Justia Iowa Supreme Court Opinion Summaries

Appellant pleaded guilty to fraudulent practice in the fourth degree. The district court granted Appellant a deferred judgment and placed him on probation. After Appellant was discharged from probation he filed a petition for writ of habeas corpus alleging that he received ineffective assistance of counsel due to counsel’s failure to adequately inform him of adverse immigration consequences resulting from his guilty plea. The district court summarily denied habeas corpus relief. The court of appeals affirmed. The Supreme Court affirmed, holding that Appellant was not entitled to relief because he failed to comply with the pleading requirements of Iowa Code 663.1(1) and because there were insufficient facts to sustain a writ of habeas corpus. View "State v. Hernandez-Galarza" on Justia Law

On July 22, 2014, the Muscatine County District Court issued an administrative order prescribing a formal procedure through which persons protected by orders of protection entered in criminal proceedings may seek to have them modified or terminated. The Muscatine County Attorney subsequently initiated an original proceeding in the Supreme Court seeking a writ of certiorari, contending that the administrative order exceeded the district court’s authority because it allowed victims in criminal cases to circumvent the County Attorney’s office and directly seek a modification or termination of no-contact orders in criminal cases. The Supreme Court issued a writ of certiorari. The Court then annulled the writ, holding that the administrative order was well within the district court’s authority, as the challenged order did not establish a right to modification or termination of no-contact orders in criminal cases but, rather, simply created a procedure for seeking such relief. View "Ostergren v. Iowa Dist. Court for Muscatine County" on Justia Law

After a jury trial, Defendant was found guilty of first-degree fraudulent practice and sentenced to an indeterminate term of ten years in prison. Defendant appealed, arguing that the trial court erred in its instructions concerning the elements of fraudulent practice and the degrees of fraudulent practice. The Supreme Court reversed, holding (1) in a fraudulent practice case arising under Iowa Code 714.8(4), the jury should be instructed that “false” means the defendant made the entry or alteration with intent to deceive, and the jury was not so instructed in this case, and the error was not harmless; and (2) the jury instructions addressing the degree of fraudulent practice were potentially confusing and contradictory. View "State v. Hoyman" on Justia Law

Appellee, a former high school basketball coach, was convicted of sexual exploitation of a student. Within hours of his sentencing, Appellee filed a notice of appeal, posted the appeal bond, and was released from custody, never having spent a night incarcerated. The Supreme Court reversed Appellee’s conviction on appeal. Thereafter, Appellee filed an application seeking the district court’s determination that he was a “wrongfully imprisoned person” who was entitled to compensation from the State under Iowa Code 663A.1. The district court found that Appellee was a wrongfully imprisoned person under section 663A.1. The Supreme Court reversed, holding that the temporary restraint of Appellee’s liberty on the afternoon of his sentencing while waiting for the delivery of his appeal bond did not constitute imprisonment for which a remedy was available under chapter 663A. View "State v. Nicoletto" on Justia Law

Pursuant to a plea bargain, Defendant pled guilty to harassment in the first degree, an aggravated misdemeanor. The district court imposed a sentence, but the sentencing order did not contain the provisions of the plea bargain. Defendant appealed, claiming (1) the district court erred by not stating adequate reasons on the record for the exercise of its sentencing discretion as required by Iowa R. Crim. P. 2.23(3)(d), and (2) she received ineffective assistance of counsel because she did not knowingly and voluntarily enter into her plea agreement. The Supreme Court vacated the sentence and remanded for resentencing, holding (1) the district court’s sentencing order did not comply with Iowa R. Crim. 2.23(3)(d); and (2) because the record did not allow the Court to determine whether Defendant entered into the plea voluntarily and intelligently, the ineffective-assistance-of-counsel issue could not be addressed on direct appeal. Remanded. View "State v. Thacker" on Justia Law

