Justia Iowa Supreme Court Opinion Summaries

Defendant was arrested and charged with operating a vehicle while under the influence of a controlled substance in violation of Iowa Code 321J.2(1)(c). Defendant asserted an affirmative defense under section 321J.2(7)(b), which provides that an operator of a vehicle cannot be convicted of operating under the influence of a drug if he is taking the drug as prescribed by his doctor and in accordance with the labeling directions of the pharmacy. After a jury trial, Defendant was convicted of operating while intoxicated. The Supreme Court reversed, holding that there was insufficient evidence to support the verdict because the evidence was too speculative for a jury to conclude beyond a reasonable doubt that Defendant failed to take the prescription drugs as directed by his doctor or the pharmacy. View "State v. Schories" on Justia Law

Defendant was one of several adult caregivers for a five-year-old girl suffering from malnutrition. The State charged Defendant with two counts of child endangerment, and a jury found Defendant guilty of child endangerment causing serious injury. Defendant appealed, contending that the district court erred by allowing a caseworker for the Department of Human Services (DHS) to testify that a child abuse report against Defendant was administratively determined to be "founded." The Supreme Court reversed the judgment of the district court and remanded the case for a new trial, holding that it was reversible error to allow testimony that DHS had determined the child abuse complaint against Defendant was founded. View "State v. Huston" on Justia Law

Defendant was charged with second-degree sexual abuse and child endangerment causing bodily injury after he admitted to sexually abusing a seventeen-month-old. Defendant moved to suppress his confession, claiming it was involuntary because the detective made promises of helping Defendant if he admitted to the crime. The district court denied the motion, holding that a promise to get help for a defendant does not constitute a promise of leniency. Defendant was found guilty of the charges. Defendant appealed the denial of his motion to suppress. The court of appeals affirmed, holding that the detective's statements about getting Defendant help were not impermissible promises of leniency. The Supreme Court vacated the court of appeals, reversed the judgment of the district court, and remanded the case for a new trial on both counts, holding (1) the interrogation of Defendant crossed the line into an impermissible promise of leniency, rendering the confession that followed inadmissible; and (2) the error was not harmless. View "State v. Howard" on Justia Law

After a jury trial, Defendant was found guilty of second-degree burglary, operating a motor vehicle without the owner's consent, and operating a motor vehicle while intoxicated, second offense. Defendant appealed his burglary conviction. The court of appeals affirmed. The Supreme Court (1) affirmed the appellate court's decision holding that the evidence was sufficient to support the second-degree burglary conviction; (2) vacated the appellate court's decision with respect to Defendant's effectiveness of counsel claims, leaving all three ineffective-assistance-of-counsel claims for postconviction relief proceedings; and (3) affirmed Defendant's convictions for operating a motor vehicle without the owner's consent and operating a motor vehicle while intoxicated. View "State v. Clay" on Justia Law

Appellant, an ALJ within the Iowa Department of Corrections (IDOC), presided over the hearing of an inmate charged with assaulting a corrections officer. Appellant found the inmate guilty of assault. The Office of Citizens' Aide/Ombudsman (Ombudsman) subsequently launched an investigation into Appellant's ruling and subpoenaed her for deposition testimony. Appellant argued that she could assert the mental-process privilege in refusing to answer questions about her decision. The Ombudsman filed an action to enforce the subpoena. The district court ruled the mental-process privilege would not apply to limit deposition testimony in the Ombudsman's investigation, as opposed to a judicial proceeding, and entered an order compelling Appellant's deposition. Appellant and IDOC appealed. The Supreme Court affirmed but on different grounds, holding (1) the mental-process privilege is available to IDOC ALJs in an Ombudsman investigation; but (2) the Ombudsman made a sufficient showing to overcome the privilege. View "Office of Citizens' Aide/Ombudsman v. Edwards" on Justia Law

