Justia Iowa Supreme Court Opinion Summaries

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

Appellant, a high school football player, was charged with possession of a firearm as a felon, carrying a weapon on school grounds, carrying a weapon, and possession of a controlled substance after the school superintendent searched Appellant’s school-issued equipment bag. The superintendent was moving the bag to the floor when he heard a “metallic sound.” Appellant filed a motion to suppress the evidence found in the bag. The district court denied the motion to suppress, concluding that, under New Jersey v. T.L.O., the search was justified at its inception and the scope of the search was reasonable. The Supreme Court affirmed, holding that the search fell within the general parameters of reasonableness as outlined in T.L.O. View "State v. Lindsey" on Justia Law

Defendant was charged with one count of driving while barred and one count of prostitution. Defendant filed a motion to dismiss, asserting that the state failed to try her case within ninety days of filing the trial information. After a hearing, the district court ruled that Defendant waived speedy trial. The trial court subsequently found Defendant guilty. Defendant appealed, arguing that the State failed to bring her to trial within the speedy trial deadline, that she did not waive her speedy trial rights, that there was not good cause for the delay, and that she timely asserted her speedy trial rights. The Supreme Court reversed, holding (1) the State did not meet its burden of showing good cause for the delay; and (2) the State did not meet its burden in showing that Defendant waived her right to a speedy trial. Remanded for dismissal of all charges. View "State v. Taylor" on Justia Law

After a jury trial, Defendant was found guilty of involuntary manslaughter by commission of public offense and child endangerment resulting in death. The trial court merged the sentences for the charges under the one-homicide rule and imposed a mandatory indeterminate fifty-year sentence. The court of appeals affirmed. The Supreme Court affirmed in part and vacated in part the decision of the court of appeals, holding (1) the district court did not err in denying Defendant’s motion to suppress; but (2) trial counsel was ineffective for failing to move for a judgment of acquittal on the child endangerment conviction under the theory that Defendant used unreasonable force that resulted in bodily injuries to the victim. Remanded for a new trial. View "State v. Schlitter" on Justia Law

David Taft, Jr. was convicted in 1987 for lascivious acts with a minor. He received one two-year and two five-year sentences. The sentences were ordered to be served concurrently. Taft was discharged in 1991. He was arrested for reoffending one week later with two more children. He was convicted and served a sentence of incarceration until discharged on January 10, 2005. On March 30, 2005, district court proceedings were initiated to commit Taft as a sexually violent predator under the Commitment of Sexually Violent Predators Act, Iowa Code chapter 229A (2005). The jury found Taft suffered from a mental abnormality that made it more likely than not that he would reoffend. Taft was committed to the Civil Commitment Unit for Sexual Offenders (CCUSO). In this case, the issue presented for the Iowa Supreme Court's review was the constitutionality of statutory conditions on the suitability of a civilly committed sexually violent predator for the transitional release program. As part of an annual review, the district court denied a final hearing for discharge or suitability for placement in a transitional release program to Taft based in part on his failure to fulfill statutory criteria for a finding of suitability for a transitional release program. Taft challenged two of the criteria as violating his due process rights and denying him equal protection under the Iowa and United States Constitutions. The Supreme Court concluded the issues were not ripe for consideration under the posture of this case. Therefore the Court affirmed the district court's order. View "Taft v. District Court" on Justia Law

In 2012, seventeen-year-old appellant Isaiah Sweet shot and killed Richard and Janet Sweet. Richard and Janet had cared for Sweet since he was four years old, as his biological mother was unable to do. Richard was Sweet’s biological grandfather. Richard and Janet had been married for thirty years. Sweet was arrested three days after the murder. After being given Miranda warnings, Sweet described events leading to the murders, the details of the murders themselves, and his activities in the days after the murders. Sweet was charged and convicted on first-degree murder charges. While his maturity was debatable, the district court stressed that the crimes were premeditated. The district court felt that Sweet's proffered expert's characterization of Sweet’s possibility of rehabilitation as "mixed" was overly optimistic. Further, the district court found Sweet’s case was the rare case in which a sentence of life without the possibility of parole was warranted, as the murders were horrific and showed utter lack of humanity. The district court concluded that Sweet was currently, and will continue to be, a threat to society and that the interests of justice and community safety outweighed mitigating factors. Sweet was sentenced to life without the possibility of parole. The Supreme Court reversed and remanded for resentencing, finding that a sentence of life without the possibility of parole for a juvenile offender violated article I, section 17 of the Iowa Constitution. View "Iowa v. Sweet" on Justia Law

A jury convicted Glendale More Jr. of first-degree murder in connection with the death of his girlfriend, Wauneita Townsend. He applied for postconviction relief, arguing that he was entitled to a new trial because at his trial the State introduced expert witness testimony on Compositional Bullet Lead Analysis (CBLA). According to More, recent scientific developments have discredited CBLA and that as a result of these new developments, he was entitled to a new trial. He also alleged that the use of CBLA testimony violated due process under both the State and Federal Constitutions by depriving him of a fair trial. The district court denied relief. The court of appeals affirmed. The Iowa Supreme Court granted further review and affirmed: "We certainly recognize that one of the roles of this court is to protect defendants from wrongful convictions when subsequently discovered evidence shows that an error has probably occurred. Yet after examination of the record in this case, we cannot conclude that More’s trial, though flawed, was fundamentally unfair in light of the entire record, which points in the direction of More’s guilt." View "More v. Iowa" on Justia Law

Defendant was charged with domestic abuse assault. During trial, the court admitted evidence about previous incidents during which Defendant allegedly slapped the victim, struck her, and threw her against a refrigerator, concluding that these other acts were admissible because they were probative of Defendant’s intent in committing the charged assault. The jury ultimately convicted Defendant of domestic abuse assault. The court of appeals affirmed, concluding that the district court did not err in admitting the other acts evidence. The Supreme Court affirmed, holding that the district court did not abuse its discretion in admitting the other-acts testimony under the circumstances of this case. View "State v. Richards" on Justia Law

Defendant was charged with two counts of robbery in the second degree. Defendant filed a motion to suppress, arguing that the warrantless search of his closed backpack by an officer who relied on a third party’s consent in conducting the search was unreasonable. Specifically, Defendant asserted that the third party had neither actual authority nor apparent authority to consent to the search of his backpack. The district court denied the motion to suppress and found Defendant guilty of the charged crimes. The Court of Appeals affirmed, concluding that Defendant had apparent authority, but not actual authority, to consent to the search of the backpack. The Supreme Court vacated the decision of the court of appeals, reversed the judgment of the district court, and remanded for a new trial, holding that the warrantless search of Defendant’s backpack violated his Fourth Amendment rights because the third party lacked apparent authority to consent to the search. View "State v. Jackson" on Justia Law