Justia Iowa Supreme Court Opinion Summaries

The Supreme Court reversed the restitution order of the district court, holding that the State failed to prove the full amount of restitution was caused by the crime of conviction.Defendant pled guilty to ongoing criminal conduct and admitted that the victim bank's losses totaled $288,000. The bank obtained a civil deficiency judgment of $988,636. The district court ordered Defendant to pay restitution in the full amount of the bank's loss rather than the amount Defendant admitted converting. The Supreme Court vacated the restitution amount in excess of $288,000 and remanded the case for entry of an amended restitution award in that amount, holding that the district court's order was not supported by substantial evidence. View "State v. Waigand" on Justia Law

The Supreme Court affirmed the restitution order of the district court in this criminal matter, holding that this Court had jurisdiction to review the restitution order and that Defendant did not meet his burden to overturn the restitution order.Defendant pled guilty to possession of methamphetamine. He was sentenced to ten years in prison and ordered to pay a $1000 fine. The district court then ordered a "second category" of restitution apart from the fine totaling $593 for court costs and attorney fees. Defendant appealed, arguing that the second category of restitution was excessive. The Supreme Court affirmed, holding (1) this Court has jurisdiction to consider Defendant's appeal; and (2) the district court did not abuse its discretion in determining the amount of restitution Defendant had the ability to pay. View "State v. Hawk" on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's motion for a new trial, holding that the district court erred in applying too strict a standard in determining whether Defendant was entitled to a new trial under the circumstances of this case.Defendant, who was charged with sexual abuse of a child, requested the child's privileged mental health and counseling records. The district court denied the request. The court of appeals remanded the case, ruling that Defendant should have been granted access to the child's mental health and counseling records because they contained exculpatory information. On remand, the district court denied the motion for new trial after applying a weight of the evidence standard. The Supreme Court reversed, holding (1) the appropriate standard for a new trial determination after a district court fails to order production of exculpatory medical records is the material standard in Brady v. Maryland, 373 U.S. 83 (1963); and (2) because the district court applied the incorrect standard in denying the motion for new trial, the case must be remanded. View "State v. Barrett" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming one of Defendant's two convictions of sexual abuse in the third degree based on an aiding-and-abetting theory, holding that the contested count was supported by a factual basis.Defendant raped a woman, G.S., and then forced his companion, J.C., to have sex with the same woman against both of their wills. Defendant pled guilty to two counts of sexual abuse in the third degree. The victim in count I was identified as G.S., and the victim in count II was identified as J.C. On appeal, Defendant argued that there was no evidence that he committed a sex act against J.C. The court of appeals affirmed. The Supreme Court affirmed, holding that J.C. was a victim because Defendant forced him to commit a sex act against his will. View "State v. El-Amin" on Justia Law

In this appeal from a court of appeals decision affirming Defendant's resentencing without eliminating the jail fees relating to the count on which Defendant was acquitted on appeal, the Supreme Court reversed the assessment of $4935 in posttrial fees, holding that Defendant's reimbursement obligation must be reduced.Defendant was found guilty of two crimes, including a forcible felony. While Defendant was confined in the county jail until his sentencing, the sheriff filed a reimbursement claim for jail fees against Defendant. The court of appeals reversed Defendant's forcible felony conviction. On resentencing, the district court revised Defendant's prison sentence but left untouched the jail fees resulting from the dismissed conviction. The court of appeals affirmed. The Supreme Court reversed in part, holding that Defendant's reimbursement obligation under Iowa Code 356.7 must be reduced by $4935 because the costs for Defendant's confinement in the county jail were clearly attributed to the forcible felony charge on which Defendant ultimately received an acquittal. View "State v. Shackford" on Justia Law

The Supreme Court affirmed Defendant's convictions for assault with a dangerous weapon and third degree criminal mischief, holding that Iowa R. Evid. 5.701 and 5.702 did not require certain testimony concerning historical cell site data to be presented by an expert.Investigating officers used Defendant's cell phone records to place him in the general vicinity at the time of the incident giving rise to Defendant's convictions. On appeal, Defendant argued that his counsel provided ineffective assistance by not challenging the phone records as inadmissible hearsay and by not challenging the testimony provided by an officer as an unqualified expert. The Supreme Court affirmed, holding (1) the testimony at issue was not based on specialized knowledge and thus did not require an expert; and (2) therefore, Defendant's counsel was not ineffective for failing to challenge the phone records or the officer's testimony. View "State v. Boothby" on Justia Law

The Supreme Court reversed the judgment of the district court convicting Defendant of second-degree murder, holding that the exclusion of evidence regarding the victim's mental health records and the limitation of testimony on those records was not harmless error.On appeal, Defendant argued that the district court erred when it excluded his mental health records at trial and limited review of those records and erred in forbidding lay testimony on the victim's suicidal behavior. The court of appeals reversed on the evidentiary rulings regarding Defendant's medical records. The Supreme Court affirmed, holding (1) evidence of a person's suicidal disposition is not properly analyzed as character evidence under the Iowa Rules of Evidence in cases where the defendant alleges suicide; (2) the temporal proximity of the medical records was not too remote to be relevant to Defendant's defense that the victim committed suicide; and (3) the exclusion of the victim's medical records and limitation of related admissible testimony was not harmless error. View "State v. Buelow" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for operating while intoxicated first offense, holding that a peace officer does not violate a duty under Iowa Code 321J.11(2) by agreeing to a detainee's request for a retest on the machine that has already tested the detainee's blood alcohol level without also informing the detainee of the statutory right to an independent test at the detainee's expense.Specifically, the Supreme Court held (1) an officer must inform the detainee of the right to an independent test only in circumstances when the detainee has reasonably asked about that right or when a failure to disclose that right could be misleading; and (2) because neither of those circumstances were present in this case, the district court did not err in denying Defendant's motion to suppress. View "State v. Casper" on Justia Law

The Supreme Court affirmed Defendant's convictions and sentences for eluding while speeding and several unrelated offenses, holding that trial counsel was not ineffective for failing to challenge Defendant's eluding charge on double jeopardy grounds based on his guilty plea to speeding in the same incident.At age seventeen, Defendant pled guilty to a speeding citation without pleading guilty to the accompanying charge of eluding. When Defendant turned eighteen, the State charged him by trial information with eluding while speeding. Defendant pled guilty to the eluding charge. The court of appeals affirmed. The Supreme Court affirmed, holding (1) speeding is a lesser included offense that at trial would merge into a conviction for eluding while speeding, but under the circumstances of this case, Defendant cannot use double jeopardy principles as a sword to defeat his conviction for eluding; and (2) therefore, Defendant's ineffective assistance of counsel claims fail. View "State v. Roby" on Justia Law

The Supreme Court reversed the judgment of the district court convicting Defendant of first-degree murder, holding that a new trial was required because the marshaling instruction for that charge failed to cross-reference Defendant's insanity defense.On appeal, Defendant argued that his trial counsel provided ineffective representation by failing to object to the instruction at issue. The Supreme Court agreed, holding (1) the jury instructions were materially misleading without the cross-reference to the insanity defense in the marshaling instruction for first-degree murder and that trial counsel breached an essential duty by failing to object; and (2) this significant error in that marshaling instruction for the main offense undermines this Court's confidence in the verdict, requiring a new trial. View "State v. Davis" on Justia Law