Justia Iowa Supreme Court Opinion Summaries

Defendant was charged with attempted murder, robbery, and willful injury. During jury deliberations, Defendant moved for a mistrial or, alternatively, a poll of the jurors about their possible exposure to a factually inaccurate media account of the case. The district court denied the motions, concluding that a factually inaccurate media article that appeared online during Defendant’s trial had not prejudiced Defendant. The Supreme Court affirmed, holding that the factually inaccurate article did not raise serious questions of possible prejudice, and therefore, the district court did not abuse its discretion in denying Defendant’s motion for a mistrial and alternative motion to poll the jury. View "State v. Gathercole" on Justia Law

Defendant was charged with attempted murder, robbery, and willful injury. During jury deliberations, Defendant moved for a mistrial or, alternatively, a poll of the jurors about their possible exposure to a factually inaccurate media account of the case. The district court denied the motions, concluding that a factually inaccurate media article that appeared online during Defendant’s trial had not prejudiced Defendant. The Supreme Court affirmed, holding that the factually inaccurate article did not raise serious questions of possible prejudice, and therefore, the district court did not abuse its discretion in denying Defendant’s motion for a mistrial and alternative motion to poll the jury. View "State v. Gathercole" on Justia Law

Defendants participated in an insurance fraud ring that staged car accidents in Illinois. Defendants lived in Wisconsin and Illinois and had never been to Iowa before their extradition. A Wisconsin insurance company paid Defendants’ claims through its Wisconsin bank account. Two of the insurer’s employees interviewed Defendants by phone from the insurer’s Davenport, Iowa branch office. The insurance fraud was reported to detectives at the Davenport Police Department, and all three defendants were arrested in their home states and extradited to Iowa. Defendants were charged with five criminal offenses. Defendants moved to dismiss for lack of jurisdiction. The district court granted the motions to dismiss. The Supreme Court (1) affirmed the district court’s dismissal of one charge, as the State failed to show that any defendant submitted a false written statement or certificate in Iowa; and (2) reversed the district court’s dismissal of the other criminal charges, holding that the phone calls between Defendants and the insurer’s investigators in Davenport induced payments on false insurance claims, a detrimental effect in Iowa, which constituted an element of four of the five crimes charged. View "State v. Rimmer" on Justia Law

Defendants participated in an insurance fraud ring that staged car accidents in Illinois. Defendants lived in Wisconsin and Illinois and had never been to Iowa before their extradition. A Wisconsin insurance company paid Defendants’ claims through its Wisconsin bank account. Two of the insurer’s employees interviewed Defendants by phone from the insurer’s Davenport, Iowa branch office. The insurance fraud was reported to detectives at the Davenport Police Department, and all three defendants were arrested in their home states and extradited to Iowa. Defendants were charged with five criminal offenses. Defendants moved to dismiss for lack of jurisdiction. The district court granted the motions to dismiss. The Supreme Court (1) affirmed the district court’s dismissal of one charge, as the State failed to show that any defendant submitted a false written statement or certificate in Iowa; and (2) reversed the district court’s dismissal of the other criminal charges, holding that the phone calls between Defendants and the insurer’s investigators in Davenport induced payments on false insurance claims, a detrimental effect in Iowa, which constituted an element of four of the five crimes charged. View "State v. Rimmer" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The trial court instructed the jury on both the premeditation and felony-murder alternatives of first-degree murder, with the underlying predicate felony being terrorism. In 2006, the Supreme Court decided State v. Heemstra, which was not given retroactive effect. If Heemstra had been controlling at the time of Defendant’s conviction, terrorism could not have been used as the predicate felony and the felony-murder instruction could not have been given as a theory to convict Defendant. Defendant later filed this second application for postconviction relief, arguing that his conviction should be vacated and a new trial ordered because the nonretroactive application of Heemstra violates constitutional due process, separation of powers, and equal protection guarantees. Defendant also argued for the first time on appeal that his postconviction counsel were ineffective. The Supreme Court affirmed, holding (1) the nonretroactivity of the rule set forth in Heemstra does not violate the due process, separation of powers, or equal protection clauses of the Iowa Constitution or the equal protection clause of the United States Constitution; and (2) Defendant’s postconviction counsel provided effective assistance. View "Nguyen v. State" on Justia Law

