Justia Iowa Supreme Court Opinion Summaries

Defendant was seventeen years old when he committed first-degree murder. Defendant was sentenced to life without parole, as required by Iowa law. Defendant later filed a motion to correct an illegal sentence. Before the trial court heard the motion and shortly after Miller v. Alabama was decided, Iowa’s Governor commuted the sentences of all juveniles previously convicted of first-degree murder to a life sentence with the possibility of parole after sixty years. The trial court then granted Defendant’s motion to the extent his sentence was imposed without “individualized consideration of the circumstances.” The court upheld Defendant’s sentence of life with parole eligibility after sixty years as commuted by the Governor. The Supreme Court vacated the sentence, holding (1) a court must use certain factors when it sentences a juvenile offender for first-degree murder; and (2) because the district court did not have the benefit of this decision when it sentenced Defendant, this case must be remanded for resentencing. View "State v. Seats" on Justia Law

After Defendant was released on parole, Defendant’s parole officer made a home visit to check on Defendant and conducted a search of Defendant’s bedroom. The search uncovered evidence used to prosecute and convict Defendant of the crime of possession of a controlled substance as a habitual offender. Defendant appealed the denial of his motion to suppress, arguing that the evidence was obtained in violation of the State Constitution. The Supreme Court adopted a special-needs exception that authorizes parole officers to search the home of a parolee without a warrant for purposes of parole supervision and then affirmed, holding that, under the special-needs exception to allow narrowly tailored parolee searches, Defendant’s constitutional rights were not violated in this case. View "State v. King" on Justia Law

After a jury trial, Defendant was found guilty of theft in the first degree. Defendant appealed the denial of his motion to suppress the search of his trailer, arguing that there was no probable cause to support the search warrant. Defendant also raised numerous claims of ineffective assistance of trial counsel. The court of appeals reversed and remanded the case for a new trial, concluding that there was no probable cause to support the search warrant. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding (1) the district court properly denied the motion to suppress because the issuing judge had a substantial basis for concluding there was probable cause to support the search warrant; and (2) the record was inadequate to reach the merits of Defendant’s ineffective-assistance-of-counsel claims. View "State v. McNeal" on Justia Law

After a jury trial, Defendant was found guilty of second-degree murder. Defendant appealed, arguing that his conviction should be vacated because of juror misconduct and juror bias and because of assorted errors in the district court’s evidentiary rulings. The court of appeals reversed Defendant’s conviction on the issue of juror bias. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the trial court, holding (1) the evidence does not support a finding of juror misconduct in this case; (2) the district court did not abuse its discretion in finding that a juror was not actually biased when, prior to the verdict, the juror clicked “like” on a Facebook comment by the victim’s stepmother which stated, “Give me strength”; and (3) the district court did not commit prejudicial error in its evidentiary rulings. View "State v. Webster" on Justia Law

At issue in this case was whether the front steps of a single-family home are a public place under Iowa’s public intoxication statute. Defendant was charged with public intoxication in violation of Iowa Code 123.46 after she was found intoxicated on the front steps of her home. After a jury-waived trial, the district court concluded that Defendant’s front stairs were a public place, and therefore, Defendant was guilty of public intoxication. The Supreme Court reversed, holding (1) the front steps of a single-family home are not a public place under section 123.46(2) unless the home’s residents make them public by extending a general invitation to the public at large to come upon the property; and (2) the evidence did not show that Defendant extended such an invitation to the public in this case. Remanded for the district court to dismiss the public intoxication charge. View "State v. Paye" on Justia Law

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