Justia Iowa Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of three counts of delivery of a controlled substance. The court of appeals reversed, concluding that defendant’s right to a fair trial by an impartial jury was violated due to certain statements a prospective juror made during voir dire. The Supreme Court vacated the decision of the court of appeals and affirmed in part and reversed in part the judgment of the district court, holding (1) the district court did not deny Defendant a fair trial by an impartial jury because the statements the prospective juror made during voir dire were not so prejudicial as to warrant a presumption they tainted at least one member of the jury panel; (2) the district court did not abuse its discretion by declining to holding a hearing to permit defense counsel to show cause for missing an extended discovery and deposition deadline; (3) the record was inadequate to assess whether prejudice resulted from defense counsel’s breach of an essential duty, and Defendant may bring his ineffective assistance claim in a future postconviction relief action; and (4) the district court applied the incorrect standard in denying Defendant’s motion for new trial on the ground the verdicts were contrary to the weight of the evidence. Remanded. View "State v. Ary" on Justia Law

After a jury trial, Defendant was convicted of three counts of delivery of a controlled substance. The court of appeals reversed, concluding that defendant’s right to a fair trial by an impartial jury was violated due to certain statements a prospective juror made during voir dire. The Supreme Court vacated the decision of the court of appeals and affirmed in part and reversed in part the judgment of the district court, holding (1) the district court did not deny Defendant a fair trial by an impartial jury because the statements the prospective juror made during voir dire were not so prejudicial as to warrant a presumption they tainted at least one member of the jury panel; (2) the district court did not abuse its discretion by declining to holding a hearing to permit defense counsel to show cause for missing an extended discovery and deposition deadline; (3) the record was inadequate to assess whether prejudice resulted from defense counsel’s breach of an essential duty, and Defendant may bring his ineffective assistance claim in a future postconviction relief action; and (4) the district court applied the incorrect standard in denying Defendant’s motion for new trial on the ground the verdicts were contrary to the weight of the evidence. Remanded. View "State v. Ary" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to possession of a controlled substance first offense. The judgment and sentence provided that Defendant’s driver’s license shall be revoked for 180 days and provided for several surcharges on top of the fine. Defendant appealed, arguing that his written plea was defective because it failed to disclose the statutory minimum sentence of two days in jail, the mandatory six months’ revocation of his driver’s license, and the surcharges that were added to his fine. The court of appeals affirmed Defendant’s plea and sentence. The Supreme Court vacated the decision of the court of appeals and vacated the judgment and sentence imposed by the district court, holding (1) Defendant’s plea was involuntary because revocation of the driver’s license of a person convicted of a drug possession offense is mandatory, immediate, and part of the punishment for that offense, and therefore, the court must inform the defendant of this consequence before accepting his guilty plea; and (2) Defendant had a right to be informed of fine surcharges. Remanded. View "State v. Fisher" on Justia Law

The juvenile court adjudicated J.C. a delinquent child after finding beyond a reasonable doubt that J.C. committed assault with intent to commit sexual abuse. The court of appeals affirmed. At issue before the Supreme Court was whether the juvenile court violated J.C.’s constitutional right to confrontation by admitting the out-of-court statements made by a four-year-old victim to a physician during a medical assessment and to a forensic interviewer. The Supreme Court affirmed, holding (1) admission of the physician’s testimony and report did not violate J.C.’s confrontation rights under either the Sixth Amendment or the Iowa Constitution; and (2) any error in admission of the forensic interviewer’s testimony was harmless beyond a reasonable doubt. View "In re J.C." on Justia Law

The juvenile court adjudicated J.C. a delinquent child after finding beyond a reasonable doubt that J.C. committed assault with intent to commit sexual abuse. The court of appeals affirmed. At issue before the Supreme Court was whether the juvenile court violated J.C.’s constitutional right to confrontation by admitting the out-of-court statements made by a four-year-old victim to a physician during a medical assessment and to a forensic interviewer. The Supreme Court affirmed, holding (1) admission of the physician’s testimony and report did not violate J.C.’s confrontation rights under either the Sixth Amendment or the Iowa Constitution; and (2) any error in admission of the forensic interviewer’s testimony was harmless beyond a reasonable doubt. View "In re J.C." 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

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