Justia Iowa Supreme Court Opinion Summaries

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

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