Justia Iowa Supreme Court Opinion Summaries

Defendant was on probation after having been convicted of drug offenses related to methamphetamine when his sister and father, concerned that he had relapsed, contacted his probation officer. Probation officers were dispatched to Defendant's residence and, with the father’s consent and without objection from Defendant, entered Defendant’s bedroom. Defendant admitted he had relapsed and used methamphetamine. The State commenced a probation revocation proceeding. Defendant filed a motion to suppress, claiming that the probation officers’ warrantless entry into his bedroom violated article I, section 8 of the Iowa Constitution. The district court denied the motion. The Supreme Court affirmed, holding that assuming, without deciding, that Defendant had a legitimate expectation of privacy in his bedroom, the probation officers’ entry was justified by the special-needs doctrine, and therefore, the entry into Defendant’s room did not violate his rights under article I, section 8 of the Iowa Constitution. View "State v. Brooks" on Justia Law

Defendant pleaded guilty to theft in the third degree. The district court sentenced Defendant to a suspended term of imprisonment and ordered that he pay $2950 in restitution to the victim. At a hearing, the victim stated that she had an insurance policy that had a deductible in the amount of $1000 but that she had not filed a claim with her insurance company for the stolen items. Following the hearing, the district court ordered Defendant to pay $2001 in restitution. Defendant appealed, arguing that the restitution award should be limited to reflect only losses not covered by insurance. The Supreme Court affirmed, holding that the victim was entitled to seek full restitution from Defendant for damages not paid by her insurer and that the victim was under no obligation to act for Defendant’s benefit by seeking coverage for her losses. View "State v. Dubois" on Justia Law

Appellee pled guilty to a crime listed in Iowa Code 902.12, which requires offenders to serve a mandatory minimum term of their sentence before being eligible for parole or work release. Appellee, who was a juvenile when he committed the offense, was sentenced to an indeterminate term of incarceration. The Iowa Department of Corrections (IDOC) classified Appellee’s sentence as category “B” and calculated his earned time accordingly. Appellee later filed a motion for correction of an illegal sentence based on State v. Lyle. The district court resentenced Appellee to an indeterminate term not to exceed ten years, without the mandatory minimum. The IDOC continued to calculate Appellee’s earned time at the rate provided for in category “B” rather than the faster rate provided for in category “A.” Appellee filed a motion to enlarge the sentencing order, arguing that the IDOC was not giving him full credit for his time served. The district court ruled that Appellee’s entire sentence was subject to the accelerated category “A” accumulation rate. The Supreme Court affirmed, holding that Breeden v. Iowa Department of Corrections, decided today, was dispositive and required that Appellant’s earned-time credit be recalculated at the category “A” rate for all his time served. View "State v. Coleman" on Justia Law

Appellant was convicted of attempted murder and terrorism with intent. Appellant was a juvenile when he committed the offenses. Appellant was sentenced to an indeterminate term of incarceration. A mandatory minimum sentence of five years for each offense was also imposed. Appellant received a sentence with a mandatory minimum, and the IDOC calculated Appellant’s earned-time accumulation according to Iowa Code section 903A.2(1). The IDOC classified Appellant’s sentence as category “B” and computed his earned time accordingly. After State v. Lyle was decided the district court resentenced Appellant to an indeterminate term without the mandatory minimum. The IDCO continued to calculate Appellant’s earned-time accumulation at the rate provided for under category “B” rather than the faster rate provided for under category “A.” The district court upheld the sentence. The Supreme Court reversed, holding that Breeden v. Iowa Department of Corrections, decided today, was dispositive and required that Appellant’s earned-time credit be recalculated at the category “A” rate for all his time served. View "James v. State" on Justia Law

