Justia Iowa Supreme Court Opinion Summaries

The Supreme Court reversed the order of the district court revoking Defendant's deferred judgment, holding that the district court failed to include sufficient factual findings to support revocation.Defendant pled guilty to child endangerment. The district court ordered the judgment deferred and Defendant to pay a civil penalty, court costs, and attorney fees. Thereafter, the State filed an application to revoke deferred judgment and pronounce sentence, alleging that Defendant had not paid the balance due. The court found that Defendant had violated the terms of her probation and revoked the deferred judgment. The Supreme Court reversed, holding (1) the holding in State v. Damme, 944 N.W. 2d 98 (Iowa 2020), that a defendant who is not challenging her guilty plea or conviction has good cause to appeal an alleged sentencing error when the sentence was neither mandatory nor agreed to in the plea bargain extends to appeals from orders revoking deferred judgments; and (2) the district court's factual findings were insufficient. The Court remanded the case to the district court for a new hearing on the State's application to revoke Defendant's deferred judgment. View "State v. Thompson" on Justia Law

The Supreme Court affirmed Defendant's conviction of homicide by intoxicated operation of a vehicle, holding that the district court did not err by denying his requested instruction for homicide by reckless driving as a lesser included offense and by excluding certain evidence.Defendant drove his pickup through a stop sign and broadsided a minivan. One of the passengers in the minivan, a six-month-old infant who wasn't secured in a child restraint system, died from injuries suffered in the crash. Defendant was convicted of homicide by intoxicated operation, and the trial court denied his motion for a new trial. The Supreme Court affirmed, holding (1) the district court did not err in refusing to give to the jury Defendant's requested homicide by reckless driving instruction because it was not a lesser included offense; and (2) the district court did not err in preventing Defendant from offering evidence that the infant wasn't secured in a child restraint seat. View "State v. Johnson" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court denying Defendant's motion for new trial based on a claim of newly discovered evidence, holding that the district court did not abuse its broad discretion in denying Defendant's motion for new trial.In 2014, Defendant registered as a sex offender in Iowa. In 2016, Defendant failed to appear at the sheriff's office to verify his registration information. Defendant was subsequently convicted of failure to comply with the sex offender registry. Thereafter, Defendant filed a motion for new trial based on newly discovered evidence. The district court denied the motion, finding that the newly discovered evidence was not material and would not have changed the jury's verdict. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying the motion for new trial. View "State v. Uranga" on Justia Law

The Supreme Court affirmed Defendant's convictions for misdemeanor possession of of marijuana and felony eluding with marijuana, holding that the convictions do not merge.After convicting Defendant the district court imposed concurrent sentences. On appeal, Defendant argued that the possession convictions merged with the eluding charges. The State argued in response that the statutory scheme demonstrates that the legislature intended cumulative punishments for these offenses. The Supreme Court affirmed, holding (1) under the legal-elements test, it is impossible to commit felony eluding with marijuana without possessing it; but (2) the legislature prescribed cumulative punishments for the two offenses. View "State v. Johnson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the judgment of the district court ordering Defendant to register as a sex offender after he entered an Alford plea to child endangerment, holding that the evidence was insufficient to prove sexual motivation beyond a reasonable doubt under Iowa Code 692A.126 and that the proper remedy was to remand and give the State an opportunity to prove sexual motivation.The district court relied on Defendant's Alford plea and a victim impact statement from the child victim's mother to find that Defendant's underlying conduct was sexually motivated. The court ordered Defendant to register as a sex offender. The court of appeals remanded the cause, finding that victim statements do not provide sufficient evidence that the offense of conviction was sexually motivated beyond a reasonable doubt but that the minutes of testimony identified evidence to establish that the offense could have been sexually motivated. The Supreme Court affirmed the court of appeals, vacated the order requiring Defendant to register as a sexual offender, and remanded, holding that, under the circumstances, the State is allowed to introduce the facts from the minutes in an effort to support its request that Defendant be required to register as a sex offender. View "State v. Chapman" on Justia Law

