Justia Iowa Supreme Court Opinion Summaries

After he was arrested for operating a motor vehicle while intoxicated (OWI), Defendant sought legal advice regarding whether to submit to a chemical breath test during a teleconference with a lawyer. Defendant asked for privacy during the call, but rather than tell Defendant that private, in-person attorney-client consultations were permitted at the jail, the arresting officer simply told Defendant that he could not consult confidentially with his lawyer while “on the phone.” Defendant subsequently took the Breathalyzer test. The district court denied Defendant’s motion to suppress the breath test results and convicted him of OWI. The Supreme Court reversed and remanded for a new trial, holding (1) Defendant adequately invoked his statutory right to a confidential attorney-client consultation under Iowa Code 804.20, and therefore, the officer was required under the statute to inform Defendant that his attorney must come to the jail for a confidential conference; and (2) the remedy for such a violation of section 804.20 rights is suppression of the chemical test evidence. View "State v. Hellstern" on Justia Law

Defendant was charged with first-degree kidnapping. The trial information included a proposed enhancement based on Defendant’s prior Ohio conviction of a sexually predatory offense. A jury ultimately found Defendant guilty of the lesser included offense of third-degree kidnapping. Thereafter, the district court ruled that the third-degree kidnapping conviction did not qualify as a sexually predatory offense within the meaning of Iowa Code 901A.1(1) and thus denied the enhancement. The court of appeals vacated Defendant’s sentence and remanded for resentencing, holding that Defendant’s third-degree kidnapping conviction was a sexually predatory offense because during trial the jury had found that Defendant had committed kidnapping with the specific intent to subject the victim to sexual abuse. The Supreme Court affirmed, holding that a jury finding that the defendant committed kidnapping with intent to subject the victim to sexual abuse can serve as the basis for an enhanced sentence. View "State v. Walker" on Justia Law

Defendant was charged with four counts of unintentionally causing serious injury by intoxicated use of a motor vehicle. Before trial, the State moved to allow three out-of-state victims of the car accident and three lab analysts employed by the State to testify remotely via two-way videoconferencing technology rather than physically appearing in court. After a hearing, the district court granted the State’s motion for distance testimony. Defendant appealed, arguing that the trial court’s decision to permit the State’s witnesses to testify remotely violated his Sixth Amendment right to be confronted with the witnesses against him. The Supreme Court reversed, holding (1) before permitting a witness to testify via two-way videoconference, a court must make a case-specific determination that the denial of the defendant’s confrontation right is necessary to further an important public interest; and (2) applying this standard to the instant case, the district court erred in allowing the videoconference testimony. View "State v. Rogerson" on Justia Law

Defendant was a pastor who had sexual relations with four women in his congregation. Defendant was convicted of four counts of sexual exploitation by a counselor or therapist and one count of a pattern or practice to engage in sexual exploitation by a counselor or therapist. The court of appeals reversed and remanded for a new trial, holding that the district court failed properly to instruct the jury on the sexual exploitation statute and that the district court abused its discretion in excluding expert testimony concerning differences between pastoral care and pastoral counseling. The Supreme Court vacated the decision of the court of appeals, concluding that the district court did not err in instructing the jury and excluding the proffered expert testimony. The Court then held (1) the district court erred in denying Defendant’s discovery request for one of the victim’s counseling records and erred in the amount of restitution awarded; and (2) the district courts judgment was correct in all other respects. Remanded. View "State v. Edouard" on Justia Law

The State charged Defendant, a probationer, with burglary and theft after police officers conducted a warrantless search of Defendant’s home. Defendant filed a motion to suppress contending that the search warrant was invalid because it inaccurately described the house to be searched and because an alteration of the warrant based upon a verbal conversation with the issuing judge violated the statutory requirement that search warrant applications be in writing. The district court overruled the motion to suppress, concluding that the search warrant was inadequate but that the warrant was valid because the search was within the contemplation of the probation agreement. The court of appeals affirmed, concluding that the search of the probationer based upon reasonable suspicion of criminal activity and based upon the limited scope of the search was valid under the search and seizure provision of Iowa Const. art I, 8. The Supreme Court reversed, holding that, in accordance with State v. Cullison, the search of Defendant’s home by general law enforcement authorities was unlawful under the Iowa Constitution because the search was based on an invalid warrant. View "State v. Short" on Justia Law

