Justia Iowa Supreme Court Opinion Summaries

The Supreme Court vacated Defendant's convictions for sexual abuse in the second degree, holding that the district court erred by giving the jury asymmetrical, particularized noncorroboration instructions focusing on the victims' testimony, requiring a new trial.After a jury trial, Defendant was convicted of two counts of sexual abuse and sentenced to a total of thirty-five years. The court of appeals reversed, holding that while the evidence was sufficient to support the convictions the noncorroboration instructions were improper, requiring a new trial. The Supreme Court granted the State's application for further review and affirmed the court of appeals' remand for a new trial, holding (1) the State presented sufficient evidence to support the convictions; but (2) the noncorroboration instruction given to the jury in this case improperly gained the jury's consideration of the victims' testimony, and the error was prejudicial. View "State v. Ross" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for voluntary manslaughter, holding that the circuit court committed no instructional error or constitutional violation in the underlying proceedings.On appeal, Defendant argued, among other things, that the district court erred in instructing the jury on a "stand your ground" defense, which confused the jury about his actual justification defense. The Supreme Court affirmed, holding (1) Defendant was not entitled to relief on his argument that the stand-your-ground defense wasn't in play, and thus that the stand-your-ground instruction was erroneously given; and (2) including the term "illegal activity" in the instructions did not violate Defendant's right to due process. View "State v. Ellison" on Justia Law

The Supreme Court reversed the district court's ruling granting Defendant's motion to suppress statements she made during a custodial interview, holding that some deception by law enforcement in this case did not exceed what the legal system tolerates.Defendant's husband died of strangulation after being zip-tied in a chair in his residence. Defendant claimed that her husband had tied himself up. During an interview at the police station, police officers told Defendant falsely that doctors were still working to save her husband's life. An hour and half into the interview the officers corrected their deception. The officers also made various reassurances and suggestions to the woman. The trial court granted Defendant's motion to suppress. The Supreme Court reversed, holding (1) the officers' lie about whether her husband had been pronounced dead did not affect Defendant's essentially knowing and voluntary waiver of her Miranda rights; and (2) the officers' expressions of sympathy did not amount either to express or implied promises of leniency that would create a fair risk of a false confession. View "State v. Park" on Justia Law

In this appeal of a restitution order that was cross-filed in a felony case and a dismissed misdemeanor case the Supreme Court declined to grant review in the dismissed misdemeanor case, granted felony review in the felony case, and held that the restitution order in this case was not illegal.In this case arising from a vehicle collision, the State charged Defendant with a simple misdemeanor. The State also charged Defendant with a felony. Defendant plead guilty to serious injury by vehicle. The court sentenced Defendant to prison but suspended his sentenced and ordered probation. The court further ordered Defendant to pay the victim restitution. Although the court dismissed a misdemeanor case, the court ordered Defendant to pay victim restitution with that case. The court ordered Defendant to pay restitution in the amount of $34,513 and cross-filed the order in both the felony case and dismissed misdemeanor case. The Supreme Court held (1) in the misdemeanor case, Defendant had no right of appeal; and (2) in the felony case, the restitution award was supported by substantial evidence. View "State v. Patterson" on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that Defendant was not entitled to a new trial after the Supreme Court remanded the case with instructions for the district court to hold a hearing under Iowa R. Evid. 5.412, holding that the district court did not abuse its discretion.After a jury trial, Defendant was found guilty of assault with intent to commit sexual abuse toward K.S. and other crimes and sentenced to a term of imprisonment. On appeal, Defendant argued that the district court erred by failing to conduct a rule 5.412 hearing before deciding whether to exclude evidence that K.S. had previously made false allegations of sexual abuse. The Supreme Court reversed and conditionally remanded with directions for the district court to conduct an in camera rule 5.412 hearing. On remand, the district court held a hearing and declined to grant a new trial. The Supreme Court affirmed, holding that the district court did not abuse its discretion by concluding that Defendant had failed to prove that K.S. had made prior false claims of sexual abuse. View "State v. Trane" on Justia Law

