Justia Iowa Supreme Court Opinion Summaries

Defendant was entitled to withdraw his guilty plea to assault causing bodily injury because the district court did not substantially comply with Iowa R. Crim. P. 2.8(2)(b)(2) during the guilty plea colloquy. Specifically, the district court did not substantially comply with Rule 2.8(2)9b)(2) because the written guilty plea form failed to inform Defendant about the mandatory thirty-five precent criminal penalty surcharge applicable to the offense. The Supreme Court thus affirmed the decision of the court of appeals, which, based the district court’s noncompliance with the rule, applied a bright-line rule of automatic reversal. View "State v. Diallo" on Justia Law

Defendant Jason Weitzel appealed the judgment and sentences entered on his guilty pleas to domestic abuse assault, possession of methamphetamine, carrying weapons, and operating while intoxicated. Defendant challenged the adequacy of his guilty plea colloquy, arguing the district court did not advise him about the statutory thirty-five percent criminal penalty surcharges, and this failure invalidated his guilty pleas. The court of appeals held the district court did not substantially comply with Iowa Rule of Criminal Procedure 2.8(2)(b)(2) during the guilty plea colloquy because it omitted information regarding the surcharges, and reversed. The State sought certiorari review, and the Iowa Supreme Court concurred with the appellate court that the district court did not substantially comply with rule 2.8(2)(b)(2) because it failed to inform the defendant about the mandatory thirty-five percent criminal penalty surcharges. Because of the district court’s noncompliance, defendant was entitled to withdraw his pleas. The case was remanded back to the district court for further proceedings. View "Iowa v. Weitzel" on Justia Law

The Supreme Court reversed the order of the district court finding that it did not have subject matter jurisdiction to hear Appellant’s challenge under Iowa Code 822.2.Appellant, a prisoner, filed a postconviction-relief action asserting that the policy of the Iowa Department of Corrections unlawfully extended his time in prison by delaying the start date of the sex offender treatment program based on a sex offender’s tentative discharge date. The district court granted the State’s motion for summary judgment on the ground that it lacked subject matter jurisdiction and dismissed the case. The Supreme Court reversed and remanded the case for further proceedings, holding (1) this was not a case concerning subject matter jurisdiction but did, rather, involve authority to hear the case; and (2) the district court did have authority to hear this case. View "Franklin v. State" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing Appellant’s amended application for postconviction relief.In his application for postconviction relief, Appellant alleged that, pursuant to Iowa Code 822.2(1)(a), his sentence violated several of his civil rights under the United States and Iowa Constitutions. Specifically, Appellant asserted that the Iowa Department of Corrections (IDOC) violated his liberty interest in obtaining parole by failing to provide the sex offender treatment program (SOTP) in a timely manner. The district court found, as a matter of law, that Appellant had not stated a claim for postconviction relief under section 822.2(1)(a). The Supreme Court remanded the case, holding that Appellant should be given an opportunity to amend his application to seek relief under Iowa Code 822.2(1)(e). View "Belk v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of second-degree murder. On appeal, Defendant claimed, among other things, that he was forced to use a peremptory strike to disqualify a potential juror who should have been disqualified for cause, and therefore, reversal was required even though the potential juror was not seated and there was no specific showing of prejudice. The court of appeals affirmed the conviction. The Supreme Court affirmed, holding (1) the actual prejudice test of State v. Neuendorf, 509 N.W.2d 743 (Iowa 1993), rather than the automatic prejudice test of State v. Mootz, 808 N.W.2 207 (Iowa 2012), controlled in this case; and (2) consequently, Defendant could not succeed in this appeal. View "State v. Jonas" on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant’s motion to suppress evidence obtained after an officer stopped his vehicle for being on a county access road after hours. The district court determined that Defendant violated Iowa Code 350.5 by entering the county access area after hours, regardless of whether there was a sign posted to identify the county access area or the park hours. The Supreme Court disagreed, holding (1) the officer did not have probable cause or reasonable suspicion to stop Defendant’s vehicle when it was on the county access road after hours because, without a proper posting of the closing time, the officer did not have probable cause or reasonable suspicion to stop Defendant; and (2) therefore, the district court should have suppressed any drug evidence found in Defendant’s vehicle. View "State v. Scheffert" on Justia Law

