Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction for carrying a firearm on the grounds of a school, holding that a school district-owned athletic complex that is not contiguous to a classroom building does not qualify as grounds of a school under Iowa Code 724.4B and that the district court did not err in giving the jury an instruction defining "grounds of a school."Specifically, the Supreme Court held (1) the "grounds of a school" as used in Iowa Code 724.4B can include school district-owned athletic facilities that are not contiguous to the classroom building, and there was substantial evidence that the parking lot where Defendant was carrying a firearm qualified as grounds of a school; and (2) the district court properly instructed the jury that the grounds of a school may include recreational and cultural facilities. View "State v. Mathias" on Justia Law

In this postconviction relief case, the Supreme Court affirmed the judgment of the district court dismissing Appellant's claim without an evidentiary hearing that he was actually innocent of robbery in the first degree and that his conviction should be vacated, holding that Appellant was not innocent in any sense of the word.Appellant pleaded guilty to robbery in the first degree, in violation of Iowa Code 711.21. This case arose out of Appellant's second application for postconviction relief. Appellant argued in his application that he was actually innocent of robbery in the first degree because a BB gun is not a dangerous weapon. The district court summarily denied application. The Supreme Court affirmed, holding (1) actual innocence requires proof of factual innocence with respect to the challenged conviction, including any lesser included offenses; and (2) Appellant did not establish a claim of actual innocence upon clear and convincing evidence that he was factually innocent of the offense of conviction. View "Dewberry v. State" on Justia Law

The Supreme Court affirmed in part and vacated in part the decision of the court of appeals reversing Defendant's conviction and remanding the case for a new trial, holding that trial counsel was not ineffective for failing to object to a jury instruction on the outdated version of the "stand your ground" justification and that the district court did not abuse its discretion in excluding character evidence of the victim.A jury found Defendant guilty of murder. During trial, Defendant asserted the justification of self-defense and defense of others. On appeal, the court of appeals held (1) the district court did not abuse its discretion in excluding certain character evidence of the victim, (2) there was sufficient evidence to support the conviction, but (3) the outdated justification instruction was prejudicial. The Supreme Court vacated the court of appeals' decision in part and affirmed the judgment of the district court, holding (1) trial counsel was not ineffective for not objecting to the instruction because engaging in an illegal activity disqualified Defendant from asserting stand-your-ground justification; and (2) the character evidence at issue was properly excluded because Defendant was unaware of the victim's specific conduct. View "State v. Baltazar" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction for sexual abuse in the second degree and lascivious acts with a child, holding that there was no error in the trial court's evidentiary rulings.Specifically, the Supreme Court held (1) the district court did not abuse its discretion in excluding certain evidence proffered by Defendant; (2) the district court did not err in admitting certain hearsay testimony under the medical diagnosis or treatment exception to the general rule; and (3) even if defense counsel breached an essential duty in failing to object to certain hearsay testimony the admission of the testimony did not amount to constitutional prejudice. View "State v. Walker" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the order of the district court approving a sheriff's claim for reimbursement of jail room and board for Defendant's pretrial detention, holding that because the sheriff did not ask that the fees be included in restitution the district court was not required to take into account Defendant's reasonable ability to pay.Defendant was convicted of arson in the second degree. Thereafter, the sheriff sought recovery of fees under Iowa Code 356.7 for Defendant's 197 days of incarceration at the county jail but did not ask that the fees be included in restitution. The district court ordered Defendant to pay the requested amount. Defendant appealed, arguing that the court should have determined his reasonable ability to pay the jail fees before awarding them. The court of appeals affirmed the order. The Supreme Court affirmed, holding that because the fees were not awarded as part of restitution the amount was not subject to the "reasonable ability to pay" limitations on restitution set forth in Iowa Code chapter 910. View "State v. Gross" on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's motion to suppress all evidence stemming from a stop of his vehicle, holding that the district court erred in finding that the deputy developed reasonable suspicion of other criminal activity before unreasonably prolonging the stop.After Defendant was stopped for violating Iowa Code 321.297(2) the deputy asked Defendant and his passenger questions. Finding the answers suspicious, the deputy sought permission for a consent search. Defendant consented. After a search of the car, the deputy located more than eighty pounds of marijuana in the trunk. Defendant filed a motion to suppress the evidence, which the district court denied. The Supreme Court reversed, holding that the delay of Defendant's stop was measurable, unreasonable, and in violation of Defendant's Fourth Amendment rights. View "State v. Salcedo" on Justia Law

