Justia Iowa Supreme Court Opinion Summaries

After a jury trial, David DeSimone was convicted of sexual abuse in the third degree. DeSimone's conviction was affirmed on appeal. DeSimone subsequently filed an application for postconviction relief, asserting that the State committed a Brady violation when it failed to turn over a witness's timecard showing that the witness could not possibly have seen the events to which she testified. The district court denied relief, and the court of appeals affirmed. The Supreme Court vacated the court of appeals and reversed the judgment of the district court, holding that the State's failure to disclose the timecard was a Brady violation because (1) the State suppressed the evidence, (2) DeSimone met his burden of proof that the evidence was favorable to his guilt or innocence, and (3) the evidence was material to the issue of guilt. Remanded. View "DeSimone v. State " on Justia Law

While investigating a death by shooting, state police spoke with Justin Marshall, whom the police believed to have information relating to the crime. Because of Marshall's apparent plan to leave the area, the State filed a material witness complaint against him and obtained an arrest warrant for him. After Marshall's arrest, another man was charged with murder in connection to the death. Marshall filed a motion to dismiss the material witness complaint, alleging his continued detention violated due process, equal protection, and cruel and unusual punishment. The district court ordered Marshall's release, concluding that the authority of the State to detain a material witness is extinguished when a trial date is set for the underlying crime and the material witness is served with a subpoena. At issue on review was the proper interpretation of Iowa Code 804.11, which provides for the arrest of a material witness when the witness might be unavailable for service of a subpoena. The Supreme Court affirmed the order of the district court, concluding that section 804.11 authorizes the arrest and detention of material witnesses to felonies only for the purpose of ensuring that a valid subpoena may be served upon the witness. View "Marshall v. State" on Justia Law

Daniel Lado pleaded guilty to dependent adult abuse. Later, Lado filed a pro se petition for postconviction relief that contained a request for appointment of counsel. The district court appointed Lado counsel. After no action was taken on Lado's application, the district court dismissed Lado's petition pursuant to Iowa R. Civ. P. 1.944. Lado filed a pro se notice of appeal, alleging dismissal under rule 1.944 resulted from ineffective assistance of counsel. The court of appeals (1) affirmed the dismissal, and (2) found Lado's counsel was ineffective but preserved his claim for postconviction relief because it found the record was insufficient to determine whether the district court would have granted Lado's postconviction relief application if his counsel had acted competently. The Supreme Court vacated the court of appeals and reversed the district court, holding (1) Lado's counsel committed structural error in failing to seek a continuance to prevent dismissal under rule 1.944 or to make application to the court for the reinstatement of his case after it was dismissed by operation of the rule; and (2) the error constructively denied Lado the right to counsel. Remanded to district court for adjudication on the merits. View "Lado v. State" on Justia Law

Alan Watts was convicted of possession with the intent to deliver, drug stamp tax violations, and possession of drug paraphernalia. Watts appealed, contending that the district court erred in denying his motion to suppress evidence obtained from searching his apartment. The Supreme Court affirmed Watts' convictions and sentence, holding that although the initial warrantless sweep of Watts' apartment was unlawful due to a lack of exigent circumstances, the district court did not err in denying Watts' motion to suppress because (1) the officers later procured a warrant to conduct a full search of the apartment, (2) the evidence in question was located during that search, and (3) the State demonstrated that the warrant would have been sought and granted even without the information from the earlier improper sweep. View "State v. Watts" on Justia Law

After Toby Welch was arrested for operating a vehicle while intoxicated, police officers requested a breath specimen to be used for chemical testing. Welch refused the request. After talking to his attorney, however, Welch told officers that he wanted to consent to the breath test. The officers declined the request, commenting that because Welch had already refused, it was too late to submit to the test. Based on his refusal to submit to chemical testing, the Iowa DOT revoked Welch's driver's license for one year. The DOT's administrative law judge sustained the revocation, and the reviewing officer affirmed. The district court affirmed the revocation. At issue on appeal was whether the "one refusal is determinative" rule set forth in Krueger v. Fulton should be abrogated in favor of a more flexible standard permitting a motorist's subsequent consent to cure a prior initial refusal to submit to chemical testing. The Supreme Court rejected Welch's appeal and upheld the revocation of his license, concluding that a rule treating the motorist's initial refusal as determinative was supported by Court precedents, was consistent with the general assembly's intent, and was easier for police and courts to administer. View "Welch v. Iowa Dep't of Transp." on Justia Law

