Justia Iowa Supreme Court Opinion Summaries

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

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