The Supreme Court held that In re T.H., 913 N.W.2d 578 (Iowa 2018) applies only to juvenile sex offenders whose cases are prosecuted and resolved in juvenile court and declined Defendant's invitation to apply its holding to a juvenile offender who is prosecuted and convicted in district court.At age seventeen, Defendant confessed to sexually abusing three children. Defendant was convicted on four class B felony counts and, at age twenty, was sentenced to terms of imprisonment. The court suspended the prison sentences, placed Defendant on probation, and imposed the special sentence of lifetime parole applicable to class B felonies under Iowa Code section 903B.1. The court further required Defendant to register as a sex offender under Iowa Code 692A.103(1). Defendant appealed, arguing that it is unconstitutional under In re T.H. to require a juvenile to register as a sex offender. The Supreme Court reversed in part, holding (1) In re T.H. does not apply to juvenile sex offenders prosecuted in district court; (2) registration under chapter 692A is not part of the "sentence" that can be suspended under section 901.5(13); and (3) Iowa Code 901.5(13) allowsed the district court to suspend Defendant's Iowa Code 903B.1 special sentence in whole or in part. View "State v. Hess" on Justia Law

The Supreme Court affirmed Defendant's conviction of robbery in the first degree and felony murder with robbery in the first degree serving as the predicate felony, holding that the district court did not err or abuse its discretion.During the course of a robbery, Defendant beat Jeremy McDowell, who was high on methamphetamine, with a bat. McDowell died of a cardiac arrhythmia either during or immediately after the beating. On appeal from his convictions, Defendant argued that did not intend to cause McDowell's death, and therefore, the evidence was insufficient to convict him. The Supreme Court affirmed, holding (1) there was substantial evidence supporting the district court's verdict; (2) the evidence was sufficient establishing Defendant caused McDowell's death; and (3) the district court did not manifestly abuse its discretion in denying Defendant's motion for a new trial. View "State v. Stendrup" on Justia Law

The Supreme Court reversed Defendant's conviction for second-degree sexual abuse, holding that Defendant's constitutional right to a public trial was violated when the trial court closed his trial during the COVID-19 pandemic.Defendant was set to stand trial on felony charges in March 2020, but his trial was repeatedly rescheduled due to COVID. The district court ultimately concluded that allowing anyone in to attend Defendant's trial, including his family and friends, violated COVID protocols previously set by the Supreme Court. The district court also rejected the option of live-streaming the trial. The jury subsequently convicted Defendant of second-degree sexual abuse. The Supreme Court reversed, holding that the district court's exclusion of all members of the public from Defendant's trial violated Defendant's constitutional rights, requiring a new trial. View "State v. Brimmer" on Justia Law

In this interlocutory appeal, the Supreme Court reversed the decision of the district court ordering certain records produced to Plaintiff in discovery before trial, holding that the district court erred by relying on civil discovery rules to compel production of the records at issue.Plaintiff's daughter was killed in a motorcycle accident. Plaintiff brought a tort action against the driver of the motorcycle and settled without subpoenaing the county sheriff's investigative reports. After a criminal investigation and prosecution of the driver was complete Plaintiff brought this enforcement action under Iowa Code chapter 22 against the county sheriff's department seeking to obtain its complete investigation file. The district court ordered the records produced to Plaintiff in discovery before trial without ruling on their confidentiality. The Supreme Court reversed, holding that the district court erred in compelling disclosure of the sheriff's investigation materials to Plaintiff's counsel. View "Vaccaro v. Polk County" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court convicting Defendant of first-degree burglary, first-degree robbery, assault causing serious injury while participating in a public offense and willful injury causing serious injury, holding that remand was required for entry of an order merging Defendant's conviction for willful injury causing serious injury with first-degree robbery.The court of appeals primarily affirmed the judgment of the district court but agreed with Defendant that his conviction for willful injury causing serious injury merged with his conviction for first-degree robbery. The Supreme Court affirmed, holding (1) the district court's rulings were all correct except as to Defendant's merger claim; and (2) a defendant's prior conviction for vehicular homicide by reckless driving under Iowa Code 707.6A(2) is a "crime of similar gravity" to a forcible felony for purposes of applying the sentencing enhancement set forth in Iowa Code 902.11. View "State v. Bloom" on Justia Law