Justia Iowa Supreme Court Opinion Summaries

In this appeal, Appellant, who at age thirteen shot and killed his mother, raised challenges to Iowa’s youthful offender laws. Specifically, he argued (1) Iowa Code 232.45(7)(a) does not provide statutory authority to try a thirteen-year-old as a youthful offender, (2) Iowa Code 232.45(7) and Iowa Code 907.3A constitute unconstitutional cruel and unusual punishment, and (3) the sentencing court abused its discretion by incarcerating him. The Supreme Court affirmed Appellant’s conviction as a youthful offender and his fifty-year indeterminate sentence with immediate parole eligibility, holding that the district court did not abuse its discretion in sentencing Appellant to a prison term rather than releasing him on probation or placing him in a transitional facility based on an individualized assessment of Defendant under a constitutional statutory scheme. View "State v. Crooks" on Justia Law

The Supreme Court affirmed the judgment of the district court summarily dismissing Appellant’s application for postconviction relief, holding that the statute of limitations did not bar Appellant’s claims but that Appellant failed to establish a Brady violation or demonstrate a viable newly-discovered-evidence claim.Appellant was found guilty of first-degree murder. This appeal concerned Appellant’s amended second pro se application for postconviction relief, in which he argued, inter alia, that newly discovered evidence required vacation of his original sentence and judgment and that the State committed a Brady violation during trial. The district court granted the State’s motion for summary dismissal, concluding that Appellant’s application was untimely by applying the newly-discovered-evidence test rather than the ground-of-fact test. The Supreme Court affirmed, holding (1) Appellant’s claims were not time barred; but (2) Appellant failed to establish that he was entitled to relief on his claims. View "Moon v. State" on Justia Law

The Supreme Court reversed the decision of the district court denying Appellant’s motion to dismiss the State’s petition for his civil commitment as a sexually violent predator (SVP) under Iowa Code Ch. 229A, holding that Appellant was not “presently confined” under section 229A.4(1) by virtue of being subject to a chapter 903B special sentence.At the time the State initiated the civil commitment proceedings, Appellant had discharged his sentence for his underlying sexual offense but was serving a special sentence under Iowa Code chapter 903B.2. The State later successfully pursued revocation of Appellant’s release under section 903B.2. Before Appellant was discharged from his incarceration under section 903B.2, the State filed a petition seeking his civil commitment as an SVP under chapter 229A. Appellant filed a motion to dismiss, arguing that he was not “presently confined” under section 229A.4 because he was being confined because of a violation of his special sentence under chapter 903B and that there was no recent overt act that might otherwise support a section 229A.4(2) proceeding. The district court overruled the motion and granted the State’s SVP petition. The Supreme Court reversed, holding (1) Appellant was not “presently confined” under section 229A.4(1); and (2) there was insufficient evidence to find an overt act under section 229A.4(2). View "In re Detention of Ronald Tripp" on Justia Law

The Supreme Court reversed the decision of the district court denying Appellant’s motion to dismiss the State’s petition for his civil commitment as a sexually violent predator (SVP) under Iowa Code Ch. 229A, holding that Appellant was not “presently confined” under section 229A.4(1), and therefore, the State could not commence an SVP proceeding in the absence of a recent overt act.At the time the State initiated the civil commitment proceedings, Appellant had discharged his sentence for his underlying offense of assault with intent to commit sexual abuse but was residing at the Curt Forbes Residential Facility while serving a special sentence under Iowa Code chapter 903B. Appellant filed a motion to dismiss because he was no longer “presently confined” under section 229A.4(1) and the State had not alleged a recent overt act that might otherwise support a section 229A.4(2) proceeding. The district court denied the motion. The Supreme Court reversed, holding (1) Defendant was not “presently confined” for the purposes of section 229A.4(1); and (2) therefore, the State could not commence an SVP proceeding in the absence of a recent overt act, as required under section 229A.4(2). View "In re Detention of Nicholas Wygle" on Justia Law

A law enforcement officer in this case had probable cause to stop a motorist’s vehicle when it was on a county access road after hours.The district court denied the motorist’s motion to suppress the evidence and convicted the motorist of possession of a controlled substance. The Supreme Court reversed the judgment of the district court, holding that the officer did not have probable cause or reasonable suspicion to stop the motorist’s vehicle. Thereafter, the Court granted the State’s petition for rehearing and withdrew its original petition. Upon further consideration, the Court held that the officer had probable cause to stop the motorist’s vehicle because, at the time the officer stopped the motorist, the closing time in the area where the officer found the motorist’s vehicle was 10:30 p.m., and the officer stopped the motorist after 10:30 p.m. Therefore, at the time of the stop, the officer had probable cause to stop the motorist’s vehicle under the Iowa Constitution. View "State v. Scheffert" on Justia Law

