Justia Iowa Supreme Court Opinion Summaries

Daniel Murillo, a registered sex offender, sought to modify his registry requirements under Iowa Code section 692A.128. Murillo had pleaded guilty to sexual abuse in the third degree in 2005 and was required to register as a sex offender. He completed a sex offender treatment program (SOTP) while incarcerated and received a certificate of completion in 2009. In 2022, Murillo applied to be removed from the sex offender registry, citing his completion of the SOTP and a low-risk assessment for recidivism.The Iowa District Court for Polk County denied Murillo's application, determining that he had not "successfully completed" the SOTP because he only admitted guilt to avoid a longer sentence. The court also found that Murillo posed an ongoing risk to the community. The Iowa Court of Appeals affirmed the district court's decision.The Iowa Supreme Court reviewed the case and held that the district court erred in determining that Murillo had not successfully completed the SOTP, as he had a certificate of completion from the Department of Corrections. However, the Supreme Court found that the district court did not abuse its discretion in denying Murillo's application for modification. The court concluded that the district court properly considered relevant factors, including Murillo's inconsistent admissions of guilt and the need for further treatment, in determining that he posed an ongoing risk to the community.The Iowa Supreme Court vacated the decision of the Court of Appeals but affirmed the judgment of the district court, maintaining Murillo's registration requirements. View "Murillo v. State of Iowa" on Justia Law

Chad Allen Staton was convicted by a jury of incest and sexual abuse of his daughter. He appealed his conviction, arguing that the evidence was insufficient, the district court erred by allowing his daughter to testify about a prior uncharged incident, and his right to allocute was violated when the sentencing court disallowed discussion of rejected plea offers. Staton contended that the rejected plea offers demonstrated his sincerity in professing innocence, which should mitigate his lack of remorse at sentencing.The Iowa District Court for Black Hawk County, presided over by Judge Linda M. Fangman, sentenced Staton to indeterminate prison sentences totaling forty years with a mandatory minimum of seventeen and a half years. Staton appealed, and the Iowa Court of Appeals affirmed his conviction and sentence, finding the evidence sufficient and the admission of the prior incident appropriate. The court also concluded that Staton’s right to allocute was not violated as he and his counsel had opportunities to address mitigation.The Iowa Supreme Court reviewed the case to address whether the defendant’s right to allocute was violated by disallowing discussion of rejected plea offers. The court held that the district court correctly cut off discussion of rejected plea offers during allocution, as such offers are inadmissible under Iowa Rule of Criminal Procedure 2.10(5). The court reasoned that allowing discussion of rejected plea offers could deter prosecutors from making plea offers. The court affirmed the decision of the Iowa Court of Appeals and the judgment of the district court, concluding that Staton’s right to allocute was not violated since he and his counsel were allowed to argue his professed innocence to explain his lack of remorse. View "State v. Staton" on Justia Law

Reuben Schooley was convicted of child endangerment causing bodily injury after an incident where he slapped his nine-year-old daughter, spanked her, yanked her by the shirt, and told her to leave the house. The child was found with marks on her collar and bruising on her buttocks. Schooley admitted to spanking her frequently and acknowledged that his actions were inappropriate. The jury found him guilty based on the evidence presented.The Iowa District Court for Emmet County sentenced Schooley to five years of incarceration. Schooley appealed, arguing that there was insufficient evidence to support his conviction and that his sentence was improperly influenced by a victim-impact statement from the guardian ad litem (GAL). He contended that the GAL was not authorized to provide such a statement and that it contained unproven allegations.The Iowa Supreme Court reviewed the case and found that sufficient evidence supported the jury's verdict. The court noted that the reasonableness of corporal punishment is generally a question for the jury and that the evidence showed Schooley's actions were excessive and abusive. The court also addressed Schooley's challenge to the GAL's victim-impact statement, concluding that Schooley had waived this issue by not raising it in the district court. Additionally, the court found no affirmative showing that the district court relied on improper information from the GAL's statement when sentencing Schooley.The Iowa Supreme Court affirmed Schooley's conviction and sentence, holding that the evidence was sufficient to support the jury's verdict and that the district court did not abuse its discretion in considering the GAL's statement. View "State of Iowa v. Schooley" on Justia Law

