iowa Supreme Court Opinion Summaries

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

The Supreme Court affirmed Defendant's convictions but reversed the illegal portion of Defendant's sentence, holding that Defendant's sentence was illegal because it specified a duration for sex offender registry obligations. Defendant was convicted of first-degree burglary, third-degree sexual abuse, domestic abuse assault causing bodily injury, and operating a vehicle without its owner's consent. The court of appeals affirmed the convictions but held that a portion of his sentence was illegal. The Supreme Court affirmed, holding (1) the district court did not err in admitting any prior act evidence; (2) Defendant's conviction of first-degree burglary and third-degree sexual abuse do not merge; and (3) Defendant's sentence was illegal because it specified a duration for sex offender registry obligations. View "State v. Goodson" on Justia Law

The Supreme Court dismissed this appeal from a 2019 order that declined to modify Defendant's court-ordered restitution in a criminal case, holding that Senate File 457 (S.F. 457) required dismissal of this appeal.Defendant was serving a life sentence for kidnapping when he requested a restitution hearing, alleging that the state had failed to comply with a prior court order finding that Defendant lacked a reasonable ability to pay attorney fees. The district court denied relief. The Supreme Court dismissed Defendant's appeal, holding that Defendant's remedies in district court had not been exhausted and that, under section 80 of S.F. 457, this Court was precluded from hearing this appeal. View "State v. Holmes" on Justia Law

The Supreme Court affirmed Defendant's conviction for assault "us[ing] any object to penetrate the genitalia or anus of another person" in violation of Iowa Code 708.2(5), holding that there was sufficient evidence to support the conviction and that Defendant's remaining claims of error were unavailing.Defendant's conviction stemmed from his act of penetrating the victim's vagina with his finger while the victim was unconscious. On appeal, Defendant argued that his finger did not constitute an "object" under section 708.2(5). The Supreme Court affirmed, holding (1) the evidence was sufficient to prove that Defendant committed assault by penetration with an object; and (2) the district court did not err in restricting Defendant from impeaching the complaining witness with otherwise inadmissible evidence. View "State v. Zacarias" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction and sentence for two counts of indecent contact with a child, holding the trial court did not err by allowing the jury to see a video recording of a child's forensic interview where the child discussed Defendant's sexual abuse of her.Long before the time the child reported the abuse and long before criminal charges were brought, the video interview at issue was recorded. During trial, the State filed a notice of intent to present the video interview. The video was shown the the jury after defense counsel cross-examined the child victim and suggested that she had fabricated her criminal trial testimony. After showing the jury the video the district court instructed the jury that the video could only be used as a tool to assess the child's credibility. Defendant appealed, arguing that the court's admission of the interview was in error. The Supreme Court affirmed, holding that the video was admissible as a prior consistent statement. View "State v. Fontenot" on Justia Law

The Supreme Court affirmed Defendant's conviction for child endangerment and remanded the case to the district court for resentencing, holding that the court of appeals properly vacated the restitution portion of the sentencing order due to the court's failure to make a proper reasonable-ability-to-pay determination regarding Defendant's restitution costs.The court of appeals affirmed Defendant's conviction but vacated the restitution portion of Defendant's sentence. The Supreme Court affirmed, holding (1) certain challenged statements fell under the excited utterance exception to the rule against hearsay; (2) Defendant's argument that her Confrontation Clause rights were violated by the admission of certain evidence was not preserved; and (3) the proper resolution of Defendant's appeal of the restitution order was to remand the case to the district court with instructions to allow Defendant to follow the procedures required by Iowa Code 910.2A and then to hold a hearing under section 910.7 on the remaining restitution issues in this case. View "State v. Dessinger" on Justia Law

In this interlocutory appeal, the Supreme Court affirmed the order of the district court prohibiting Defendant from filing any additional pro se supplemental documents in a postconviction relief proceeding, holding that the district court did not err.Under Iowa Code 822.3A, postconviction relief applicants are prohibited from filing "any pro se document, including an application, brief, reply brief, or motion, in any Iowa court." At issue was the constitutionality of the law, which was passed in the spring of 2019 and effective July 1, 2019, to pending postconviction relief proceedings and postconviction relief appeals. Defendant in this case argued that section 822.3A violated his constitutional rights. The Supreme Court rejected the argument, holding that there is no constitutional right to file pro se supplemental documents in postconviction relief proceedings and postconviction appeals. View "Hrbek v. State" on Justia Law

The Supreme Court reversed the decision of the district court denying Appellant's application to modify his sex offender registry requirements, holding that the district court erred in penalizing Defendant for his years of successful adjustment to sex offender registration.In 2000, Defendant pled guilty to two counts of sexual abuse in the third degree, making him subject to lifetime as a sex offender. Defendant was released in 2009 and, since then, had been on the registry without any violation of the registration requirements. In 2019, Defendant filed an application for modification of his sex offender registry requirements pursuant to Iowa Code 692A.128. The district court denied the application. The Supreme Court reversed, holding that the district court abused its discretion by not putting Defendant's STATIC-99R score into proper context and improperly relied on the absence of a stipulation with the Iowa Department of Correctional Services approving of a modification of the registration requirement. View "Becher v. State" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing the trial information in this case, holding that the State's delay in arresting and formally charging Defendant did not amount to a due process violation.By late 2017, law enforcement had focused on Defendant as the suspected perpetrator of a robbery. However, the police did not file a criminal complaint against Defendant until August 2018 and did not serve an arrest warrant until September 2019. In October 2019, after it was finally filed, the district court dismissed the trial information, concluding that Defendant's due process rights under the Fifth Amendment were violated. The Supreme Court reversed, holding that the State's delay in arresting and charging Defendant did not violate the speedy indictment rule or violate due process where Defendant failed to show actual prejudice. View "State v. Smith" on Justia Law