While an inmate at a correctional facility, Kevin Walker was assaulted by another inmate and was seriously injured. Walker brought a tort claim against the State, a correctional officer, and two activity specialists, claiming they negligently failed to ensure his safety. The State sought summary judgment based upon the discretionary function and intentional tort exceptions to the Iowa Tort Claims Act (ITCA). The district court denied the motion, concluding a genuine issue of material fact existed as to whether the prison staff involved had knowledge of a history of prior trouble involving Walker. The Supreme Court granted the State's application for interlocutory appeal and affirmed the decision of the district court, holding that the district court did not err in denying the State's motion for summary judgment where (1) because the decisions made by the correctional staff in the supervision of the inmates, in this instance, did not involve the evaluation of broad public policy factors, the State was not entitled to the discretionary function exception; and (2) as long as a claimant can show the State is negligent in performing a duty to protect a person from an assault, the intentional tort exception to the ITCA is not applicable. View "Walker v. State" on Justia Law

Michael Anderson, a convicted sex offender, was placed on electric monitoring and home supervision while on probation. After the district court revoked Anderson's probation, the court reinstated the prison terms. Anderson did not receive sentencing credit for the time he lived at home. Anderson filed an application for postconviction relief seeking such credit. The district court denied Anderson' application, concluding the statutory scheme only provided sentencing credit for time spent in a jail-like facility. The court of appeals affirmed. On review, the Supreme Court vacated the decision of the court of appeals and reversed the district court order denying credit, holding that the plain language of Iowa Code 907.3(3) requires credit for the time Anderson was committed to electronic monitoring and home supervision during his probation. Remanded. View "Anderson v. State" on Justia Law

After the district court dismissed criminal charges against J.W., J.W. filed a motion to expunge any information pertaining to the dismissed charges pursuant to Iowa Code 692.17, specifically requesting that the information be removed from the Iowa Court Information System (ICIS), including the website Iowa Courts Online, and the computer data storage systems for the county sheriff, city police, state division of criminal investigation, and the FBI. The district court granted J.W.'s request. The attorney general petitioned for a writ of certiorari, which the Supreme Court granted. The Court sustained the writ, holding that (1) Section 692.17(1) does not require criminal cases that ended in dismissal or acquittal to be removed from ICIS or the website Iowa Court Online; and (2) making dismissed criminal case information available to the public, while withholding public access to deferred judgments, does not violate the Equal Protection Clause of the Iowa Constitution. View "Judicial Branch v. Dist. Court for Linn County" on Justia Law

After the district court dismissed a criminal charge against C.R., C.R. filed an application to expunge the dismissed charge pursuant to Iowa Code 692.17. The district court granted the request and held (1) judicial review from the administrative process afforded by Section 692.5 was not the exclusive remedy for a person seeking deletion of records from the Department of Public Safety, Division of Criminal Investigation (DPS) computer system, and (2) electronic docket entries on the Iowa Courts Information System (ICIS) and the website Iowa Courts Online relating to C.R.'s dismissed case were covered by the statute. The Supreme Court granted the attorney general's petition for writ of certiorari. The Court sustained the writ and vacated the district court's order, finding that the district court acted without jurisdiction in reviving a dismissed criminal case for the purpose of ordering a nonparty such as DPS to delete records. The Court concluded that Section 692.5 provides the exclusive administrative remedy for a person such as C.R. seeking removal of criminal history data from DPS files, and it is not appropriate to bring a direct civil action or to use a prior criminal case for that purpose. View "Dep't of Pub. Safety v. Dist. Court for Polk County" on Justia Law

One of the subsidiaries of Annett Holdings was a trucking company that employed Michael Vititoe as a driver. Vititoe was given a Comdata credit card to purchase fuel. Comdata had a written contract with Kum & Go that enabled the Kum & Go truck stop from which Vititoe purchased fuel to handle Comdata transactions. For four years, Vititoe used the Comdata credit card at the Kum & Go truck stop to obtain cash while reporting purchases of fuel. After the fraud was discovered, Vititoe was arrested and convicted of theft. Annett Holdings sued Kum & Go for negligence and breach of contract as an alleged third-party beneficiary of the contract between Kum & Go and Comdata. The district court granted summary judgment to Kum & Go, (1) finding the negligence claim was barred by the economic loss rule; and (2) rejecting the breach of contract claim on the ground that Annett was not an intended beneficiary of the contract. The Supreme Court affirmed, holding the district court did not err in granting summary judgment to Kum & Go on both claims. View "Annett Holdings, Inc. v. Kum & Go, L.C." on Justia Law