Justia Iowa Supreme Court Opinion Summaries

A special restitution law provides that the court may order restitution paid to any public agency for the costs of the “emergency response” resulting from the actions constituting a violation of the operating while intoxicated (OWI) statute. In this case, Defendant was arrested for and convicted of OWI, second offense. The State sought restitution for the costs of the traffic stop, which was conducted by an officer while on regular nighttime parole. The district court denied the request on the grounds that there was no emergency in this case. Thereafter, the State filed a petition for writ of certiorari with the Supreme Court. The Supreme Court affirmed, holding (1) routine law enforcement activities do not qualify as an “emergency response”; and (2) there was no emergency response by law enforcement in this case. View "State v. Iowa District Court for Scott County" on Justia Law

Defendant appealed his convictions and sentences following two bench trials, challenging the underlying searches in each of the two cases. Specifically, Defendant argued that the district court erred in denying his motions to suppress firearms and drugs seized by his stepfather, a police officer with the Davenport Police Department, while his stepfather was off duty. Defendant argued that the searches were unconstitutional because his stepfather conducted the searches while exercising state action as a law enforcement official. The district court denied each motion to suppress. After bench trials, Defendant was found guilty of the charges. The Supreme Court affirmed the denial of the motions to suppress, holding that Defendant’s off-duty police officer stepfather was acting in his private capacity, and not in his governmental capacity as a law enforcement officer, when he conducted the searches of Defendant’s person and vehicle. View "State v. Brown" on Justia Law

Defendant pleaded guilty to attempted murder. Defendant was sixteen years old at the time of the offense. Defendant was sentenced to twenty-five years in prison, including a mandatory minimum term of incarceration. Defendant was also ordered to pay $150,000 in mandatory restitution to the victim’s estate. Defendant was later resentenced and received immediate parole eligibility because the mandatory minimum period of incarceration had been deemed unconstitutional. The restitution was left in place. Defendant appealed, challenging the $150,000 in restitution to the victim’s estate. The Supreme Court affirmed, holding (1) the $150,000 mandatory restitution for juvenile homicide offenders is not facially unconstitutional; and (2) the $150,000 mandatory restitution was not unconstitutional as applied to Defendant. View "State v. Breeden" on Justia Law

Defendant pleaded guilty to second-degree murder. Defendant was fifteen years old at the time of the offense. The district court sentenced Defendant to an indeterminate term of incarceration and ordered Defendant to pay $150,000 in mandatory restitution to the victim’s estate. Defendant appealed, challenging the $150,000 restitution award. The Supreme Court affirmed, holding (1) Iowa Code 901.5(14) does not authorize the district court to modify a restitution award otherwise required by Iowa Code 910.3B(1), and restitution under chapter 910 is mandatory; and (2) section 910.3B is not unconstitutional either as applied to all juvenile homicide offenders or as applied to Defendant. View "State v. Richardson" on Justia Law

After a jury trial, Defendant was convicted of going armed with intent and willful injury causing bodily injury. Defendant appealed, arguing that defense counsel provided ineffective assistance by failing to challenge the sufficiency of the evidence supporting submission of the going-armed-with-intent charge to the jury and failing to object to the jury instruction on going armed with intent on the ground that it omitted an element of the charged offense. The Supreme Court reversed, holding (1) defense counsel was not ineffective in failing to challenge the sufficiency of the evidence; but (2) defense counsel breached a duty in failing to object to the marshaling instruction for the going-armed-with-intent offense, and Defendant suffered prejudice as a result. Remanded. View "State v. Harris" on Justia Law

In 2004, Gary Pettit pled guilty to third-degree sexual abuse and third-degree kidnapping, Pettit was incarcerated at the Anamosa State Penitentiary. In 2015, the Iowa Department of Corrections (IDOC) informed Pettit that he would be required to complete sex offender treatment. After a sex offender treatment program (SOTP) classification hearing, an administrative law judge (ALJ) affirmed the classification decision, concluding that Pettit was required to complete the SOTP. Pettit filed a petition for judicial review, claiming that the IDOC violated his due process rights by refusing to allow him access to counsel during the classification hearing. The district court determined that Pettit was entitled to counsel at the hearing. The Supreme Court vacated the judgment of the district court and remanded, holding that the district court did not have authority to review the classification hearing under Iowa Code chapter 17A. Remanded for dismissal of Pettit’s petition for judicial review. View "Pettit v. Iowa Department of Corrections" on Justia Law

Defendant was charged with driving while barred. Defendant filed a motion to suppress, which the district court denied. Defendant was subsequently convicted. Defendant appealed the denial of his motion to suppress, arguing that a law enforcement officer, after making a valid traffic stop supported by reasonable suspicion that an offense may being committed, must terminate the stop when the underlying reason for the stop is no longer present. The Supreme Court agreed with Defendant and reversed, holding (1) when the reason for a traffic stop is resolved and there is no other basis for reasonable suspicion, Iowa Const. art. I, 8 requires that the stop must end; and (2) consequently, the law enforcement officer that stopped Defendant in this case violated Defendant’s rights under the Iowa Constitution. View "State v. Coleman" on Justia Law

Appellant pleaded guilty to failure to appear for sentencing. Appellant filed a postconviction relief action asserting that his counsel provided ineffective assistance for several reasons. The district court denied relief. Appellant appealed, arguing that counsel was ineffective by allowing Appellant to plead guilty when a factual basis did not exist for the plea. The court of appeals concluded that it could not reach this issue on appeal because the record was insufficient to determine whether a factual basis existed at the time Appellant pleaded guilty. The Supreme Court vacated the decision of the court of appeals and affirmed the district court judgment, holding (1) a factual basis existed in the record for the court to accept Appellant’s plea; and (2) Appellant’s remaining claims were without merit. View "Yocum v. State" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to theft in the first degree. The district court sentenced Defendant to a term of imprisonment and imposed fines and restitution. The sentencing order also included a provision for the forfeiture of Defendant’s pretrial bond in payment of the various financial obligations imposed as part of his sentence. Defendant moved for reconsideration and requested that he be sentenced to probation. The district court denied the motion. Defendant appealed, arguing, inter alia, that the district court lacked authority to order forfeiture of the bail. The court of appeals affirmed. The Supreme Court vacated the decision of the court of appeals with regard to the issue pertaining to the appearance bond, holding that the district court lacked the authority to forfeit bail as a term of sentencing. View "State v. Letscher" on Justia Law

An inmate pled guilty to domestic abuse assault in a plea bargain that dismissed a related sex abuse charge. After the inmate arrived at a facility of the Iowa Department of Corrections (IDOC), the IDOC required the inmate to participate in a Sex Offender Treatment Program (SOTP). For the initial classification mandating SOTP, the IDOC relied on the dismissed sex abuse charge and the victim’s detailed written statement included in a police report. An administrative law judge (ALJ) upheld the determination following an evidentiary hearing based on the inmate’s admission that he assaulted his girlfriend and the victim’s statement. The district court reversed, concluding that the IDOC cannot use unproven charges to require SOTP. The Supreme Court reversed and reinstated the IDOC’s decision, holding (1) the IDOC may rely on the victim’s written statement in a police report for the initial classification requiring SOTP provided that the inmate is afforded due process; (2) the ALJ may uphold the classification based on the inmate’s testimony admitting to a sexual component to the assault along with other evidence; and (3) the inmate in this case was provided with appropriate procedural protections, and there was no other error in these proceedings. View "State v. Iowa District Court for Jones County" on Justia Law