Justia Iowa Supreme Court Opinion Summaries

In 2010, Defendant pled guilty to stalking, first offense, with protective order, and fourth-degree criminal mischief. In 2011, Defendant was charged by information with stalking, second offense, or, alternatively, stalking in violation of a protective order. Defendant filed a motion to dismiss, arguing the State had not alleged sufficient facts to support a violation of the stalking statute, as the State had only detailed one incident of harassment. Specifically, Defendant argued that the use of the previous incidents, for which he was convicted, to prove the required course of conduct, would violate the double jeopardy clause. The district court granted the motion. The Supreme Court reversed, holding that the stalking statute, as applied in this case, did not violate the double jeopardy clause. View "State v. Lindell" on Justia Law

Defendant killed her longtime boyfriend. At trial, Defendant raised a defense of justification based on evidence of battered women's syndrome and a defense of insanity based on various diagnoses including depression and an anxiety disorder. Defendant was convicted of first-degree murder. The Supreme Court affirmed the conviction, holding that the district court did not erroneously (1) instruct the jury on the elements of a justification defense; (2) instruct the jury that Defendant bore the burden to prove an insanity defense; and (3) deny Defendant's motion for mistrial after the prosecution violated a ruling in limine during opening statements. View "State v. Frei" on Justia Law

Respondent was incarcerated with an approaching release when the State filed a petition alleging Respondent was a sexually violent predator (SVP) under Iowa's civil commitment statute. After a jury trial, Respondent was found to be an SVP. The primary issue on appeal was whether the State properly waited until the conclusion of Respondent's overall prison term to bring an SVP proceeding, when Respondent received consecutive sentences for a sexual abuse offense and a burglary/arson offense, with the sentence for burglary/arson to be served after the sentence for the sexual abuse offense. The Supreme Court reversed, holding (1) a person receiving consecutive sentences, one of which is for a sexually violent offense, is "presently confined" within the meaning of the civil commitment statute, and thus, an SVP petition is timely filed if it is filed before the respondent's anticipated release from prison, as long as the current term of imprisonment includes a sentence for a sexually violent offense; (2) sufficient evidence supported the jury's verdict that Respondent was an SVP; but (3) it was error to admit expert testimony on the State's procedure for selecting persons against whom SVP proceedings are filed. View "In re Detention of Stenzel" on Justia Law

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