The defendant engaged in online conversations with an undercover police officer posing as a fifteen-year-old girl. He arranged to meet the girl for sex at a gas station shower room. Upon arrival, he was arrested and charged with solicitation of commercial sexual activity under Iowa Code section 710A.2A. The defendant argued that there was insufficient evidence to support the charge because he did not offer or promise anything of value in exchange for sexual activity. The district court rejected these arguments, and a jury convicted him.The Iowa District Court for Polk County denied the defendant's motion for a new trial and sentenced him to five years in prison. The Iowa Court of Appeals conditionally affirmed the conviction but remanded the case for the district court to reconsider the motion for a new trial under the correct standard. The defendant sought further review.The Iowa Supreme Court reviewed the case and found that the evidence was insufficient to show that the defendant was attempting to engage in commercial sexual activity. The court noted that while the defendant's behavior was reprehensible, he did not give or promise the undercover officer any item of value in exchange for a sex act. The court concluded that the statutory definition of "commercial sexual activity" requires an express or implied quid pro quo, which was not present in this case. Consequently, the court vacated the decision of the court of appeals, reversed the district court's judgment, and remanded the case for dismissal. View "State v. Fenton" on Justia Law

Sarah Berg, an employee at Casey’s General Store, activated three gift cards without paying for them and used one to purchase gas the next day. She was arrested for fourth-degree theft. The county attorney did not file a trial information for this charge within the required 45 days. Instead, a trial information was later filed for unauthorized use of a credit card.The Iowa District Court for Black Hawk County denied Berg’s motion to dismiss the trial information for unauthorized use of a credit card, despite the missed speedy-indictment deadline for the theft charge. Berg was found guilty following a trial on the minutes. She was sentenced to 120 days in jail (suspended), a fine (suspended), court costs, probation, and potential restitution. Berg appealed, arguing the district court erred in denying her motion to dismiss and that the evidence was insufficient to support her conviction. The Iowa Court of Appeals affirmed her conviction.The Iowa Supreme Court reviewed the case and affirmed the lower courts' decisions. The court held that fourth-degree theft and unauthorized use of a credit card are not the same offense for speedy-indictment purposes. The court reasoned that the charges relied on distinct underlying facts: the theft charge required proof of taking property valued between $300 and $750, while the unauthorized use charge required proof of using a credit card to obtain property or services. Therefore, the State was not precluded from filing the new charge after the 45-day period had elapsed. View "State of Iowa v. Berg" on Justia Law

A sixteen-year-old defendant, concerned that a poor Spanish grade might hinder his plans to study abroad, conspired with a friend to murder his Spanish teacher. They meticulously planned and executed the murder, later bragging about it to classmates. The defendant initially lied to the police but eventually pleaded guilty to first-degree murder, agreeing to challenge only his sentence. At sentencing, the State recommended life imprisonment with parole eligibility after thirty years, while the defendant argued against any minimum term. The district court sentenced him to life with parole eligibility after thirty-five years.The Iowa District Court for Jefferson County rejected the defendant's argument that a minimum sentence required expert testimony. The court considered various factors, including the impact on the victim's family and community, the defendant's role in the crime, and his potential for rehabilitation. The court found that the severity and premeditation of the crime warranted a minimum term of thirty-five years before parole eligibility.The Iowa Supreme Court reviewed the case, focusing on whether sentencing juvenile offenders to a minimum term before parole eligibility violates the Iowa Constitution and whether expert testimony is required to impose such a sentence. The court upheld the district court's decision, ruling that the Iowa Constitution does not categorically ban minimum sentences for juveniles and that expert testimony is not mandatory. The court found that the district court properly considered the relevant factors and did not abuse its discretion in sentencing the defendant to life with the possibility of parole after thirty-five years. The sentence was affirmed. View "State of Iowa v. Miller" on Justia Law

Eric Harris was arrested on March 25, 2023, on suspicion of arson and other crimes. He had his initial appearance before a magistrate the next day, March 26. The State filed its trial information on May 10, which was the forty-sixth day after Harris's arrest but the forty-fifth day after his initial appearance. Harris moved to dismiss the prosecution, arguing that the State violated the speedy-indictment rule by filing the trial information one day late.The Iowa District Court for Johnson County denied Harris's motion to dismiss. The court interpreted the speedy-indictment rule to mean that the forty-five-day period began on the date of Harris's initial appearance, not the date of his arrest. Consequently, the court found that the trial information filed on May 10 was timely.The Iowa Supreme Court reviewed the case and reversed the district court's decision. The Supreme Court held that under the pre-amendment version of Iowa Rule of Criminal Procedure 2.33, the forty-five-day period for filing a trial information begins on the date of the defendant's arrest, not the initial appearance. Since the State filed the trial information on the forty-sixth day after Harris's arrest, it was untimely. The court concluded that the district court erred in denying Harris's motion to dismiss and remanded the case for dismissal of the prosecution. View "State of Iowa v. Harris" on Justia Law

