Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction of voluntary manslaughter and assault with intent to cause serious injury, holding that Defendant was not entitled to a pretrial evidentiary hearing and that Defendants remaining challenges were without merit.Defendant was charged with one count of murder and two counts of attempted murder. Following a jury trial, Defendant was convicted of the lesser included offenses of one count of voluntary manslaughter and two counts of assault with intent to cause serious injury. On appeal Defendant argued, among other things, that the district court should have held a pretrial hearing pursuant to section 704.13 to determine his immunity from prosecution before trial. The Supreme Court affirmed, holding (1) the district court did not err in refusing to conduct a pretrial hearing on Defendant's justification defense; (2) the trial evidence was sufficient to prove lack of justification; and (3) Defendant's remaining allegations of error were without merit. View "State v. Wilson" on Justia Law

The Supreme Court vacated Defendant's guilty plea to possessing a tool with the intent to use it in the unlawful removal of a theft detection device under Iowa Code 714.7B(3), holding that there was no factual basis to support Defendant's guilty plea to this charge.Defendant's conviction arose from his act of using bolt cutters to cut the padlock off of a steel cable wrapped around a riding lawn mower on display outside of a Mills Fleet Farm. Defendant pled guilty violating section 714.7B(3). On appeal, Defendant argued that the padlock-steel cable combination device he cut with bolt cutters was not a "theft detective device" under section 714.7B, and therefore, his trial counsel was ineffective for allowing him to plead guilty to this charge.The Supreme Court agreed and vacated Defendant's guilty plea, holding (1) the padlock-steel cable combination did not constitute a "theft detective device" under the statute, and therefore, there was no factual basis to support Defendant's guilty plea; and (2) Defendant's counsel was ineffective for allowing Defendant to plead guilty. View "State v. Ross" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of child endangerment, holding that the evidence was sufficient to support Defendant's conviction.During trial, the State was required to prove Defendant had custody of her child and that she knowingly acted in a manner that created a substantial risk to her child's health or safety. The district court concluded that the State met its burden of production and persuasion. The Supreme Court affirmed, holding that Defendant's failure to remove her child from a physical environment that caused a risk of fire was sufficient to establish that Defendant had knowledge she had created or allowed her child to remain in a physical environment that posed a substantial risk to her child's physical health and safety. View "State v. Folkers" on Justia Law

The Supreme Court annulled the writ of certiorari sought by Defendant after the district court denied his motion to correct an illegal sentence, holding that Iowa Code 124.413 and 901.12 serve to reduce the minimum period of confinement for specific criminal drug offenses and that Defendant's minimum period of confinement was not eligible for the one-half reduction.Defendant pled guilty to possession of methamphetamine with intent to deliver and to possession or control of a firearm. Defendant's guilty plea to the firearm charge enhanced the drug charge by doubling his maximum sentence to fifty years. The legislature later amended section 124.413 and created section 901.12, which amended Iowa law by retroactively reducing particular mandatory sentences by one-half. Defendant filed a motion to correct an illegal sentence arguing that section 901.12 reduced his minimum period of confinement by one-half. The district court denied the motion. The Supreme Court granted certiorari review but then annulled the writ, holding that Defendant's firearm-enhanced sentence was not eligible for the one-half reduction. View "Campuzano v. Iowa District Court for Polk County" on Justia Law

