Justia Iowa Supreme Court Opinion Summaries

In Iowa in 2021, a mother of six, Paula Cole, left her five oldest children, ranging in age from 12 to five, asleep at home while she left to go to Walmart for groceries, taking her youngest, an infant, with her. While she was gone, a disagreement arose between two of the children, leading one to leave their apartment building. A neighbor, with whom the family had an open-door policy, helped the children and eventually called 911 due to the disagreement and the child leaving the building. Upon return, Cole was charged with child endangerment. She was convicted and appealed the decision. The court of appeals affirmed the conviction, but Cole sought further review from the Supreme Court of Iowa.The Supreme Court of Iowa reversed the conviction, holding that Cole did not create a risk that violated section 726.6(1)(a), which defines child endangerment as knowingly acting in a manner that creates a substantial risk to a child's physical, mental, or emotional health or safety. The court concluded that while leaving her children home alone could potentially pose risks, these were not risks created by Cole's decision to go shopping, but rather, they were ordinary risks of everyday life. The court also noted that no evidence suggested the home was unsafe, the older children could help care for the younger ones, and a neighbor was available to assist. The court stressed that not all risks children encounter are created by their parents or caregivers, and life inherently poses risks. Additionally, the court stated that a parent does not create a risk if the risk is part of the background risk of ordinary life. View "State of Iowa v. Cole" on Justia Law

In Iowa, the defendant, Jesse Jon Harbach, was involved in a single-vehicle rollover accident. Based on observations at the scene, an officer applied for a warrant to draw blood from Harbach. The test revealed methamphetamine but no alcohol. Harbach moved to suppress the evidence from the blood draw, arguing that the officer's claims of smelling alcohol and observing Harbach with bloodshot eyes and slurred speech were false. The district court agreed, suppressing the evidence. The state appealed, and the Supreme Court of Iowa reversed the decision, stating that the officer's observations of the defendant's physical state and the smell of alcohol were sufficient to establish probable cause for the search warrant. The court held that the officer's affidavit did not contain intentionally or recklessly false statements and the remaining content established probable cause for the issuance of the warrant. View "State of Iowa v. Harbach" on Justia Law

In this case heard by the Supreme Court of Iowa, the defendant, Morgan Marie McMickle, was charged with operating a motor vehicle while intoxicated (OWI). McMickle was stopped by law enforcement after rear-ending another vehicle and leaving the scene. The investigating officer obtained a search warrant to collect a blood sample from McMickle for chemical testing, which showed a blood alcohol content over three times the legal limit. Additionally, McMickle repeatedly asked to speak to her lawyer but was denied. She later filed a motion to suppress evidence, arguing that the use of a search warrant instead of the statutory implied consent procedure violated her rights, and that her right to counsel was violated under Iowa Code section 804.20.The district court granted McMickle's motion, determining that the officer's use of a search warrant was not authorized, that the officer had no statutory authority to collect and test bodily specimens, and that the officer's actions violated McMickle's constitutional rights to equal protection and due process. Additionally, the court found that the officer's refusal of McMickle's requests to speak to her lawyer violated her rights under section 804.20. As a result, the court ordered the suppression of McMickle's statements and the results of the blood test.However, the Supreme Court of Iowa reversed the district court's decision. The court held that the statutory implied consent procedure was not the exclusive means by which an officer can investigate suspected OWI offenses, and that a law enforcement officer's decision to obtain and execute a search warrant did not violate a suspect's constitutional rights. The court also ruled that although McMickle's rights under section 804.20 were violated, the blood test results should not have been suppressed because they were obtained through a legally issued search warrant, independent of any violation of section 804.20. The case was remanded back to the lower court. View "State of Iowa v. McMickle" on Justia Law

