Justia Iowa Supreme Court Opinion Summaries

After a jury trial, Defendant Kenneth Madsen was convicted of two counts of sexual abuse in the second degree and one count of lascivious acts with a child. Madsen appealed, arguing (1) the district court erred in failing to suppress his confessions because his confessions were involuntary under the constitutional totality-of-the-circumstances test due to the detective's threat to make him late for work and promise that if Madsen confessed he could keep his name out of the newspaper and put the matter behind him; and (2) his counsel was ineffective for not attempting to suppress his confession under the common law evidentiary test for promises of leniency. The Supreme Court affirmed in part and reversed in part, holding (1) Madsen's trial counsel breached an essential duty by failing to move to suppress Madsen's confessions under the evidentiary test; (2) the interrogating officer made promises of leniency that required suppression of part of Madsen's confession, but Madsen's self-incriminating statements made before those promises remained admissible; and (3) Madsen was entitled to a new trial on one count of second-degree sexual abuse, but his two remaining convictions were affirmed based on lack of prejudice. View "State v. Madsen" on Justia Law

Defendant Anthony Polk confessed in a jailhouse interview to firing his handgun at the scene of a gang-related shooting that left two men with gunshot wounds. Polk filed a motion to suppress his conviction, contending that the interrogating police officer baited him into talking after Polk had invoked his Fifth Amendment right to remain silent and made improper promises of leniency that suggested by talking to police Polk could get a better deal and spend less time away from his children. The district court denied Polk's motion and convicted Polk of several weapon-related crimes. The Supreme Court reversed Polk's convictions and sentences, holding that the interrogating officer's promises of leniency rendered Polk's confession inadmissible, and therefore, the district court erred in denying Polk's motion to suppress. View "State v. Polk" on Justia Law

Petitioner, a juvenile offender whom the State tried as an adult, brought a postconviction relief action claiming that his conviction for first-degree murder should be overturned and that his sentence was illegal because it amounted to cruel and unusual punishment under the state and federal Constitutions. The district court dismissed both claims. The court of appeals affirmed, holding that Petitioner made the same claims in the past, and thus, the law of the case doctrine precluded the court from revisiting them. The Supreme Court vacated the decision of the court of appeals and reversed in part the judgment of the district court, holding (1) the law of the case doctrine precluded Petitioner from attacking his conviction for first-degree murder; but (2) the doctrine did not preclude Petitioner from attacking his sentence as illegal because the controlling authority regarding cruel and unusual punishment had changed since his original appeal regarding the issue, and the three-year limitation period for bringing a postconviction relief action did not prohibit a challenge to an illegal sentence. Remanded. View "State v. Ragland" on Justia Law

Charles Oliver was convicted a second time of third-degree sexual abuse, and Oliver stipulated that he had a prior conviction for third-degree sexual abuse. Because of his prior conviction, Oliver was guilty of a class A felony under the enhanced sentencing provisions of Iowa Code 902.14(1), and the district court accordingly sentenced Oliver to life in prison without the possibility of parole. The Supreme Court affirmed Oliver's sentence, holding (1) the sentence of life without parole did not constitute cruel and unusual punishment in violation of the state and federal Constitutions when considered in light of the particular facts of Oliver's case; and (2) section 902.14(1) was not unconstitutional either on its face or as applied to Oliver. View "State v. Oliver" on Justia Law

Defendant was convicted of possession of marijuana as an accommodation offense. Defendant was previously convicted of simple possession of marijuana. Defendant requested a sentencing hearing to determine whether he should be sentenced for a serious misdemeanor or an aggravated misdemeanor. The district court concluded the plain language of Iowa Code 124.410 and 124.401(5) provided Defendant be sentenced for a serious misdemeanor. The Supreme Court affirmed the judgment and sentence imposed by the district court, holding that the court did not misinterpret or misapply sections 124.401(5) and 124.410 when it sentenced Defendant for a serious misdemeanor under the circumstances presented here. View "State v. Dist. Court" on Justia Law

