Justia Iowa Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of third-degree sexual abuse. Six years later, the Supreme Court overturned Defendant's conviction and sentence and remanded for a new trial. The second trial resulted in Defendant's acquittal. Defendant subsequently filed an application to be declared a wrongfully imprisoned individual pursuant to Iowa Code 663A.1. The district court granted the application. The State appealed. The Supreme Court reversed and remanded, holding (1) Defendant was eligible to bring a wrongful imprisonment claim when he was acquitted on retrial; (2) the district court erred by failing to consider testimony that had been presented at Defendant's two criminal trials in making the wrongful imprisonment determination, even though the State did not show the witnesses were no longer available; and (3) while substantial evidence supported the district court's finding of innocence on the existing record, a remand was necessary for the court to consider the full record, including the prior testimony.View "State v. DeSimone" on Justia Law

After a jury trial, Defendant was found guilty of possession of marijuana and crack cocaine with intent to deliver. The court of appeals reversed, holding that there was insufficient evidence to support the convictions. The Supreme Court reinstated Defendant’s convictions, holding (1) considering the totality of the evidence in this case, the evidence was sufficient to sustain a jury verdict of guilt; and (2) the district court correctly found that the State provided a race-neutral explanation for striking a potential alternate juror, and therefore, there was no Batson error in jury selection. View "State v. Thomas" on Justia Law

Defendant was the driver in an accident that resulted in the deaths of Mark Empen and Lindsay Gibbs. Defendant entered into civil settlement agreements with the estates of Empen and Gibbs. Defendant subsequently pleaded guilty to two counts of homicide by vehicle. The district court sentenced Defendant to a term of imprisonment and ordered Defendant to pay restitution to the victims' families. Several years later, Defendant applied for an order stating he had satisfied his restitution obligation, arguing that the settlement amounts paid to the victims' estates should be set off against the restitution amounts he was ordered to pay the families. The district court denied the applications. The Supreme Court reversed, holding that Defendant was entitled to a setoff for the settlement payments made to each estate.View "State v. Driscoll" on Justia Law

Defendant pleaded guilty to theft and agreed to enter a drug court program. The district court also ordered that Defendant participate in residential treatment at the Iowa Residential Treatment Center (IRTC). As a result of drug court program violations, Defendant was incarcerated in jail for a period of time. Defendant was later arrested for another violation of the terms of the drug court program. The district court then removed Defendant from participation in the drug court program and imposed a sentence for second-degree theft as a habitual offender pursuant to the plea bargain. Upon resentencing, the district court denied Defendant credit for time spent at IRTC and for the time Defendant spent in jail. The Supreme Court vacated the district court sentence in part, holding that Defendant was entitled to credit for time spent at the IRTC and for time spent in jail as a result of his drug court program violations. View "State v. Calvin" on Justia Law

Defendant was convicted of operating while intoxicated, second offense. Defendant appealed the district court’s denial of his motion to suppress the breath-test result obtained after his arrest, arguing that he had been denied his statutory right to an independent chemical test. The court of appeals reversed, concluding that the district court erred in denying Defendant’s motion to suppress. The Supreme Court affirmed, holding (1) Defendant’s statutory right to an independent chemical test was violated when he made statements that could be reasonably construed as a request for an independent test under Iowa Code 321J.11 but law enforcement denied his request, and (2) the error was not harmless. Remanded for a new trial. View "State v. Lukins" on Justia Law

Defendant was charged with and found guilty of driving under revocation. Defendant appealed, arguing that the district court’s admission of a certified abstract of his driving record and affidavits of the mailing of suspension notices violated his rights under the Confrontation Clauses of the United States and Iowa Constitutions. The court of appeals concluded that the admission of the disputed documents did not violate the Confrontation Clauses. The Supreme Court affirmed, holding (1) the admission of the certified abstract of Defendant’s driving record did not violate the Confrontation Clauses; and (2) the admission of the affidavits of the mailing of suspension notices violated the Confrontation Clauses, but their admission into evidence was harmless error. View "State v. Kennedy" on Justia Law

Police officers stopped Defendant’s vehicle after discovering that the vehicle’s license plate frame covered up the county name on the license plate, which the officers believed violated Iowa Code 321.37(3). As a result of the stop, Defendant was charged with possession with intent to deliver crack cocaine, a drug tax stamp violation, and driving under suspension. A district court judge denied Defendant’s motion to suppress, concluding that the license plate frame violation gave no reason to stop Defendant but that the stop was lawful based on a reasonable suspicion of drug dealing. A different judge who presided at trial upheld the stop based on the license plate violation alone. After a jury trial, Defendant was found guilty as charged. The court of appeals affirmed, which held that the traffic stop was lawful based on reasonable suspicion of drug dealing without deciding the license plate issue. The Supreme Court affirmed the conviction without reaching the issue of whether the traffic stop was lawful based on reasonable suspicion of drug dealing, holding that a license plate frame that covers up the county name violates Iowa Code 321.37(3) and provides a valid basis for a traffic stop. View "State v. Harrison" on Justia Law

Appellant was a registered sex offender who was not permitted to loiter within 300 feet of a public library. In 2012, Appellant was arrested for sitting on a park bench located across the street from the main entrance of a public library. Appellant was facing the library and had been sitting on the bench, which was seventy-two feet from the front door of the library, for approximately forty-five minutes. The district court subsequently convicted Defendant of loitering within 300 feet of a public library in violation of Iowa Stat. 692A.113(1)(g). On appeal, Appellant contended that there was insufficient evidence was “loitering” within the meaning of the statute. The Supreme Court reversed the conviction and remanded for new findings, conclusions, and judgment because it was unclear whether the district court applied the appropriate legal standard in this case. View "State v. Showens" on Justia Law

After a jury trial, Defendant was convicted of sexual exploitation by a school employee in violation of Iowa Code 709.15(3)(a) and (5)(a). At the time of the offense, Defendant was a worker at a local pipe manufacturer who, while not a licensed teacher, coached high school basketball under a coaching authorization. Defendant appealed, arguing that he was not a school employee as the term is used under section 709.15(3)(a), and therefore, he was not subject to criminal prosecution under this statute. The Supreme Court reversed and remanded with instructions to dismiss the case, holding that a coach who holds a teaching or other professional license is subject to the statute, but a mere holder of a coaching authorization without a professional license within the meaning of Iowa Code 272.1(7) does not fall under the sexual exploitation statute. View "State v. Nicoletto" on Justia Law

After a jury trial in 2007, Tammy Smith was convicted of child endangerment resulting in serious injury against her four-year-old son. The court of appeals affirmed on appeal. In 2009, Smith applied for postconviction relief based on evidence that her son communicated that his injury occurred when he placed his arm in the washing machine. The court of appeals held that this was newly discovered evidence and remanded for a new trial. On remand, the district court vacated Smith’s conviction and dismissed the case against Smith. In 2011, Smith filed a petition for wrongful imprisonment. The district court found that Smith did not establish by clear and convincing evidence neither she nor anyone else committed the crime of child endangerment. The court of appeals affirmed. The Supreme Court affirmed, holding that substantial evidence supported the district court’s finding that Smith did not establish her wrongful imprisonment action by clear and convincing evidence. View "Smith v. State" on Justia Law