Justia Iowa Supreme Court Opinion Summaries

In 2001, Calvin Matlock was confined to the Civil Commitment Unit for Sexual Offenders (CCUSO). In 2013, the district court found the State failed to meet its burden to prove Matlock’s mental abnormality made him likely to engage in predatory acts that constitute sexually violent offenses if discharged. The court then ordered Matlock released with supervision. Matlock appealed, arguing that, once the court found he no suffered from a mental abnormality that made him likely to engage in acts of sexual violence, release with supervision violated his due process rights. The Supreme Court (1) affirmed the part of the district court judgment releasing Matlock with supervision, holding the statutory scheme found in Iowa Code 299A did not violate the Due Process Clauses of the state or federal Constitutions so long as Matlock continued to suffer from a mental abnormality and the testimony supports the need for supervision upon release; but (2) remanded for a determination that the State proved the terms of supervision were consistent with due process principles, holding that the record was insufficient for the Court to determine whether the specific release conditions ordered by the district court comported with Matlock’s due process rights. View "In re Detention of Matlock" on Justia Law

In 2008, the district court placed Stephen Curtiss in the Civil Commitment Unit for Sexual Offenders (CCUSO). In 2011, the district court found the State failed to meet its burden to prove Curtiss was likely to commit a sexual offense if discharged and ordered Curtiss released with supervision. While released with supervision, Curtiss committed several violations of his release conditions. After a hearing, the district court found the State met its burden to prove that Curtiss had violated his release plan and returned him to CCUSO in the full commitment side of the facility. The Supreme Court affirmed, holding that, pursuant to Iowa Code 229A, the district court properly returned Curtiss to the secure side of CCUSO upon revocation of his release. View "In re Detention of Curtiss" on Justia Law

Defendant was charged with first-degree murder. The district court appointed two attorneys from the Des Moines adult public defender’s office to represent Defendant. When the two attorneys discovered that other attorneys in their office had previously represented three of the State’s witnesses on unrelated matters, the attorneys requested a determination whether a conflict of interest existed requiring their disqualification. After a hearing, the district court concluded that a conflict of interest disqualified all attorneys employed at the public defender’s office from serving as Defendant’s counsel in this case. The Supreme Court reversed, holding that the prior representations of the witnesses in unrelated matters by other members of the public defender’s office did not represent an actual conflict or a serious potential conflict that justified disqualification of the attorneys. View "State v. McKinley" on Justia Law

After the State withdrew its first plea offer and proposed a second, less favorable plea offer, Defendant accepted the second plea offer and pleaded guilty to second-degree burglary and assault with intent to commit sexual abuse not resulting in injury. The district court imposed an indeterminate term of imprisonment not to exceed fourteen years. Defendant filed this petition for postconviction relief asserting several claims of ineffective assistance of counsel. Specifically, Defendant claimed that he received ineffective assistance as a result of counsel’s failure to accurately inform him of the terms and potential sentencing outcomes of the State’s first plea offer. The district court denied the petition on all grounds. The Supreme Court affirmed, holding (1) counsel may have failed to perform an essential duty when he did not accurately inform Defendant of the exact terms and sentencing outcomes of the first plea offer, but (2) because Defendant did not show he would have accepted the first plea offer had counsel accurately informed him of its exact terms and potential sentencing outcomes, Defendant failed to establish the necessary prejudice to succeed on his ineffective assistance of counsel claim. View "Dempsey v. State" on Justia Law

Following a jury trial, Defendant was found guilty of six drug-related crimes. After Defendant was sentenced, the court of appeals reversed one of Defendant’s convictions, and Defendant received a resentencing hearing on the five convictions that were not reversed. The new sentence was the same as the original sentence with the only difference being that the new sentence did not include one of the five-year sentences as a result of the reversal of the single conviction. The Supreme Court affirmed the sentence of the district court, holding (1) the sentencing court did not abuse its discretion in imposing the sentence; and (2) the record was not adequate to address Defendant’s ineffective assistance of counsel claim. View "State v. Hopkins" on Justia Law

After a jury trial, Defendant was convicted of two counts of sexual abuse in the second degree and one count of lascivious acts with a child. Defendant appealed, arguing, among other things, that trial counsel was ineffective in failing to object to a lascivious-acts jury instruction that he claimed was not supported by sufficient evidence. The court of appeals affirmed. The Supreme Court addressed only Defendant’s claim regarding counsel’s response to the lascivious-acts instruction and let the court of appeals’ affirmance on the remaining issues stand as the final decision of the Court. The Supreme Court affirmed, holding that Defendant failed to establish that he suffered prejudice as a result of counsel’s failure to object to the lascivious-acts instruction, and therefore, his ineffective-assistance-of-counsel claim must fail. View "State v. Thorndike" on Justia Law

After a jury trial, Defendant was convicted of domestic abuse assault causing bodily injury. The Supreme Court vacated the judgment of the court of appeals and affirmed, holding (1) trial counsel was not ineffective in failing to object on Confrontation Clause grounds to the testimony of a law enforcement officer regarding the complaining witness’s out-of-court statements; and (2) the record was insufficient to determine whether trial counsel should have objected to and move to strike as hearsay the officer’s unsolicited testimony regarding another witness’s out-of-court statement. View "State v. Tomkins" on Justia Law

After a jury trial, Defendant was found guilty of first-degree arson. On appeal, Defendant requested a judgment of acquittal or, alternatively, a new trial, claiming that the evidence was insufficient to support the conviction and that his pretrial counsel operated under a conflict of interest due to his representation of a prosecution witness. The court of appeals reversed, holding that Defendant’s pretrial counsel’s conflict of interest required reversal of Defendant’s conviction. The Supreme Court vacated the decision of the court of appeals and affirmed the district court’s judgment of conviction and sentence, holding that, where the district court replaced the conflicted defense attorney with a conflict-free attorney more than three months before trial, and there was no showing that the previous conflict had ongoing adverse effects on the representation, a new trial was not required. View "State v. Vaughan" on Justia Law

Defendant was convicted of first-degree kidnapping allegedly arising out of a sexual assault. The court of appeals affirmed the conviction. Defendant appealed, raising eight allegations of error. The Supreme Court affirmed in part and vacated in part the decision of the court of appeals and reversed the conviction, holding (1) there was insufficient evidence in the record to support the kidnapping conviction; (2) Defendant was not entitled to relief on his claim that he was improperly denied access to barrier-free contact with his counsel prior to trial; and (3) the remaining arguments raised by Defendant on appeal were properly resolved by the court of appeals. View "State v. Robinson" on Justia Law

In this case involving a violent domestic altercation, Defendant was charged with kidnapping in the first degree, attempted murder, and willful injury causing bodily injury. The jury was instructed on each of the offenses. The attempted murder instruction included assault with intent to inflict serious injury as a lesser included offense. The jury acquitted Defendant of kidnapping and attempted murder but found him guilty of the lesser included charge of assault with intent to inflict serious injury as well as the willful injury causing bodily injury charge. The district court sentenced Defendant to terms of imprisonment for the willful injury conviction and for the assault conviction. Defendant appealed, arguing that the district court erred in sentencing him for two separate crimes because the assault conviction should have merged with the willful injury conviction under Iowa’s merger statute. The Supreme Court vacated Defendant’s conviction of assault with intent, holding that, under the unique circumstances of the instructions given in this case, the offenses of willful injury and assault with intent should merge. Remanded for sentencing on the willful injury conviction. View "State v. Love" on Justia Law