Under Iowa Code 321.561, the State must prove as the essential elements of the offense of driving while barred as a habitual offender that the defendant operated a motor vehicle during the time period his or her license was revoked as a habitual offender. Proof that the Iowa Department of Transportation (IDOT) mailed a notice of revocation to the defendant may be relevant to whether the defendant’s license was in fact revoked, but it is not an actual element of the offense.The Supreme Court affirmed Defendant’s convictions of both operating while intoxicated third offense as a habitual offender and driving while barred. Contrary to Defendant’s contention on appeal, Defendant’s conviction for driving while barred need not be set aside where the State did not prove it mailed notice of revocation to Defendant because proof of mailing is not an essential element of the State’s proof. View "State v. Williams" on Justia Law

At issue was whether the evidence was sufficient to support Defendant’s conviction on one count of sexual exploitation by a school employee under Iowa Code 709.15(3)(a)(1) and 709.15(5)(a) where Defendant hugged a student several times.The Supreme Court affirmed Defendant’s conviction, holding (1) Iowa Code 709.15(3)(a)(1) does not require the State to show that a school employee engaged in a pattern, practice, or scheme to engage in sexual conduct with multiple students or over a certain period of time; and (2) the State presented substantial evidence - including dozens of hugs, thousands of communications, and photographs - that Defendant engaged in a pattern, practice, and scheme to engage in sexual conduct with the student at issue. View "State v. Wickes" on Justia Law

The Supreme Court overruled its cases holding that defendants may attack the voluntary and intelligent character of their pleas, holding that the Iowa Constitution allows freestanding claims of actual innocence, and therefore, applicants may bring such claims to attack their pleas even though they entered their pleas knowingly and voluntarily.Appellant filed an application for postconviction relief under Iowa Code 822.2(1)(d), claiming that he was innocent and that he pled guilty because he was “scared.” The district court granted summary judgment for the State, concluding that Appellant waived his claim of actual innocence by pleading guilty. The Supreme Court reversed, holding (1) the Court hereby adopts a freestanding claim of actual innocence that applicants may bring under the postconviction relief statute; and (2) thus, Appellant’s pleas did not preclude him from filing a postconviction-relief action. View "Schmidt v. State" on Justia Law

The relief-required rule, which ordinarily requires proof that a criminal client had been exonerated from the underlying conviction, does not apply to a convicted criminal suing one of his defense attorneys for legal malpractice over an alleged missed opportunity to shorten his period of supervised probation.In this case, Plaintiff’s defense attorney successfully vacated two of Plaintiff’s convictions. Meanwhile, Plaintiff was incarcerated for a probation violation. The district court later determined, sua sponte, that Plaintiff’s term of supervised probation should have ended earlier, which would have avoided almost one year in prison. The district court granted summary judgment to the defendant attorney based on the relief-required rule. The court of appeals reversed, ruling that Plaintiff could sue over the sentencing error without proving his exoneration from the conviction as long as he obtained relief from the sentencing error. The Supreme Court affirmed, holding that Plaintiff here must prove relief from the sentencing error allegedly caused by the malpractice, not the underlying conviction. View "Kraklio v. Simmons" on Justia Law

The Supreme Court reversed Defendant’s conviction for robbery in the first degree and remanded for entry of judgment and sentencing for robbery in the second degree, holding that Defendant’s conviction for robbery in the first degree as an aider and abettor was not supported by sufficient evidence.Defendant agreed to be the getaway driver for his two codefendants, who were going to rob a pharmacy. The codefendants robbed the pharmacy, but Defendant did not give them a ride because they were apprehended by the police before the planned rendezvous took place. All three individuals were convicted of first-degree robbery because a gun had been used in the robbery. On appeal, Defendant argued that the evidence was insufficient to support his conviction because he did not know a gun would be used in the robbery. The court of appeals affirmed. The Supreme Court reversed, holding (1) proof that Defendant had knowledge or intent of the use of the gun was required to support his conviction under an aiding and abetting theory; and (2) there was insufficient evidence to convict Defendant of first-degree robbery as an aider and abettor due to a failure of proof on the dangerous weapon element. View "State v. Henderson" on Justia Law