Defendant pled guilty to two counts of sexual abuse in the third degree. The district sentenced Defendant to two concurrent, indeterminate ten-year sentences. Defendant appealed, arguing that the district court applied the wrong Code section at his sentencing and that the error could not be corrected by the use of a nunc pro tunc order. The court of appeals agreed with Defendant and vacated the judgment and sentence to allow the district court to amend the judgment and sentence to reflect Defendant’s intent in entering the plea. On remand, the district court resentenced Defendant to two indeterminate ten-year sentences to be served consecutively instead of merely correcting the error in the sentencing order. The Supreme Court vacated the judgment and sentence of the district court, holding that the district court exceeded its mandate when it resentenced Defendant upon remand. Remanded. View "State v. Pearson" on Justia Law

After a jury trial, Defendant was found guilty of domestic abuse assault and domestic abuse assault causing bodily injury. Defendant appealed, arguing that the district court erred in (1) admitting hearsay statements made to police and medical personnel, and (2) failing to merge the two convictions for purposes of sentencing. The court of appeals (1) concluded that the district court erred by admitting the alleged victim’s statements to police but did not err in admitting the alleged victim’s statements made to the nurse or doctor and that Defendant was not prejudiced by the admission of the hearsay statements to police; and (2) merged the convictions and affirmed the judgment and sentence for domestic abuse assault causing bodily injury. The Supreme Court affirmed in part and vacated in part the decision of the court of appeals, holding that the trial court erred by admitting the alleged victim’s hearsay statements through the testimony of the emergency room nurse and doctor without sufficient foundation, and the error was prejudicial. View "State v. Smith" on Justia Law

After a jury trial, Defendant was convicted of two counts of lascivious acts with a child for inappropriately touching his granddaughter’s genitals over her clothing on more than one occasion. Defendant appealed, arguing that the evidence was insufficient to support his convictions under Iowa Code 709.8 because he did not make skin-to-skin contact with his granddaughter’s genitals. The court of appeals affirmed. The Supreme Court affirmed, holding that a person can “touch the pubes or genitals of a child” within the meaning of section 709.8(1) without making skin-to-skin contact, and therefore, the evidence was sufficient to support Defendant’s convictions. View "State v. Alvarado" on Justia Law

After a jury trial, Defendant was found guilty of drug dealing, child endangerment, and possession of firearms. The trial court sentenced Defendant to 100 years in prison with a mandatory one-third minimum term. The court of appeals affirmed Defendant’s convictions and sentence. The Supreme Court affirmed in part and vacated in part the decision of the court of appeals, holding (1) the evidence was insufficient to prove Defendant’s constructive possession of firearms; (2) Defendant’s remaining convictions were supported by sufficient evidence; and (3) the court of appeals’ rejection of Defendant’s ineffective assistance of counsel claims remains intact. Remanded for resentencing without the firearm conviction and enhancement. View "State v. Reed" on Justia Law

Defendant was arrested for driving while intoxicated. Defendant was transported to a law enforcement center and placed in the booking room. Defendant telephoned an attorney, who went into the booking room to meet with Defendant. The attorney was aware that the room had audio and video monitoring but took no steps to disable them or to request another room. Defendant was subsequently charged with operating while intoxicated. Defendant filed a motion to suppress evidence obtained following the attorney-client meeting, alleging, inter alia, a failure to honor his rights under Iowa Code 804.20. The district court denied the motion to suppress. Thereafter, the jury returned a guilty verdict. The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress, holding that, under the circumstances of this case, no violation of section 804.20 occurred. View "State v. Lamoreux" on Justia Law