Justia Iowa Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of possession of a controlled substance and introduction of a controlled substance into a detention facility. Defendant appealed, arguing that the district court entered an illegal sentence because the offenses of introduction and possession merged into a single offense by operation of Iowa’s merger statute. The court of appeals concluded that the offenses did not merge. The Supreme Court affirmed, holding that neither the merger statute nor double jeopardy principles formed a basis for reversing Defendant’s possession conviction and that the crimes may be simultaneously charged in one criminal prosecution. View "State v. Stewart" on Justia Law

Defendant was charged with operating while intoxicated, first offense. Defendant moved to suppress the evidence against her, arguing that the stop of her vehicle was made without probable cause or reasonable suspicion and that the implied consent statute was violated when the transporting deputy failed to administer a blood or urine test instead of insisting on a breath test after acquiring reasonable grounds to believe Defendant was impaired by a prescription drug. The district court overruled the motions to suppress and found Defendant guilty of the charge. The Supreme Court affirmed, holding (1) the investigatory stop of the vehicle did not violate the Fourth Amendment to the United States Constitution or Iowa Const. art. I, VIII; and (2) the legislature did not intend for the implied consent law to mandate a blood or urine test under the circumstances of this case but only intended to impose the implied consent penalty of license revocation for drivers suspected of driving under the influence of drugs other than alcohol who refuse to submit to a urine or blood test when requested by a law enforcement officer. View "State v. McIver" on Justia Law

Petitioner, a prison inmate, was ordered to pay restitution as part of his sentence and was required to pay fifteen percent of his income to his institutional account as restitution. When Petitioner began working for a private employer he petitioned the district court to modify the restitution plan to allow him to pay fifty percent of his earnings as restitution. The district court initially granted the request but then rescinded its prior order, concluding that the modified restitution order violated the state statutory scheme for the distribution of inmate earnings from private-sector employment. The Supreme Court reversed the district court decision to rescind the modified restitution order, holding that the amended restitution order was not contrary to the governing statutory scheme. View "State v. Morris" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree and other criminal offenses. The Supreme Court affirmed, holding (1) Defendant failed to preserve for appeal his argument that an instruction given to the jury that it may not consider a lesser offense unless it unanimously found Defendant not guilty of the greater offense was a misstatement of the law; (2) certain instructions concerning the various inferences and conclusions the jury was permitted to draw did not constitute reversible error; and (3) Defendant was not denied effective assistance of counsel for failing to argue that the contested instructions were improper. View "State v. Ambrose" on Justia Law

Defendant was in custody of a residential facility commonly referred to as a halfway house when he was charged with knowingly possessing marijuana on the grounds of a facility “under the management of the department of corrections” pursuant to Iowa Code 719.7(3)(c). After a jury trial, Defendant was convicted. Defendant appealed, arguing that his trial counsel provided ineffective assistance for specifically failing to assert that the evidence was insufficient to establish that the residential facility was an institution under the management of the Department of Corrections (Department). The Supreme Court reversed, holding that defense counsel was ineffective as a result of his failure to assert that there was insufficient evidence to show the residential facility was an institution under the management of the Department, and Defendant was prejudiced by the failure to his counsel to assert the claim. View "State v. Halverson" on Justia Law

Defendant pled guilty to two counts of incest and was sentenced to two consecutive terms of incarceration not to exceed five years. The Supreme Court remanded the case for resentencing on the grounds that the district court had relied upon an improper sentencing consideration. Upon resentencing, the district court again sentenced Defendant to two consecutive terms of incarceration not to exceed five years. In so doing, however, the court again referred to the impermissible sentencing factor. The Supreme Court vacated the sentence, holding that although the district court attempted to disclaim the reference to the impermissible sentencing factor, Defendant’s sentence must be vacated and remanded for resentencing to protect the integrity of the judicial system from the appearance of impropriety. View "State v. Lovell" on Justia Law

Defendant pleaded guilty to possession of a controlled substance pursuant to a plea agreement. The district court deviated from the recommended sentence in the plea agreement. However, the court did not give its reason for Defendant’s sentence in the written sentencing order. The court of appeals affirmed the sentence because, under current caselaw, Defendant waived his appeal rights as to his sentence by waiving reporting of the sentencing hearing. The Supreme Court affirmed in part and vacated in part the court of appeals, holding (1) a defendant who waives reporting of sentencing and fails to provide a recreated record does not waive error when the sentencing judge fails to indicate on the written record the reasons for the sentence imposed; and (2) the district court did not err by deviating from the plea agreement in this case. View "State v. Thompson" on Justia Law

After a jury trial, Defendant was convicted of sexual abuse in the second degree. The court of appeals reversed the conviction, concluding that Defendant was entitled to a new trial on the ground that an expert witness vouched for the credibility of the victim. The Supreme Court affirmed, holding that when the expert testified that the child victim’s “demeanor was completely consistent with a child who has been traumatized, particularly multiple times,” the expert indirectly vouched for the victim’s credibility, thereby commenting on Defendant’s guilt or innocence. Remanded for a new trial. View "State v. Jaquez" on Justia Law

After a jury trial, Defendant was convicted of one count of sexual abuse in the second degree. The court of appeals reversed, concluding that Defendant was entitled to a new trial on the ground that a certain expert witness vouched for the credibility of the victim. The Supreme Court affirmed, holding that the district court erred in allowing into evidence an objected to portion of the expert’s report to the jury, as the disputed portion of the testimony crossed the line and vouched for the victim’s credibility, and the expert’s statement prejudiced Defendant. Remanded for a new trial. View "State v. Brown" on Justia Law

After a jury trial, Defendant was convicted of two counts of sexual abuse in the second degree. The court of appeals reversed the conviction. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion by not dismissing the case due to the State’s alleged repudiation of a plea agreement; but (2) abused its discretion when it found the testimony of an expert witness did not amount to an impermissible comment on the victim’s credibility, as the testimony of two expert witnesses indirectly conveyed to the jury that the child’s out-of-court statements were credible. View "State v. Dudley" on Justia Law