The Supreme Court reversed the judgment of the district court convicting Defendant of violating Iowa Code 724.4C, which criminalizes carrying a dangerous weapon while intoxicated, holding that the jury instructions were erroneous because section 724.4C prohibits only carrying, which requires more than mere possession.On appeal, Defendant argued that the jury instructions improperly allowed the jury to convict him based on conduct not covered under the statute. Specifically, Defendant argued that the jury could have convicted him on a finding of possession alone, rather than carrying a dangerous weapon. The Supreme Court reversed and remanded the case for a new trial, holding (1) the jury instructions that allowed the jury to convict Defendant if he either carried or possessed a dangerous weapon misstated the law; and (2) the instructional error prejudiced Defendant and required reversal. View "State v. Shorter" on Justia Law

The Supreme Court vacated the order of restitution in this criminal case for the reasons explained today in State v. Davis, __ N.W.2d __ (Iowa 2020), concluding that interim orders on components of restitution requiring a reasonable ability to pay are neither appealable nor enforceable, but because the district court did not have the benefit of State v. Albright, 925 N.W.2d 144 (Iowa 2019) in issuing the restitution order, the order is vacated and the case remanded for further proceedings.Defendant entered a guilty plea to sexual abuse in the third degree. The court placed Defendant on probation, ordered him to register as a sex offender, and ordered that Defendant pay $204 in court costs, stating that additional amounts could be assessed at a later date. Defendant filed this direct appeal from his judgment of sentence, arguing that the district court erred in ordering him to pay restitution when it did not know the total amount of those costs and had not conducted a reasonable-ability-to-pay determination. The State argued in response that Defendant's appeal was unripe because no final restitution order had been entered. The Supreme Court vacated the restitution order and remanded the matter for further proceedings because the district court did not have the benefit of Albright. View "State v. Staake" on Justia Law

In this criminal action, the Supreme Court vacated the restitution awarded and clarified State v. Albright, 925 N.W.2d 144 (Iowa 2019), holding that defendants may seek appellate review of interim restitution orders in a direct appeal of right from the judgment of conviction.Appellant filed a direct appeal from his judgment of conviction, challenging only the restitution award, which was awarded without a determination of his reasonable ability to pay and without a final order of restitution. The State argued that under Albright, which held that "any temporary, permanent, or supplemental order regarding restitution is not appealable or enforceable until the court files its final order of restitution," the appeal must be dismissed. The Supreme Court vacated the restitution orders, holding (1) interim restitution orders are not enforceable until the district court determines the defendant's reasonable ability to pay all items of restitution and enters the final order of restitution; (2) there is no right of direct appeal from interim restitution orders preceding the court's final order of restitution, but defendants may seek appellate review of interim restitution orders in a direct appeal of right from the judgment of conviction; and (3) because the district court did not have the benefit of Albright, this case is remanded for further proceedings. View "State v. Davis" on Justia Law

In this criminal case arising from Appellant's act of writing checks without authorization from a bank account that was not hers the Supreme Court reversed the judgment of the district court denying Appellant's motion for acquittal, holding that the State failed to present sufficient evidence supporting a conviction under Iowa Code 714.1(6).Appellant was convicted under section 714.1(6), which forbids knowingly presenting a check that will not be paid when presented. The checks the State charged Appellant with writing were paid when presented. On appeal, Appellant argued that presenting a check without authorization was different than providing a check one knows will not be paid when presented. The Supreme Court agreed and reversed, holding that the State failed to present sufficient evidence that Appellant knew the checks would not be paid when presented, and therefore, there was insufficient evidence to support Appellant's conviction under section 714.1(6). View "State v. Schiebout" on Justia Law

The Supreme Court affirmed Defendant's sentence for theft after Defendant pleaded guilty, holding that "good cause" under the newly amended Iowa Code 814.6 means a "legally sufficient reason," and the good cause requirement is satisfied when the defendant appeals a sentence that was neither mandatory nor agreed to in the plea bargain.Defendant pleaded guilty to two separate charges of theft in the third degree. The court sentenced Defendant to an indeterminate term of two years of incarceration for each case to run concurrently. Defendant appealed, arguing that the sentencing court abused its discretion by considering improper factors when imposing her sentence. The State responded that the Supreme Court lacked jurisdiction over Defendant's appeal without a showing of good cause under the newly amended Iowa Code 814.6. The Supreme Court affirmed, holding (1) Defendant satisfied the good-cause requirement to proceed with her appellate challenge to the sentence; and (2) on the merits, Defendant's challenge to her sentence failed. View "State v. Damme" on Justia Law