Shannon Breeden and Laura Hochmuth, both juveniles when their crimes were committed, were convicted of forcible felonies listed in Iowa Code 902.12. Both offenders were subject to the mandatory minimum requirement to serve at least seven-tenths of their sentences before becoming eligible for parole or work release. Each offender received a sentence with a mandatory minimum, and the Iowa Department of Corrections (IDOC) classified their sentences as category “B” for purposes of calculating earned-time credit. The Supreme Court subsequently decided State v. Lyle, which required resentencing of all offenders serving prison sentences with automatically imposed mandatory minimum terms for crimes committed as juveniles. The district court then resentenced Breeden and Hochmuth to an indeterminate term of years but without a mandatory minimum. The IDOC continued to classify the offenders’ sentences as category “B” such that their earned-time continued to accrue at a slower rate than the rate provided for under category “A.” The court of appeals reversed based on the plain language of section 903A.2(1), which provides that earned-time credit accrues at the faster rate for sentences lacking a mandatory minimum term. The Supreme Court affirmed, holding that removal of the mandatory minimum triggers the faster accrual for earned-time credit. Remanded. View "Breeden v. Iowa Department of Corrections" on Justia Law

Defendant was charged with operating while intoxicated, third offense. Defendant filed a motion to suppress evidence obtained after a police officer pulled his patrol car into Defendant’s driveway with its emergency lights flashing, approached Defendant on foot, and directed him to step down from his front porch onto the driveway. Defendant argued that the officer’s conduct amounted to an unlawful seizure. The district court denied the motion to suppress, concluding that no seizure occurred. The court of appeals affirmed. The Supreme Court reversed, holding that Defendant was seized within the meaning of the Fourth Amendment when the officer directed Defendant to step off the front porch and onto the driveway. Remanded. View "State v. White" on Justia Law

Defendant pled guilty to carrying weapons, an aggravated misdemeanor. Defendant appealed, arguing that the sentencing judge should have sua sponte recused himself from the case based on his prior familiarity with Defendant. In the alternative, Defendant asserted that his counsel provided ineffective assistance for not requesting that the judge recuse himself. The court of appeals affirmed the judgment and sentence. The Supreme Court affirmed in part and vacated in part, holding (1) the court of appeals correctly found that the judge was not required to recuse himself; and (2) the record on appeal was inadequate to determine whether counsel was ineffective for failing to file a motion for recusal at the sentencing hearing. View "State v. Toles" on Justia Law

Kelli Jo Griffin was convicted for the crime of delivery of a controlled substance. Griffin later registered to vote and cast a provision ballot in a municipal election. The county auditor concluded that Griffin was not eligible to vote due to her felony conviction and rejected her ballot. Griffin filed a petition asking the district court to declare that her felony conviction did not disqualify her from voting under the Iowa Constitution. The district court denied relief. At issue on appeal was whether the felony crime of delivery of a controlled substance is an “infamous crime” under the voter disqualification provision of the Iowa Constitution. The Supreme Court affirmed, holding that the Constitution permits persons convicted of a felony to be disqualified from voting in Iowa until pardoned or otherwise restored to the rights of citizenship. View "Griffin v. Pate" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The court of appeals reversed, concluding (1) the State violated Appellant’s Sixth Amendment right to counsel by acquiring incriminating evidence through a jailhouse informant when Defendant was represented by counsel, and the error was not harmless; and (2) the trial court’s instructions on aiding and abetting and joint criminal conduct were not supported by substantial evidence. The Supreme Court affirmed in part and vacated in part the court of appeals’ decision and reversed in part the trial court’s judgment, holding that the trial court erred in overruling Defendant’s motion to suppress as to one of the jailhouse informants. View "State v. Marshall" on Justia Law

Defendant was detained at the police station for suspicion of drunk driving but was not yet formally charged when he made a phone call with a lawyer to get advice regarding the implied-consent procedure and his decision whether to refuse a breathalyzer test. The arresting officer was present during Defendant’s phone call, which was allowed under Iowa Code 804.20. Defendant’s lawyer did not arrive in time, and Defendant submitted to the test. Defendant was subsequently charged with operating a motor vehicle while intoxicated. Defendant filed a motion to suppress the test result, arguing that he was entitled to a private phone consultation with counsel before chemical testing was conducted. The district court denied the motion, and Defendant was convicted as charged. The Supreme Court affirmed, holding (1) the right to counsel under the Iowa and United States Constitutions does not attach until formal criminal charges are filed; and (2) Defendant’s right to counsel had not attached at the time Defendant was asked to submit to the chemical breath test, and therefore, Defendant’s constitutional right to counsel was not violated. View "State v. Senn" on Justia Law