The Supreme Court affirmed Defendant's conviction of a class C felony drug offense and prison sentence, holding that immigration status per se is not an appropriate sentencing consideration but that immigration status may be taken into account to the extent it affects an otherwise relevant sentencing factor.Defendant, a Mexican national, pled guilty to a felony drug offense and was placed on immigration hold for likely deportation. Defendant sought probation, but the district court imposed a prison sentence, expressing the view that it would not be feasible to order probation for a defendant who was going to be deported to Mexico. The Supreme Court affirmed, holding (1) a defendant's immigration status may not be the basis for a sentence, but to the extent it affects an otherwise relevant sentencing factor it may be taken into account; and (2) on the record, the district court properly determined that probation would not be appropriate for someone whose probation would need to be supervised in Mexico. View "State v. Valdez" on Justia Law

The Supreme Court conditionally remanded this case involving Defendant's conviction for assault with attempt to commit sexual abuse; pattern, practice, or scheme to engage in sexual exploitation by a counselor or therapist; and child endangerment, holding that the trial court should have conducted a Iowa R. Evid. 5.412 hearing to determine whether one of the alleged victims made false accusations of sexual abuse against her parents.Defendant, the former owner of a school for troubled youth, was convicted of two offenses involving acts of sexual misconduct against a former female student and a third offense relating to the school's physical mistreatment of two former male students. The Supreme Court affirmed on condition and remanded with directions, holding (1) the evidence was sufficient to sustain Defendant's convictions; (2) the district court did not err in declining to consider ineffective assistance claims as part of motion for new trial proceedings; but (3) the district court erred by failing to conduct a rule 5.412 hearing before or during trial to determine whether the female student made false accusations of sexual abuse against her adoptive or foster parents. View "State v. Trane" on Justia Law

The Supreme Court affirmed the district court's judgment convicting Defendant of first-degree murder, holding that Defendant's Sixth Amendment rights of confrontation or compulsory process were not violated when the district court refused to permit Defendant during trial to call a witness who intended to invoke his Fifth Amendment privilege against self-incrimination on all questions.In his retrial for murder, Defendant sought to call a witness so that the jury could him him "take the Fifth" and thus infer the witness's guilt. The district court refused to permit Defendant to call the witness because, pursuant to State v. Bedwell, 417 N.W.2d 66 (Iowa 1987), the jury is not entitled to draw inferences favorable to the defense from a witness's decision to exercise his constitutional privilege. The court of appeals reversed, distinguishing Bedwell on grounds that the witness had testified in Defendant's prior trial and the district court failed to ascertain the scope of his privilege question by question. The Supreme Court vacated the court of appeals' decision and affirmed the district court, holding (1) under the circumstances, Bedwell provides a categorical rule against compelling the witness to assert his Fifth Amendment privilege in front of the jury; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "State v. Heard" on Justia Law

The Supreme Court reversed the magistrate's dismissal of three pending misdemeanor charges against Defendant based on the legal proposition that Iowa courts lack jurisdiction over crimes committed on the Meskwaki Settlement, holding that the State may assert jurisdiction involving crimes committed on tribal lands by non-Indians involving either victimless crimes or non-Indian victims.An officer of the Meskwaki Nation Police Department filed two cases in district court alleging that Defendant committed the misdemeanor crimes of trespass, possession of drug paraphernalia, and violation of a no-contact order while on the Meskwaki Settlement. The magistrate dismissed the charges, concluding that recent federal legislation removed state jurisdiction for crimes committed on the Settlement. The Supreme Court reversed the dismissal of the charges and vacated the remaining portions of the district court's order, holding that the recent legislation left undisturbed state court criminal jurisdiction involving criminal acts involving non-Indians. View "State v. Stanton" on Justia Law