In the state of Iowa, a police officer investigated a suspected case of driving a motor vehicle while intoxicated. The officer pulled over the suspect, Colby Laub, and obtained a search warrant to collect a breath specimen for chemical testing after Laub refused to participate in field sobriety testing. The chemical testing showed that Laub had a blood alcohol content well above the legal limit, and he was subsequently arrested. Laub moved to suppress the evidence of the chemical breath test, as well as statements he had made to the officer, arguing that the officer was required to invoke the statutory implied consent procedure and give him the opportunity to refuse to provide a sample, rather than proceed with a search warrant. The district court agreed with Laub and granted his motion on the grounds that the officer had no statutory authority to obtain a search warrant to collect and test bodily specimens, and that doing so violated Laub's constitutional rights to equal protection and due process. The state appealed this decision.The Supreme Court of Iowa reversed the district court's decision. The court found that the district court erred in holding that the statutory implied consent procedure is the only way a law enforcement officer can obtain a bodily specimen and conduct chemical testing in investigating an OWI case. The court noted that the officer's decision to obtain a search warrant instead of invoking the statutory implied consent procedure did not violate the defendant's rights to equal protection or due process. The court also disagreed with the district court's interpretation of the statute, stating that the statutory implied consent law is not the exclusive means by which a law enforcement officer can obtain a breath sample in an OWI case. Therefore, the court reversed the district court's suppression ruling and remanded the case for further proceedings. View "State of Iowa v. Laub" on Justia Law

The Supreme Court of Iowa examined a case where a defendant, T.J., was ordered to pay restitution after the court had already dismissed and expunged all charges upon completion of a deferred judgment. T.J. had pleaded guilty to criminal mischief and was placed on unsupervised probation as part of the deferred judgment. After successfully completing the terms of the deferred judgment, the court dismissed and expunged the charge. However, later that day, the court set a hearing for restitution and two months later ordered T.J. to pay over $6,000 in restitution to the victim.The main question before the court was whether it had the authority to impose a restitution order after the charges had been dismissed and expunged. The court concluded that it did not. The court found that a dismissal and expungement of a criminal charge after successful completion of probation under a deferred judgment should be treated no differently than other situations where a defendant is discharged from probation. The court stated that if a court unconditionally dismisses all pending charges, there's no need for sentencing or any other action by the court before the judgment becomes final. That finality terminates the court’s jurisdiction in the matter.In this case, the court determined that no statutory or constitutional provision empowered the district court to retain jurisdiction to order restitution after dismissing and expunging criminal charges. Therefore, the court found that it lacked jurisdiction to enter the restitution order after it dismissed and expunged the lone charge in the trial information, and as a result, the order was void. Hence, the writ of certiorari was granted, and the restitution order was vacated. View "State of Iowa v. T.J.W." on Justia Law

In the Supreme Court of Iowa, the State of Iowa appealed against the district court's dismissal of an extortion charge against Jerome Bailey Sr. Bailey had demanded $10,000 from his former property manager, threatening to expose her for allegedly sending a registered sex offender to his house, which he claimed was a childcare facility. The district court dismissed the charge, concluding that Bailey's threats were made with the reasonable belief that he had a right to make them under Iowa's extortion statute. However, the Supreme Court of Iowa reversed the district court's decision and remanded the case for further proceedings. The court reasoned that the statutory defense in the extortion statute, which allows threats made with a reasonable belief of a right to make them, does not apply automatically at the motion to dismiss stage if there are disputed facts. The court found that whether Bailey had a reasonable belief that he could demand $10,000 for the alleged misconduct was a question for a jury to decide, not a matter for dismissal. View "Iowa v. Bailey" on Justia Law

This case was heard by the Supreme Court of Iowa and involved an appeal by a defendant, Demetrias Martin, who was challenging the mandatory minimum term imposed with his sentence for first-degree robbery. The main issue in the case was the use of a risk assessment tool that categorized Martin as a "high" risk for violent recidivism and a "moderate/high" risk for continuous victimization. Martin argued that the district court abused its discretion by relying on these conclusions without any information about how the tool actually arrived at them.In March 2019, Martin was sentenced to twenty-five years in prison with a requirement to serve at least 70% of his sentence under a statutory mandatory minimum. After a retroactive amendment to the robbery sentencing statute in June 2019, Martin was eligible for resentencing with a potential mandatory minimum as low as 50%. The amendment required the district court to consider certain factors when determining the mandatory minimum to impose, including a validated risk assessment.The Supreme Court of Iowa affirmed the decision of the lower courts, holding that the district court did not abuse its discretion in considering the results of the risk assessment tool. The court found that Martin had notice of the risk assessment and had the opportunity to challenge it but failed to do so. The court held that a district court does not abuse its discretion by considering risk assessment information in a presentence investigation report where a defendant has notice of the risk assessment and fails to present evidence exposing some actual unsoundness in it. Therefore, the court rejected Martin's argument and affirmed the sentence imposed by the lower court. View "State of Iowa v. Martin" on Justia Law