Defendant was not entitled to an automatic new trial after the district court, over Defendant’s objection, required a standby interpreter for his jury trial.Defendant requested, and was provided, an interpreter for all of his pretrial hearings. Defendant sought to waive the interpreter for his jury trial, however. The district court nevertheless ordered a standby interpreter to sit in the gallery translating through a wireless earpiece Defendant could remove at his option. Defendant waived the jury and, after a bench trial, was convicted of selling cocaine. The Supreme Court affirmed, holding (1) Defendant had a right to waive the interpreter, but the district court did not abuse its discretion by ordering a standby interpreter over Defendant’s objection; and (2) the record was inadequate to review Defendant’s claim that his counsel was ineffective in waiving the jury. View "State v. Garcia" on Justia Law

A “criminal case” as used in Iowa’s recently enacted expungement law, Iowa Code 901C.2, refers to a single numbered legal proceeding.In 2011, Defendant was charged with several aggravated misdemeanors in a single trial information. At the same time, he was separately charged by criminal complaint with a single misdemeanor. Defendant pleaded guilty to a lesser included offense of one count of the trial information, and all other charges, including the simple misdemeanor criminal complaint, were dismissed. In 2016, Defendant sought expungement of the record of the dismissed simple misdemeanor complaint. The magistrate and district court denied relief, concluding that the misdemeanor and the offense to which Defendant had pled guilty in the trial information comprised a single criminal case within the meaning of section 901C.2(1)(a)(1) because they were factually related. The Supreme Court reversed the district court’s judgment denying expungement, holding that Defendant was entitled to expungement of the record of the dismissed simple misdemeanor complaint. View "State v. Clemens" on Justia Law

Defendant was required to register as a sex offender under Iowa Code 692A.103(1) upon his conviction of lascivious conduct with a minor and release on bond, notwithstanding this appeal.Defendant argued that he had no obligation to register after posting an appeal bond to stay execution of the underlying criminal judgment and before he began serving any prison sentence or was placed on probation. The district court concluded that Defendant was required to register as of the date he was sentenced to prison for the sex offense and was released on the appeal bond. Defendant’s conviction was later affirmed on appeal. Now Defendant faced new criminal charges for violating chapter 692A’s sex offender residency restrictions before his conviction was affirmed. The Supreme Court affirmed the judgment of the district court, holding (1) the stay of execution on Defendant’s criminal judgment did not delay the automatic administrative registration requirement for convicted sex offenders; and (2) Defendant’s release on the appeal bond constituted a “release from incarceration” within the meaning of section 692A.103(1). View "Maxwell v. Iowa Department of Public Safety" on Justia Law

Under the circumstances of this case, Defendant was denied procedural protections for determining his status as an habitual offender at trial, and Defendant did not need to preserve error by filing a motion in arrest of judgment.After a bench trial, Defendant was convicted of indecent exposure and sentenced as a habitual offender. Defendant also pled guilty to indecent exposure. On appeal, the State conceded that the plea colloquy was insufficient. However, contrary to Defendant’s arguments, the State argued that the stipulation relating to Defendant’s prior convictions was sufficient. The court of appeals concluded that Defendant failed to preserve error on his claim that the stipulation concerning his prior convictions was deficient and that Defendant was required to challenge the sufficiency of the proceedings either by filing a motion in arrest of judgment or by another means. The Supreme Court vacated the decision of the court of appeals and reversed the judgment and sentences of the district court, holding (1) requirements of the enhanced-penalty hearing were not followed by the district court; and (2) the error preservation rule established in State v. Harrington, 893 N.W.2d 36 (Iowa 2017) was not in existence at the time. View "State v. Steiger" on Justia Law