Police officers initiated an investigatory encounter with William DeWitt in Walmart based initially on information provided to them by a confidential informant. The officers decided to confront DeWitt and take him outside to his car to talk to him about their suspicion he was selling drugs. One or both of the officers took DeWitt by the arm. DeWitt broke free from their grasp, and the officers responded by taking him to the ground and handcuffing him. DeWitt was subsequently convicted of possession with intent to deliver, violation of the drug stamp act, and interference with official acts. The court of appeals affirmed the convictions. The Supreme Court affirmed, holding (1) the district court did not err in denying DeWitt's motion to suppress, as the officers' conduct in physically restraining DeWitt was not a violation of his right to be protected from unreasonable seizures under the state and federal constitutions; and (2) under the facts and circumstances of this case, the evidence was sufficient to support DeWitt's conviction. View "State v. DeWitt" on Justia Law

In this case, the Supreme Court considered whether an internal audit created by Broadlawns Medical Center as a result of the theft of drugs by an employee was a public record under the Iowa Open Records Act. The district court concluded that, because the internal audit was provided to the Iowa Board of Pharmacy in order to assist in its investigation of licensing matters arising from the theft, the internal audit amounted to investigative materials in the hands of a licensing board under Iowa Code 272C.6(4) and was not subject to disclosure. The Supreme Court (1) reversed the judgment of the district court holding that the internal audit was not subject to disclosure, as the internal pharmacy audit was a public record, not a confidential record, and other statutory exceptions asserted to prevent public disclosure were inapplicable; and (2) affirmed the rulings of the district court that the plaintiff failed to establish the basis for nondisclosure under Iowa Code 22.7(61). View "Hall v. Broadlawns Med. Ctr." on Justia Law

Rachel Overbay, the driver of a vehicle, was involved in an accident and transferred to the hospital. A law enforcement officer requested a blood sample from Overbay. Overbay, however, was incorrectly informed that her refusal of the requested chemical test would automatically lead to revocation of her driving privileges. In fact, Overbay's refusal of the blood test would not have been deemed final but would have led to her being offered a different chemical test. Overbay agreed to provide the blood sample, and the results showed a blood alcohol content of more than twice the legal limit. The State subsequently charged Overbay with operating a motor vehicle while under the influence of alcohol. The district court granted Overbay's motion to suppress, finding that Overbay's consent to the blood test was not voluntary because it was based on misleading information. The court of appeals affirmed. The Supreme Court vacated the court of appeals and reversed the district court, holding that consistent with precedent, inaccurate information does not render a driver's consent involuntary when the record indicates that the inaccuracy did not affect the driver's decision. Remanded. View "State v. Overbay" on Justia Law

Defendant Jerin Mootz was convicted for assault on a police officer resulting in bodily injury. During voir dire, Mootz sought to use a peremptory challenge to remove a Hispanic juror. The district court found Mootz was using his strikes in a racially discriminatory manner, denied the strike, and seated the juror. The court of appeals affirmed the conviction, finding that the district court erred in refusing to allow the strike of the potential juror, but that Mootz had not shown that the error prejudiced him. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the district court, holding (1) the trial court erred when it prohibited Mootz from using his peremptory challenge to remove the juror; (2) Mootz, or any other similarly situated defendant, was not required to show actual prejudice in order to reverse his conviction; and (3) automatic reversal is required whenever a defendant is denied the use of a peremptory challenge based on an erroneous interpretation of Batson v. Kentucky and its progeny and the objectionable juror is improperly seated. View "State v. Mootz" on Justia Law

Robert Lowe was charged with several criminal counts related to Lowe's alleged manufacture of methamphetamine. Lowe moved to certain suppress statements he made to the police. The district court granted the motion, determining that because the statements had been made in response to a promise of leniency they were rendered involuntary. The Supreme Court affirmed, holding (1) the consent that led to the search of the premises was proper and the motion to suppress the physical evidence obtained as a result of the search was properly denied; and (2) when police reinitiated questioning of Lowe after he requested an attorney, they violated his constitutional rights under Miranda, and because there was not sufficient exigency to justify such questioning, the public safety exception to Miranda did not apply under the facts of this case. Therefore, Lowe's statements were properly suppressed. View "State v. Lowe" on Justia Law