Justia Iowa Supreme Court Opinion Summaries

Robert Harkins was convicted of third-degree sexual abuse. While he was incarcerated, Harkins refused to sign a treatment contract assuming responsibility for his offenses in order to participate in the correctional facility's sex offender treatment program (SOTP). The Department of Corrections then suspended Harkins's earned time pursuant to Iowa Code 903A.2(1)(a). Harkins filed an application for postconviction relief, arguing that the suspension of his earned-time credits for failure to participate in the SOTP violated his Fifth Amendment privilege against self-incrimination. The district court held that the State unconstitutionally compelled Harkins to give testimony but found the testimony would be potentially incriminating only until March 21, 2009, the last day on which the State could prosecute Harkins for perjury based upon his trial testimony. The Supreme Court granted certiorari, holding that (1) the statute does not violate the Fifth Amendment, and (2) the State may use earned-time credits as an incentive for convicted sex offenders to obtain sex offender treatment even when the treatment requires an acknowledgment of responsibility. The Court set aside the district court's order to the extent it reinstated Harkins's earned time through March 21, 2009 and remanded. View "State v. Iowa Dist. Court for Webster County" on Justia Law

Defendant Wendell Harrington was convicted of ongoing criminal conduct, first-degree theft, second-degree theft, and three counts of second-degree burglary, all enhanced as a habitual offender. The court of appeals reversed Harrington's conviction for ongoing criminal conduct, affirmed his remaining convictions, and preserved his ineffective-assistance claim for postconviction relief. The Surpeme Court granted review to consider whether the district court erred in admitting Harrington's prior theft and burglary convictions under Iowa R. Evid. 5.609. At issue was whether State v. Axiotis required the district court to balance the probative and prejudicial nature of Harrington's prior convictions before admitting them. The court of appeals concluded the district court had no duty to apply a balancing test as Harrington's prior convictions involved dishonesty and were therefore admissible under Iowa R. Evid. 5.609(a)(2). The Supreme Court agreed with the court of appeals and overruled Axiotis to the extent it suggests the balancing test articulated in Iowa R. Evid. 5.609(a)(1) applies to prior convictions that involve dishonesty or false statement under Iowa R. Evid. 5.609(a)(2). Accordingly, the Court affirmed the court of appeals decision as to the issue and affirmed the district court's admission of Harrington's prior convictions for impeachment purposes. View "State v. Harrington" on Justia Law

Defendant Justin Derby was charged with third-degree burglary, five counts of forgery, and escape from custody. On the morning of trial, Derby presented the district court with an oral motion in limine seeking to exclude the admission of Derby's prior convictions. The district court partially sustained Derby's motion and prevented the State from using Derby's prior convictions in its case in chief. The court overruled Derby's motion to the extent that it sought to "bullet-proof...the defendant from being impeached" with his prior felony convictions. Derby elected not to testify as a result of the ruling and was later convicted as charged. Derby appealed, asserting the district court erred in overruling his motion in limine. The court of appeals held Derby failed to preserve his claim because he elected not to testify. In support of its ruling, the court cited State v. Brown, which held that the defendant must testify in order to preserve error to challenge the use of his prior convictions as impeachment. On review, the Supreme Court declined to depart from stare decisis and, accordingly, affirmed the decision of the court of appeals and the district court's judgment. View "State v. Derby" on Justia Law

Defendant Anouhak Keutla pled guilty to manufacturing a controlled substance. The district court granted Keutla a deferred judgment and placed her on supervised probation for two years. After a report of probation violations was filed, the district court revoked defendant's deferred judgment, entered an adjudication of guilt, imposed a five-year prison sentence, suspended the sentence, ordered probation, and imposed a fine. The court further ordered defendant to serve six months in jail for contempt. Defendant appealed, arguing that the district court did not have the authority both to revoke her deferred judgment and to find her in contempt. The court of appeals concluded that the district court exceeded its authority by both revoking defendant's deferred judgment and punishing her for contempt and remanded the case. The Supreme Court granted review. The Court agreed with the court of appeals, concluding that the entire sentence should be reversed and remanded to the district court for resentencing. View "State v. Keutla " on Justia Law

Appellant Randy Meyers was convicted of lascivious conduct with a minor and sex abuse in the third degree stemming from Meyer's sexual relationship with his seventeen-year-old stepdaughter, Mindy. Meyers appealed, contending there was insufficient evidence to support the conviction. Meyers supported his appeal by focusing on the absence of testimony by Mindy that the sex acts with Meyers were by force or against her will. Myers also asserted that Mindy's consent could not be negated without expert evidence that she suffered from a recognized mental defect, and claimed that expert testimony presented by the state that Mindy was psychologically unable to consent was insufficient to vitiate consent under the statute. The court of appeals affirmed. The Supreme Court also affirmed, holding (1) the district court did not err in finding sufficient evidence that the sex acts occurred, and (2) that all the circumstances taken together support a finding that the sex acts engaged in between Meyers and Mindy were by force or against the will of Mindy. View "State v. Meyers" on Justia Law