A police officer stopped Defendant’s vehicle based upon a suspicion that Defendant was operating a vehicle without proper illumination. Defendant was subsequently arrested for, and charged with, driving while intoxicated. Defendant filed a motion to suppress, alleging that the arresting officer lacked reasonable suspicion to make a traffic stop and that, after his arrest, his rights under Iowa Code 804.20 were violated because the officer failed properly to inform him of the purpose of a phone call. The district court denied the motion. A jury subsequently found Defendant guilty of operating a motor vehicle while intoxicated. The Supreme Court affirmed, holding (1) the deputy had a reasonable suspicion that there was no working license plate light on Defendant’s vehicle; and (2) law enforcement officers are not required to explain that a purpose of the phone call is to obtain advice regarding whether to submit to a chemical test. View "State v. Lyon" on Justia Law

Defendant was arrested for public intoxication. The State filed a criminal complaint 120 days later charging Defendant with operating while intoxicated (OWI). The complaint arose from the same incident that resulted in the public intoxication arrest. Defendant filed a miss to dismiss the ensuing trial information charging him with OWI, claiming that the State was required to indict him under the speedy indictment rule for OWI within forty-five days of his arrest because he maintained a reasonable belief that he had been arrested for OWI at the time. The district court dismissed the motion and found Defendant guilty of OWI. The public intoxication charge was dismissed. The court of appeals reversed, concluding that the State was required to indict Defendant for OWI within forty-five days of the arrest because the officers could only have arrested Defendant for the crime of OWI. The Supreme Court vacated the court of appeals and affirmed the district court, holding that the speedy indictment rule is not triggered for a prosecution of a public offense by an arrest that resulted in an earlier prosecution of a separate offense arising from the same incident. View "State v. Penn-Kennedy" on Justia Law

After a jury trial, Defendant was convicted of third-degree burglary for entering a soon-to-be demolished, dilapidated house to obtain scrap metal. Defendant appealed, arguing (1) the evidence was insufficient to support the jury’s conclusion that he entered an occupied structure, (2) the district court erred in submitting the adopted-for-overnight-accommodation and the used-for-the-storage-or-safekeeping-of-anything-of-value alternatives defining occupied structure to the jury; and (3) the district court erred in overruling his motion for mistrial based on alleged prosecutorial misconduct during closing argument. The court of appeals affirmed. The Supreme Court reversed the conviction, holding that the evidence was insufficient to support a conviction for burglary. View "State v. Rooney" on Justia Law

Defendant was charged with theft in the third degree based on her current crime and two prior theft convictions. Defendant moved to strike her 2003 conviction of theft in the third degree as a basis to support the charge of third-degree theft, asserting that the conviction was constitutionally infirm because she was not represented by counsel when she pled guilty and served a term of incarceration. In fact, Defendant was held in jail for one day prior to her initial appearance and then, upon pleading guilty, was sentenced to one day in jail, with credit for time served. The district court denied the motion, concluding that Defendant’s situation was not one in which she faced the possibility of imprisonment requiring the appointment of counsel. Defendant was subsequently found guilty of theft in the third degree. The Supreme Court reversed, holding (1) under the right to counsel provision under Iowa Const. art. I, 10, a misdemeanor defendant has a right to counsel when the defendant faces the possibility of imprisonment; and (2) because Defendant was not provided the assistance of counsel and the State stipulated there was not a valid waiver, the 2003 misdemeanor conviction could not be used as a predicate offense to enhance a later punishment. Remanded. View "State v. Young" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder and attempt to commit murder. The trial court imposed a sentence of life imprisonment for the murder conviction and a term of twenty-five years for the attempted murder conviction, to be served consecutively. The court of appeals affirmed, holding (1) the evidence was sufficient to support the convictions, there was no abuse of discretion in the imposition of the sentences, and defense counsel provided effective assistance; and (2) the district court erred in refusing to give an instruction describing the affirmative defense of intoxication, but Defendant was not prejudiced by the refusal. The Supreme Court vacated the portion of the court of appeals’ opinion that concluded that the district court erred in failing to submit the intoxication instruction to the jury and otherwise affirmed, holding that the district court did not abuse its discretion in failing to instruct the jury on how to apply the evidence of intoxication in deciding if the State established the specific-intent elements of the crimes. View "State v. Cordero" on Justia Law