In this case, the Supreme Court of Iowa addressed whether the district court erred in ordering the placement of a sexually violent predator in a transitional release program over the State’s objection. The State argued that the offender was ineligible for that program without a relapse prevention plan (RPP) accepted by his treatment provider at the Civil Commitment Unit for Sexual Offenders (CCUSO) as required by Iowa Code section 229A.8A(2)(d) (2022). The district court determined that the offender’s plan, approved by the offender’s expert, satisfied that statutory requirement. The State appealed, asserting that the court erred by substituting its judgment for that of CCUSO’s staff.The Supreme Court of Iowa held that a writ of certiorari is the proper form of appellate review, and granted the petition. On the merits, the court held that the district court erred by substituting its judgment for that of CCUSO’s staff. The court agreed with the State that the offender was ineligible for placement in the transitional release program because his treatment provider at CCUSO had not accepted his proposed RPP. The court also rejected the offender's substantive due process claims. Consequently, the court sustained the writ and vacated the district court’s ruling. View "In Re Detention of Schuman" on Justia Law

This case from the Supreme Court of Iowa involves a juvenile, I.S., who was charged with sexual exploitation of a minor and possession of child pornography. The juvenile court initially waived its jurisdiction over the case, allowing it to be tried in the district court. However, the juvenile court later vacated its waiver and reclaimed jurisdiction over the case. The State sought a review of the juvenile court's decision to vacate its earlier order, arguing that the juvenile court no longer had jurisdiction or authority to modify or vacate the waiver order once it had been issued.The Supreme Court of Iowa held that the juvenile court did not have the authority to reclaim jurisdiction over the case after it had waived it to the district court. The court found that there was no provision in Iowa law for such a "revocation of waiver." The court reasoned that once a case has been transferred or waived to another court, the transferring court loses jurisdiction over the parties. The court also noted that allowing a juvenile court to reclaim jurisdiction could lead to disruption of proceedings and friction between the district and juvenile courts.Therefore, the court sustained the State's writ, vacated the juvenile court's revocation of its waiver of jurisdiction, and remanded the case, with the expectation that any further proceedings would occur in the district court. View "State of Iowa v. Iowa Juvenile Court for Plymouth County" on Justia Law

In this case from the Supreme Court of Iowa, the appellant, David Gordon, a minor at the time of committing his crimes, was charged with theft in the first degree and willful injury resulting in bodily injury. He pleaded guilty and was sentenced to ten years in prison for the theft conviction and five years for the assault conviction, with the sentences to run concurrently. Gordon appealed the sentence and also filed a motion requesting reconsideration of the sentence under Iowa Code § 902.4. The district court reconsidered the sentence and placed Gordon on probation for up to five years. Gordon then filed a petition for writ of certiorari challenging his resentencing, arguing that the district court had abused its discretion by not granting him a deferred judgment in its initial sentencing, and then by wrongly concluding that it lacked the authority to do so under § 902.4 when resentencing him.The Supreme Court of Iowa affirmed the district court's decisions. The court held that the district court did not abuse its discretion in the initial sentencing. It found that the district court had considered and weighed the arguments for and against a deferred judgment, and had thoroughly explained its reasoning for the sentence imposed. As for Gordon's argument about the district court's power to defer judgment when reconsidering a sentence under § 902.4, the Supreme Court held that a deferred judgment involved more than a sentence. It involved the deferring of a judgment adjudicating guilt as well as a sentence. The court concluded that the district court correctly interpreted its authority under § 902.4 when it determined that it could not defer judgment when reconsidering Gordon's sentence. Therefore, the court affirmed Gordon's conviction and sentence and annulled the writ of certiorari. View "State of Iowa v. Gordon" on Justia Law