When he was seventeen years old, Appellant committed the crime of first-degree robbery. Appellant was sentenced to a term of imprisonment not to exceed twenty-five years. Appellant was sentenced under a statute that required him to serve at least seventy percent of his sentence before he was eligible for parole. Appellant appealed, arguing that his sentence constituted cruel and unusual punishment. The Supreme Court vacated the sentence and remanded to the district court for resentencing, holding that, for the reasons express in State v. Lyle, filed on this same date, the mandatory sentence violated the prohibition against cruel and unusual punishment under the Iowa Constitution. View "State v. Taylor" on Justia Law

Appellant was a seventeen-year-old high school student when he took a small plastic bag containing marijuana from a fellow student outside the high school. After a jury trial, Appellant was convicted of robbery in the second degree. Appellant was prosecuted as an adult and was sentenced under a statute that required the imposition of a mandatory seven-year minimum sentence of imprisonment. Appellant appealed, arguing that the mandatory minimum was unconstitutional as applied to him. During the pendency of the appeal, the United States decided Miller v. Alabama. The court of appeals affirmed the sentence. The Supreme Court granted review to consider whether Appellant’s sentence was constitutional in light of the cases the Court handed down subsequent to Miller. The Supreme Court vacated the sentence and remanded for resentencing, holding that a statute mandating a sentence of incarceration in a prison for juvenile offenders with no opportunity for parole until a minimum period of time has been served is unconstitutional under the Iowa Constitution. View "State v. Lyle" on Justia Law

Defendant pleaded no contest to second-degree sexual assault of a child, a felony, in Wisconsin. The Wisconsin trial court deferred judgment of conviction (DJOC), which allowed the Wisconsin court to refrain from entering an adjudication of guilt and a judgment for four years if Defendant agreed to certain terms. Before the termination of the DJOC, the state of Iowa charged Defendant with a violation of Iowa’s felon-in-possession statute, Iowa Code 724.26, which prohibits felons from possessing firearms in Iowa. Defendant filed a motion to dismiss the Iowa charge, arguing that the predicate Wisconsin felony was not a conviction for purposes of section 724.26. The district court denied the motion. The Supreme Court affirmed, holding that district court properly denied Defendant’s motion to dismiss the case where the Wisconsin court found Defendant guilty upon his tendering of a no contest plea and where Defendant had not completed the terms of his deferred judgment on his felony count. View "State v. Olsen" on Justia Law

After a jury trial, Defendant was convicted of first-degree sexual abuse for performing a sex act on a two-year-old girl. Defendant appealed, arguing that the district court erred by admitting as prior bad acts evidence the fact that child pornography was found on Defendant’s computer and other electronic devices. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court did not abuse its discretion by admitting the evidence that Defendant possessed specific videos involving child sexual abuse, as the evidence was relevant to the issue of the identity of the perpetrator, and the evidence’s probative value was not substantially outweighed by the danger of unfair prejudice. View "State v. Putnam" on Justia Law

Defendant was charged with and pled guilty to criminal transmission of HIV in violation of Iowa Code 709C.1. The district court accepted the plea, sentenced Defendant to twenty-five years suspended and placed Defendant on probation for five years. Defendant subsequently filed an application for postconviction relief, claiming that his trial counsel provided ineffective assistance for allowing him to plead guilty, by failing to challenge the factual basis of the plea, and failing to complete a proper investigation before the plea hearing. The district court denied the application, and the court of appeals affirmed. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the trial court, holding that the guilty plea record did not contain a factual basis to support the plea, and the court in this case could not use the rule of judicial notice to establish the factual basis in the guilty plea record. Remanded. View "Rhoades v. State" on Justia Law