The Supreme Court dismissed Appellant's appeal from an order of the district court directing Appellant to pay room and board reimbursement for the seventy-eight days Appellant spent in the Mills County jail, holding that this Court lacked jurisdiction to consider matters raised in the restitution order or any other subsequent order of the court.On September 24, 2018 Appellant entered guilty pleas in two sex abuse cases. On October 5, after Appellant was sentenced, the sheriff a room and board reimbursement claim seeking a total of $4680 for the time Appellant spent in jail. The district court approved the claim and ordered Appellant to pay the amount. Appellant appealed, seeking relief from the district court's September 24 order. However, Appellant's entire argument was a challenge to the October 5 order. The Supreme Court dismissed the appeal, holding that it lacked jurisdiction to consider matters raised in the October 5 restitution order. View "State v. Boyer" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing Appellant's petition for postconviction relief, holding that the limitations period for challenging Appellant's convictions had expired and that his resentencing did not bring about a new limitations period for attacking his conviction.In 2011, Appellant pled guilty to second-degree robbery and forgery. In 2015, the district court granted Appellant's motion to correct an illegal sentence. Appellant was resentenced. That same, year, Appellant filed the instant petition for postconviction relief. The State moved for summary judgment, arguing that Appellant's petition was time barred under the three-year statute of limitations in Iowa Code 822.3. The district court dismissed the petition. The court of appeals affirmed. The Supreme Court affirmed, holding that the resentencing of Defendant, which did not affect his underlying convictions, did not restart section 822.3's time clock. View "Sahinovic v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court imposing a seventeen and one-half year mandatory minimum prison term before parole eligibility on Defendant's second resentencing for attempted murder during a home invasion after considering the youth sentencing factors under State v. Roby, 897 N.W.2d 127 (Iowa 2017), holding that there was no error in the sentence and that counsel was not constitutionally ineffective.Defendant was seventeen years old at the time of the crime and was since resentenced twice, once in 2014 and once in 2018, as caselaw on juvenile sentencing evolved. In this appeal from his latest resentencing, Defendant argued that the district court failed to follow the Supreme Court's 2017 mandate to apply Roby and that his counsel was constitutionally ineffective for failing to retain a defense expert on the youth sentencing factors. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in applying the Miller/Lyle/Roby factors and deciding to impose the mandatory minimum sentence; and (2) Defendant's defense counsel had no duty to present a defense expert to testify regarding the Roby factors where Defendant decided to forgo retaining a defense expert. View "State v. Majors" on Justia Law

The Supreme Court vacated in part and affirmed in part the decision of the court of appeals affirming Defendant's conviction of voluntary manslaughter, holding that the court of appeals correctly found that the district court correctly determined that Defendant was not justified in his use of deadly force because he continued the incident which resulted in the victim's death.On appeal from his conviction of voluntary manslaughter Defendant argued that he was justified in his use of deadly force. The district court rejected the argument, finding that Defendant continued the incident with the victim and could have pursued an alternative course of action by retreating. The court of appeals affirmed, concluding that, while Defendant did not continue the incident with the victim, Defendant was not justified in his use of self-defense because he had an alternative course of action available. The Supreme Court held (1) Defendant continued the incident that resulted in the victim's death, and therefore, substantial evidence supported the district court's finding that Defendant was not justified in his use of deadly force; and (2) Defendant was not entitled to relief on his due process and equal protection claims. View "State v. Fordyce" on Justia Law

In this appeal challenging several district court rulings in a grand jury proceeding the Supreme Court affirmed in part and reversed in part the judgment of the district court, holding that the State cannot subpoena a criminal defense expert but that the prosecution's contact with the expert does not merit recusal and that there was no basis to quash the grand jury proceeding.Before the grand jury proceedings, the prosecutor contacted an expert witness retained by John Doe, who faced possible criminal charges, and asked the expert her opinions about the matter. When the expert declined to substantively respond, the prosecutor served the expert with a subpoena to appear before the grand jury. Doe moved to quash the subpoena and to disqualify the prosecutor from the proceeding. Doe also sought to quash the grand jury proceedings. The district court denied the motion. The Supreme Court affirmed in part and reversed in part, holding (1) the district court erred in not quashing the grand jury subpoena of Defendant's retained expert; (2) the issuance of the subpoena did not amount to the kind of misconduct that requires the disqualification of the prosecutor; and (3) the district court did not err in declining to quash the grand jury. View "In re 2018 Grand Jury of Dallas County v. Doe" on Justia Law

In this criminal case in which Defendant was charged with sexually abusing his fourteen-year-old daughter, S.V., the Supreme Court reversed the district court's preliminary ruling that a video recording of a forensic interview of S.V. was not admissible under the residual exception to the hearsay rule, holding that the district court committed two overarching error in its analysis of the preliminary question.After the district court granted Defendant's motion to exclude the forensic interview the State sought a definitive ruling on four of the findings requisite for evidence to be admitted under the residual exception - trustworthiness, materiality, notice, and service of the interests of justice. The district court concluded that the video was not admissible under the residual hearsay exception. The Supreme Court reversed, holding that the district court erred in concluding that it had discretion regarding the admission of the videotape and that the district court's analysis of the preliminary question was contaminated with extraneous considerations relating to confrontation clause jurisprudence. View "State v. Veverka" on Justia Law