Justia Iowa Supreme Court Opinion Summaries

After his vehicle collided with and killed a bicyclist, Defendant was convicted of homicide by vehicle, operating while intoxicated, and leaving the scene of an accident. The court of appeals affirmed his convictions but remanded for a sentencing correction. The Supreme Court granted further review to determine whether the State must prove in a prosecution under Iowa Code 707.6A(1) that Defendant's intoxication was a proximate cause of the victim's death and, if so, whether Defendant's trial counsel was ineffective for failing to raise the issue below. The Supreme Court affirmed the conviction, holding (1) the State must prove Defendant's intoxicated driving caused the victim's death to sustain a conviction for homicide by vehicle; and (2) the record was not adequate to determine whether Defendant's trial counsel was ineffective in failing to raise the causation issue, and therefore, the claim of ineffective assistance of counsel was preserved for postconviction proceedings. View "State v. Adams" on Justia Law

Dennis Richards was convicted of second-degree murder and second-degree arson for strangling his ex-wife to death and setting her house on fire. The court of appeals reversed and remanded for a new trial after concluding that Richards should have been allowed to call a physical therapist in his defense even though the witness had been disclosed a day late. The Supreme Court vacated the decision of the court of appeals and affirmed Richards' convictions, holding that even if the district court erred in excluding the therapist, any error was harmless in light of the overwhelming evidence of Richards' guilt. View "State v. Richards" on Justia Law

Lee Breuer was the apparent driver in a one-car accident. Breuer and the passenger were transported to the hospital, where a deputy sheriff asked Breuer to provide a breath test. Breuer refused. An officer then obtained a warrant authorizing withdrawal of a blood specimen from Breuer. Before the officer arrived at the hospital with the warrant, the deputy sheriff advised Bruer that his blood would be withdrawn by force if necessary, and Breuer acquiesced to a blood draw. The passenger in Breuer's vehicle subsequently died as a result of injuries sustained in the accident. The State charged Breuer with homicide by vehicle. Breuer filed a motion to suppress the results of the blood draw, which the district court denied. The court of appeals affirmed. The Supreme Court affirmed, holding that neither the state or federal constitution required the search warrant to be physically present before the search could begin. View "State v. Breuer" on Justia Law

The State charged Anthony Rodriguez with second-degree sexual abuse, willful injury, and domestic abuse assault. Ultimately, the district court dismissed the case due to a speedy trial rights violation. The court of appeals reversed. At issue on appeal was whether the State was entitled to an independent psychiatric evaluation of Rodriguez, a request the district court had denied. The Supreme Court affirmed the court of appeals and reversed the district court, holding (1) when a defendant puts at issue his mental capacity to knowingly, intelligently, or voluntarily waive his Miranda rights, the State is entitled to obtain an independent psychiatric evaluation of the defendant; (2) in order to protect the defendant's constitutional right against self-incrimination in these cases, the safeguards found in State v. Craney regarding the expert's testimony following the evaluation are applicable; and (3) the expert should not disclose to the State the same matters about which Craney prohibits an expert from testifying. Remanded. View "State v. Rodriguez" on Justia Law

The State charged Daniel Rainsong with theft in the first degree, dependent adult abuse and habitual offender. The State alleged Rainsong stole $15,000 each from his mother, a dependent adult who passed away, and her husband, Loren Radford. The State later noticed the deposition of Radford, but Rainsong refused to attend the deposition. The State proceeded to take the deposition of Radford without participation by Rainsong. When the State attempted to introduce the deposition at trial, the district court denied the request. The Supreme Court granted interlocutory review and affirmed, holding that the district court correctly decided not to allow the State to introduce at trial the statement contained in Radford's noticed deposition because (1) Iowa R. Crim. P. 2.13 did not authorize the taking of the deposition; and (2) therefore, the noticed deposition was nothing more than a sworn affidavit, and its admission would violate Rainsong's right to confrontation as guaranteed by the Confrontation Clause. View "State v. Rainsong " on Justia Law

