Justia Iowa Supreme Court Opinion Summaries

Deputy Dan Furlong prepared a warrant application to search a residence. The detective brought the application before a judicial officer and, without signing the application, orally swore to the trust of the application in the presence of the judicial officer. The judicial officer approved and signed the warrant. After the warrant was executed Defendants were charged with several drug charges. Defendants moved to suppress the results of the search based on the detective’s failure to sign the warrant application. The district court granted the motions to suppress. The Supreme Court reversed, holding (1) Iowa Code 808.3 permits the warrant applicant to swear to the truth of the warrant application in the presence of the judicial officer even if, inadvertently, the applicant fails to sign it; and (2) in this case, the issuance of the warrant complied with section 808.3. View "State v. Angel" on Justia Law

After a bench trial, Defendant was convicted of making a false statement on an application to acquire a weapon permit, in violation of Iowa Code 724.17. The court of appeals affirmed the conviction, concluding that the district court correctly interpreted the statute and that substantial evidence supported the conviction. The Supreme Court reversed, holding (1) the district court misinterpreted the statute; and (2) under the correct interpretation of the statute, section 724.17 does not criminalize Defendant’s act of falsely answering an unauthorized question on the application to acquire a weapon permit. View "State v. Downey" on Justia Law

Kent Tyler, Yarvon Russell, James Shorter, and Leprese Williams were charged with first-degree murder in connection with the death of Richard Daughenbaugh. Tyler was tried separately from the other three defendants. At the trial of the three codefendants, Russell and Shorter were convicted of second-degree murder. Williams was acquitted. The court of appeals reversed Russell’s conviction, concluding that there was insufficient evidence to support a joint criminal conduct instruction. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding (1) there was sufficient evidence to support the verdict, and any erroneous submission of the joint criminal conduct instruction did not undermine the jury’s verdict; and (2) Russell’s claim of ineffective assistance of counsel should be addressed in an action for postconviction relief. View "State v. Russell" on Justia Law

Four defendants, including Kent Tyler and James Shorter, were charged with murder in connection with the death of Richard Daughenbaugh. Tyler was convicted of second-degree murder. In State v. Tyler, the Supreme Court reversed and remanded, concluding that the evidence in Tyler’s case did not support the trial court’s instruction on joint criminal conduct. In this case, as in Tyler, a jury convicted Shorter of second-degree murder. Relying on Tyler, the court of appeals reversed, concluding that although there was sufficient evidence to support the conviction on the ground that Shorter was a principal in the murder or aided and abetted the murder, there was insufficient evidence to support the joint criminal conduct instruction. The Supreme Court vacated the judgment of the court of appeals and affirmed Shorter’s conviction, holding that even if the joint criminal conduct instruction was erroneously given, reversal was not required under the facts of this case. View "State v. Shorter" on Justia Law

Defendant was charged with robbery in the second degree. After a jury trial, Defendant was found guilty. The State sought a habitual offender sentencing enhancement, but the district court did not inform Defendant of certain constitutional and statutory rights associated with accepting guilty pleas before accepting his admission to the prior convictions to support the habitual offender status. The district court subsequently sentenced Defendant for the crime of robbery in the second degree as a habitual offender. Defendant appealed. The court of appeals affirmed, ruling that Defendant failed to preserve error concerning deficiencies in the habitual offender colloquy by filing a motion in arrest of judgment and that the district court did not abuse its discretion in refusing to permit the admission to be withdrawn. The Supreme Court vacated the decision of the court of appeals, reversed the district court and remanded the case for a trial on Defendant’s habitual offender status, holding that Defendant did not knowingly and voluntarily admit his prior convictions because he was not informed of his constitutional rights and the consequences of his admission. View "State v. Harrington" on Justia Law

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 the instant case, Defendant pled guilty to OWI, first offense. The Sate submitted a request for “emergency response restitution” on behalf of the Davenport Police Department pursuant to Iowa Code 321J.2(13)(b). The district court denied the State’s claim for restitution, concluding that this case only involved “services provided by a police department in investigating and effecting the routine arrest and processing of a person” for OWI. The Supreme Court affirmed for the reasons set forth in today’s State v. District Court decision, holding that section 321J.2(13)(b) does not authorize recovery of the costs of the routine law enforcement activities involved in this case. View "State v. Iowa District Court for Scott County" on Justia Law

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 pled guilty to OWI, first offense. The State requested that Defendant pay “victim restitution” to the City of Davenport and requested “emergency response restitution” on behalf of the Davenport Police Department. The district court denied the State’s claim for restitution, concluding that this case involved only police department services provided to investigate and effect the routine arrest and processing of a person for OWI. The Supreme Court affirmed, holding that, for the reasons set forth in today’s decision in State v. District Court, Iowa Code 321J.2(13)(b) did not authorize recovery of the costs of the routine law enforcement activities involved in this case. View "State v. Iowa District Court for Scott County" on Justia Law

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