Defendant received suspended sentences for drug offenses and two years of probation. He was incarcerated after his probation was revoked. At issue on appeal was whether an offender accrues earned time under Iowa Code 903A.2 while on supervised probation before his incarceration. Defendant contended the Iowa Department of Corrections (IDOC) erroneously withheld his earned-time credit for the probationary period. IDOC argued earned-time credits are only earned while the offender is incarcerated. The district court denied earned-time credit for the time Defendant spent on supervised probation. The Supreme Court affirmed, holding that the district court did not err in ruling IDOC correctly calculated Defendant's discharge date because earned-time credits are only earned while the offender is incarcerated. View "State v. Allensworth" on Justia Law

In 1995, Appellant was convicted of first-degree armed robbery. In 2011, the governor commuted Appellant's sentence. Thereafter, Appellant filed an application for postconviction relief seeking recalculation of his earned time to comply with the governor's commutation of the mandatory minimum portion of his sentence. Specifically, Appellant contended that with the mandatory minimum portion of his sentence removed he was entitled to accumulate earned time at a faster rate than had been available to him under the original sentence, which included a mandatory minimum term of incarceration. If his earned time were calculated at the accelerated rate, Appellant contended he would be entitled to an immediate release. The district court denied his application. The Supreme Court (1) affirmed the district court's determination that the governor's commutation order did not entitle Appellant to an immediate discharge; but (2) reversed the part of the district court's ruling that the commutation had no effect on the rate of Appellant's accumulation of earned time and the resulting tentative discharge, as the legal effect of the governor's commutation order changed the rate at which Appellant could accumulate earned time from the date of the commutation forward. Remanded. View "Lowery v. State" on Justia Law

The district court found Defendant guilty of fraudulent practice in the third degree for possessing 218 packs of cigarettes lacking tax stamps. At issue on appeal was whether "the amount of money or value of property or service involved" in this crime was the amount of the unpaid tax or, rather, the value of the cigarettes. Defendant contended the degree of the crime should be based on the unpaid cigarette tax, which was insufficient to convict her of third-degree fraudulent practice. The district court determined the degree of fraudulent practice was based on the value of the cigarettes, not the amount of the unpaid tax. The court of appeals affirmed. The Supreme Court affirmed, holding that, under Iowa Code 453A.36, the possession of unstamped cigarettes was the fraudulent practice, not the unpaid tax, and therefore, the district court correctly entered judgment against Defendant for third-degree fraudulent practice. View "State v. Messer" on Justia Law

Appellant was convicted of first-degree in murder in 2005. In 2009, Appellant filed an application for postconviction relief alleging his trial was ineffective for (1) failing to raise the defense of temporary insanity or diminished capacity, and (2) failing to adequately support the request for bifurcation of his trial. Appellant also asserted his appellate counsel on direct appeal was ineffective for failing to appeal the trial court's denial of his request for bifurcation. The postconviction court denied Appellant's application. The court of appeals affirmed, finding that the postconviction court did not rule on Appellant's specific claims, and Appellant failed to preserve error by filing a subsequent motion under Iowa R. Civ. P. 1.904. The Supreme Court affirmed the denial of Appellant's application for postconviction relief, holding (1) the postconviction court did rule on Appellant's claims, and the claims were properly preserved for appeal; but (2) Appellant's claims lacked merit. View "Lamasters v. State" on Justia Law

Defendant was charged with murder in the first degree. Defendant provided notice he would be relying on the defense of insanity to the charge. The jury rejected the insanity defense and found Defendant guilty of first-degree murder. The district court sentenced Defendant to life in prison without the possibility of parole and ordered him to pay restitution for his attorney and expert witness fees. The court of appeals affirmed the conviction and restitution orders. Defendant appealed, claiming (1) the instructions given by the district court did not accurately define insanity, and (2) his own instruction should have been given. The Supreme Court affirmed, holding (1) the instructions given by the district court, when read as a whole, fairly and accurately advised the jury of the legal standard it was to apply to Defendant's insanity defense; and (2) due process under the Iowa Constitution does not require the district court to inform the jury of the consequences of a not-guilty-by-reason-of-insanity verdict under the facts of this case. View "State v. Becker " on Justia Law