Jose Aguilera was convicted of second-degree murder. In his second application for postconviction relief, Aguilera contended that he was denied due process when the prosecution failed to turn over an Iowa Division of Criminal Investigation file containing several witness statements prior to Aguilera's initial trial. The district court found the material was suppressed and that it was favorable but that it was not material to the issue of guilt and dismissed the application. The court of appeals affirmed. The Supreme Court vacated the court of appeals and reversed the district court, holding that because the suppressed, favorable statements that were not turned over by the State had a reasonable probability of impacting the outcome of the trial, a Brady violation occurred, and Aguilera's due process rights were violated. Remanded. View "Aguilera v. State" on Justia Law

Matthew Elliott was found guilty by a jury of willful injury causing serious injury and child endangerment resulting in death. The court of appeals affirmed. At issue on appeal was whether the district court erred in allowing hearsay testimony from a detective when it allowed the detective to testify about a certain interview. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the district court, holding that the disputed testimony was hearsay, and the error was not harmless because the improper admission of the hearsay evidence was prejudicial to Elliott's substantive rights. Remanded for a new trial. View "State v. Elliott" on Justia Law

Stevie Harrington was sentenced to forty years incarceration after he pled guilty to and was convicted of several drug-related offenses. His sentence included a mandatory sentence enhancement for being in the immediate possession of a firearm. The court of appeals remanded for resentencing, concluding that there was insufficient evidence to support the sentencing enhancement and the district court had relief on improper factors for imposing sentence. On resentencing, the district court sentenced Harrington to a total of thirty years. The sentences included two sentence enhancements that the district court did not apply in Harrington's original sentence. Harrington appealed, contending that, although his overall sentence decreased, because the district court applied the new sentencing enhancements, he was entitled to a presumption of judicial vindictiveness under North Carolina v. Pearce. The court of appeals affirmed. The Supreme Court affirmed, holding that because Harrington received a shorter overall sentence on resentencing for his convictions, the presumption of judicial vindictiveness did not apply. View "State v. Harrington" on Justia Law

Randall Pals' vehicle was searched during a traffic stop to investigate an ongoing minor infraction of a municipal ordinance. The police officer discovered marijuana. Pals moved to suppress the evidence, challenging the legality of the traffic stop and search. The district court denied the motion, and Pals was convicted of possession of a controlled substance. The court of appeals affirmed. The Supreme Court vacated the court of appeals and reversed the district court, holding that the district court erred by refusing to grant Pals' suppression motion where (1) the police officer had probable cause to believe that Pals was committing an ongoing civil offense, and therefore, the initial traffic stop was legal; but (2) pursuant to an application of the Iowa version of the U.S. Supreme Court's Schneckloth v. Bustamonte totality of the circumstances test, Pals' consent to search his vehicle was not voluntarily under the Iowa Constitution. Remanded. View "State v. Pals" on Justia Law

Homeowners filed suit against Contractor, asserting claims for defamation and illegal collection practices. After a trial, the jury rejected Homeowners' claims and awarded Contractor damages for its breach of contract counterclaim. Homeowners filed a motion for a new trial, arguing that Contractor committed misconduct by giving false testimony and fabricating an exhibit in order to support that testimony. Homeowners recognized the flaws in the exhibit before the case was submitted to the jury, but instead of alerting the court, decided to argue those flaws to the jury during the rebuttal stage of closing argument. The district court granted the motion. The court of appeals reversed the district court's order granting a new trial. The Supreme Court affirmed, holding that the district court abused its discretion in granting a new trial where (1) the district court did not lack authority to grant a new trial simply because the objection to the exhibit could have been raised earlier and was not; but (2) considering all the circumstances, including the absence of real misconduct or prejudice and Homeowners' decision to wait until rebuttal argument to bring forward its concerns, the district court abused its discretion in granting a new trial. View "Loehr v. Mettille" on Justia Law