Nathan Olsen, convicted of a sex offense in Wisconsin in 2009, moved to Iowa where he was required to register as a sex offender. After serving a prison sentence for an unrelated crime, Olsen moved to Illinois where he was not required to register. He wished to return to Iowa, but doing so would require him to register again. Olsen filed an application in the district court to modify his status as a sex offender and the registration requirements that would apply to him in Iowa before he moved back. The district court dismissed his application, and the court of appeals affirmed the dismissal.The district court and the court of appeals both concluded that Olsen's claim was not ripe for adjudication because his application sought to modify a "hypothetical" registration requirement predicated on his potential future return to Iowa. Olsen argued that the statute permitting only those who currently live, work, or attend school in Iowa the opportunity to modify their sex offender registration requirements unlawfully discriminates against nonresidents in violation of the Privileges and Immunities Clauses of the Iowa and United States Constitutions.The Supreme Court of Iowa found that the residency restriction imposed by the statute prohibits nonresidents from seeking the same fundamental privilege to access Iowa’s courts that a resident receives. However, the court was unable to evaluate the State’s justification for treating residents and nonresidents differently due to lack of evidence. Therefore, the court remanded the case for the parties to present evidence and for the district court to rule on Olsen’s constitutional challenge in light of that evidence. The court also rejected the State's argument that Olsen was not eligible for modification because five years hadn’t passed from the date of commencement of his requirement to register. View "Olsen v. State of Iowa" on Justia Law

The case involves a defendant who appealed the denial of her motion to suppress evidence obtained from a traffic stop, a dog sniff of her vehicle, and a search of her purse. The defendant was driving slower than the speed limit, causing traffic issues, and crossed the centerline multiple times. The officer, suspecting drug-related activity due to the defendant's history of drug offenses, initiated a traffic stop and requested a K-9 unit. The dog sniffed the exterior of the vehicle, occasionally touching it with its paws, and alerted to the presence of drugs. A subsequent search of the vehicle and the defendant's purse revealed methamphetamine and related paraphernalia.The defendant argued that the traffic stop was unjustified, the dog sniff constituted an unconstitutional search because the dog touched the exterior of her vehicle, and the search of her purse was unlawful. The district court denied the motions to suppress, and the defendant was found guilty on three counts.The Supreme Court of Iowa affirmed the lower court's decision. The court held that the traffic stop was justified due to the defendant's driving behavior. It also ruled that the dog sniff did not violate the Fourth Amendment or the Iowa Constitution, as the dog was in a place where police had a right to be and the sniff only revealed the presence or absence of contraband. The court did not rule on the legality of the purse search, as the defendant failed to properly raise and preserve the issue for appeal. View "State of Iowa v. Bauler" on Justia Law

Shannon Hightower pleaded guilty to dependent adult abuse and theft in the second degree. She later appealed, arguing that there were defects in her guilty plea, her sentencing, and the conditions set for her appeal bond. Hightower also contended that Iowa Code section 814.29, which regulates judicial review of challenges to a guilty plea, was unconstitutional.The district court had found Hightower guilty based on her plea and sentenced her to concurrent prison terms. One of the court's reasons for the sentence was Hightower's failure to pay restitution prior to sentencing. After sentencing, Hightower filed a motion asking the court to order a stay of the sentence and to set a hearing to review concerns about her guilty plea. Alternatively, she asked the court to set an appropriate appeal bond. The court denied Hightower's request for a hearing about her guilty plea and set an appeal bond in the amount of $17,000 cash only.The Supreme Court of Iowa found that Hightower's guilty plea was defective due to the absence of an accurate advisory as to the maximum punishment she faced by pleading guilty. However, the court concluded that section 814.29 prevented it from vacating Hightower's plea. The court also agreed with Hightower that resentencing was required because the district court relied on an improper sentencing factor. Furthermore, the court agreed with Hightower that the district court erred by ordering unauthorized forfeiture requirements for Hightower’s appeal bond. The court affirmed Hightower’s conviction, vacated her sentence, and reversed the forfeiture requirements. The case was remanded for resentencing and for lawful disbursement of funds paid for Hightower’s release during the appeal. View "State of Iowa v. Hightower" on Justia Law