Justia Iowa Supreme Court Opinion Summaries

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

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