Justia Iowa Supreme Court Opinion Summaries

Defendant pleaded guilty to attempted murder and was sentenced to twenty-five years in prison. Defendant appealed, claiming his counsel provided ineffective assistance because counsel permitted him to plead guilty without an established factual basis for each element of the crime. The court of appeals vacated Defendant's conviction and sentence and remanded the case, concluding that the guilty plea colloquy failed to establish a factual basis for the underlying charge. The Supreme Court vacated the court of appeals' decision and affirmed the conviction and sentence of the district court, holding that the minutes of testimony provided an adequate factual basis to support Defendant's guilty plea. View "State v. Finney" on Justia Law

Defendant was charged with several crimes based on his involvement in a shooting. The jury found Defendant guilty of intimidation with a dangerous weapon with intent, among other crimes. At the same time, the jury answered “no” to a special interrogatory asking whether Defendant had possessed a firearm. The district court concluded that the verdicts were inconsistent and proposed that the matter be resubmitted to the jury. However, Defendant and the State requested that the court accept the verdicts as rendered. Accordingly, the district court accepted the verdicts. Defendant subsequently appealed. The court of appeals reversed and remanded for a new trial on the intimidation charge, finding the special interrogatory answer in direct conflict with the jury’s guilty verdict. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding that the verdicts were not inconsistent based on how the case was charged to the jury. View "State v. Merrett" on Justia Law

Defendant was charged with and convicted of operating a motor vehicle while under the influence. Defendant appealed, contending that the district court erred in denying his motion to suppress the evidence obtained from the stop of his vehicle after the police received an anonymous tip reporting a drunk driver. The Supreme Court reversed and suppressed all evidence seized from the stop, holding that the investigatory stop of Defendant was illegal under the Fourth Amendment, as a bare assertion by an anonymous tipster reporting drunk driving, without relaying to the police a personal observation of erratic driving or other facts to establish the driver is intoxicated, does not provide reasonable suspicion to stop a vehicle. Remanded for a new trial. View "State v. Kooima" on Justia Law

After a jury trial, Defendant was convicted of escape. Defendant appealed, arguing, among other things, that the district court abused its discretion when it refused to instruct the jury that the crime of absence from custody was a lesser included offense of escape. The court of appeals denied each claim raised by Defendant and affirmed. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the district court, holding that the crime of absence from custody is a lesser included offense of the crime of escape. Remanded for a new trial. View "State v. Miller" on Justia Law

Anthony Geltz was prosecuted as a juvenile and adjudicated delinquent for sexual abuse in the second degree for an offense he committed when he was fourteen years old. After Geltz turned eighteen, the State petitioned to have him declared a sexually violent predator (SVP) under Iowa Code 229A.2(11). The district court ordered Geltz confined as an SVP based on Geltz's previous offense. The Supreme Court reversed, holding (1) a juvenile adjudication does not constitute a predicate conviction required to commit an offender as an SVP pursuant to section 229A.2; and (2) therefore, the district court erred in committing Geltz as an SVP solely on the basis of his juvenile adjudication for the offense he committed at age fourteen. View "In re Detention of Geltz" on Justia Law

Defendant pled guilty to four counts of fraudulent practices for willfully failing to file his Iowa income tax returns and pay taxes for the years 2006 through 2009. After a restitution hearing, the district court ordered Defendant to pay restitution in the form of unpaid taxes but denied the State's request for penalties and interest as part of the restitution order. The Supreme Court reversed the district court's denial of penalties and interest as part of the restitution order, holding that the court erred by not including in its restitution order (1) the requested civil tax penalties, as the civil tax penalties were properly awarded as an element of pecuniary damages in the restitution order; and (2) prejudgment and postjudgment interest at the statutory rate under Iowa Code 421.7. View "State v. Hagen" on Justia Law

Defendant pleaded guilty to possession of marijuana. At the hearing on Defendant's plea and sentencing, the sentencing court threatened to convict Defendant, instead of deferring judgment, if Defendant's declined to answer the court's inquiry on whether he would test positive on a drug test. Defendant invoked his right to remain silent. The court deferred judgment but imposed 250 hours of community service and a $350 penalty. The Supreme Court vacated Defendant's sentence and remanded for resentencing, holding that the district court improperly penalized Defendant for invoking his right against self-incrimination by imposing 250 hours of community service unconnected to any legitimate penological goal related to the court's drug-test inquiry. Remanded for resentencing. View "State v. Washington" on Justia Law

After a jury trial, Defendant was convicted of five counts of sexual exploitation of a minor and three counts of sexual exploitation by a school employee. Defendant appealed, arguing, among other things, that he could not be convicted of sexual exploitation by a school employee because none of the students involved with Defendant at the time of the events charged in the trial information were in an existing teacher-student relationship with Defendant. The court of appeals affirmed Defendant's convictions. The Supreme Court affirmed, holding that the district court did not err in (1) concluding that a contemporaneous teacher-student relationship was not required for Defendant to be convicted of sexual exploitation by a school employee; (2) concluding that physical contact between a school employee and student was not required to support a conviction for sexual exploitation by a school employee; and (3) refusing to sever Defendant's charges into multiple trials. View "State v. Romer" on Justia Law

The State charged Defendant by way of trial information of "assault domestic abuse causing bodily injury - enhanced" and "assault domestic abuse by use or display of a weapon." At the close of evidence during the trial, the State moved to amend the trial information to add a habitual offender enhancement. Defendant's trial counsel did not object to the amendment, and the district court granted the State's motion. Defendant was subsequently convicted Defendant of the underlying charge in count I. After Defendant was sentenced, Defendant appealed, asserting that his trial counsel was ineffective for failing to object to the State's motion to amend the trial information. The court of appeals denied relief. The Supreme Court affirmed Defendant's conviction and sentence but vacated the court of appeals decision to reject Defendant's ineffective-assistance claim, holding (1) under certain circumstances, an amendment to add a habitual offender enhancement to a trial information should not be allowed after the close of the evidence; but (2) the record in this case was insufficient to resolve Defendant's ineffective assistance of counsel claim. View "State v. Brothern" on Justia Law

Defendant, a parolee, was charged with four drug-related crimes after a search of her house by narcotics police officers revealed firearms and marijuana. Defendant filed a motion to suppress the marijuana as evidence at trial, arguing that it was obtained in violation of her Fourth Amendment rights because she did not consent to the search. The district court found that Defendant gave advance consent to search her property without a warrant or probable cause by signing a parole agreement and that the search was justified under exigent circumstances and the community caretaking function. Defendant was then convicted as charged. The Supreme Court reversed, holding (1) three of Defendant's convictions must be dismissed for a lack of substantial evidence; and (2) the warrantless search of Defendant's home and seizure of the evidence violated the Iowa Constitution, as (i) Defendant's parole agreement did not justify the search of her home, and (ii) no exception to the warrant requirement justified the search. View "State v. Kern" on Justia Law