Justia Iowa Supreme Court Opinion Summaries

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

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