Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction for possession of a controlled substance with intent to deliver, holding that Iowa R. Evid. 5.106 and the common law doctrine of completeness cannot trump Iowa R. Evid. 5.402.Specifically, the Supreme Court held (1) Defendant's right to a jury drawn from a fair cross section of the community under Iowa Const. art. I, 10 was not violated; (2) Defendant's claims of ineffective assistance of counsel were not properly before the Court and must be raised in the first instance on postconviction review; (3) the district court did not abuse its discretion in excluding certain documents proffered by Defendant as a discovery sanction; (4) the district court did not abuse its discretion in showing the jury an abbreviated version of a law enforcement officer's bodycam video; and (5) the evidence was sufficient to support the convictions. View "State v. Tucker" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of first-degree murder for killing his mother, holding that the district court did not err in admitting testimony from a probation officer and the mother's friend as statements of the mother's then-existing mental state under Iowa R. Evid. 5.803(3).Defendant's mother sent an email to Defendant's probation officer hours before Defendant killed her stating that she was "scared" and that she needed "help." During trial, Defendant's defense to the first-degree murder charge was that he acted impulsively out of rage. Over Defendant's objection, the trial court allowed the probation officer and the mother's friend to testify about the mother's fear of Defendant and her plan to stop financially supporting him. The Supreme Court affirmed, holding that the district court correctly admitted the two individuals to testify under Rule 5.803(3) about previous statements the mother made because they constituted relevant hearsay statements. View "State v. Thompson" on Justia Law

The Supreme Court affirmed in part and vacated in part the decision of the court of appeals in this postconviction proceeding declining to reverse Appellant's second-degree murder conviction but ordering the return of a previously-forfeited $50,000 cash bond, holding that postconviction relief was not a proper way to overturn the forfeiture order.To obtain pretrial release, Defendant had to post a $200,000 cash bond with $50,000 subject to the condition that it would be forfeited for purposes of restitution if Defendant were convicted. Defendant was subsequently found guilty of second-degree murder. The district court denied Defendant's later-filed application for postconviction relief. The court of appeals reversed as to the bond forfeiture order, ruling that Defendant's counsel provided ineffective assistance in failing to challenge the order. The Supreme Court affirmed except as to the bond forfeiture issue, holding that postconviction relief was not available to set aside the order directing that Defendant's cash bond be forfeited for victim restitution. View "Farnsworth v. State" on Justia Law

The Supreme Court reversed the order of the district court granting Defendant's motion to suppress his breath test because no interpreter was available and the advisory was read to him in English, holding that the police officer discharged his duty by making all reasonable efforts to obtain a Tigrinya interpreter before reading the advisory to Defendant in English.Defendant was from Eritrea, and his primary language was Tigrinya. Defendant, who was pulled over for traffic violations, agreed to do a preliminary breath test, which came back over the legal limit. He was then arrested and transported to a law enforcement center. The arresting officer contacted a commercial service known as Language Line to obtain an on-demand Tigrinya interpreter for the implied consent advisory, but not such interpreter was available. The officer then read Defendant the advisory. Defendant was subsequently charged with operating while intoxicated second offense. Defendant moved to suppress the evidence of his blood alcohol content from the DataMaster test on the grounds that he did not give consent. The district court sustained the motion. The Supreme Court reversed, holding that the officer complied with Iowa Code 321J.8 by making reasonable efforts and using reasonable methods to convey to Defendant the implied consent advisory. View "State v. Baraki" on Justia Law

The Supreme Court reversed the ruling of the district court approving a third five-year extension of a no-contact order that was originally entered after a serious incident of domestic violence in 2009, holding that Defendant carried his burden of showing that he no posed a threat to the safety of the victim and that substantial evidence did not support the extension.In 2021, the victim again applied for an extension of the no-contact order. The district court approved the five-year extension of the no-contact order to 2026. The court of appeals affirmed. The Supreme Court vacated the decision of the court of appeals, holding that, under the circumstances, where Defendant had completed therapy and ten years had elapsed since any violation of the no-contact order, there was not substantial evidence to support the extension of the no-contact order from 2021 to 2026. View "State v. Petro" on Justia Law

The Supreme Court dismissed this appeal brought by Defendant after pleading guilty to criminal gang participation, holding that Defendant's failure to file a motion in arrest of judgment to preserve his argument for appeal precluded relief in this direct appeal.Defendant pleaded guilty pursuant to a plea agreement. The court expressly advised Defendant of the requirement to file a motion in arrest of judgment in order to challenge his guilty plea on appeal. Defendant never filed a motion in arrest of judgment but did appeal, arguing that his conviction and guilty plea should be vacated because his plea lacked a factual basis. The Supreme Court dismissed the appeal, holding that this court lacked jurisdiction to hear Defendant's appeal. View "State v. Hanes" on Justia Law

The Supreme Court upheld Defendant's convictions and sentences for several drug offenses and other misdemeanors, holding that the trial court did not err in denying Defendant's motion to suppress or in denying Defendant's retained attorney's requests to enter limited appearances.On appeal, Defendant argued, among other things, that the district court erred in denying his motion to suppress because the arresting officer's recollection that Defendant had a driving status of "barred" as of several months before did not amount to a reasonable suspicion to justify a traffic stop. The Supreme Court affirmed, holding (1) while the officer's information about Defendant's driver's license status was several months old, it gave the officer reasonable suspicion to justify stopping Defendant's vehicle; and (2) if a constitutional right to have a retained attorney enter a limited appearance exists, it is subject to reasonable regulation by the district court, and the district court in this case did not abuse its discretion in denying Defendant's requested limited appearances. View "State v. Sallis" on Justia Law

In this criminal case, the Supreme Court dismissed Appellant's appeal for lack of jurisdiction, holding that Appellant's pro se notice of appeal filed while he was represented by counsel was a nullity under Iowa Code 822.3A.The version of section 822.3A that controlled this case prohibits the filing of pro se documents by represented parties and the court's consideration thereof. The legislature subsequently amended the statute to allow pro se notices of appeal by represented litigants. Appellant filed this action for postconviction relief, and the court denied relief on all claims. Appellant's lawyers did not file a timely notice of appeal, and at issue was whether Appellant's pro se notice of appeal was valid. The Supreme Court dismissed the appeal, holding that Defendant was not entitled to a delayed appeal because his pro se notice of appeal was a nullity and his counsel's notice of appeal was untimely. View "Jones v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for domestic abuse assault and other offenses but vacated his sentence, holding that the prosecutor did not satisfy her promise to make a specific sentencing recommendation, entitling Defendant to resentencing before a different judge.Defendant agreed to plead guilty if the prosecutor recommended suspended sentences on all counts. Defendant pleaded guilty. At sentencing, the prosecutor asked the court to adopt the parties' plea agreement but then qualified her request with certain comments during sentencing. The district court declined to impose suspended sentences and instead sentenced Defendant to an indeterminate combined term of imprisonment with a suspended sentence to follow. The Supreme Court vacated the sentence, holding that the prosecutor's comments at sentencing breached her obligation under the plea agreement to recommend suspended sentences. View "State v. Patten" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder arising from events in 1990 after his fourth trial, held almost thirty years after the crime, holding that Defendant was not entitled to relief on any of his claims of error.On appeal, Defendant argued that his conviction must be reversed due to juror misconduct, the improper admission of certain testimony, the erroneous exclusion of hearsay evidence, and a violation of due process. The Supreme Court disagreed and affirmed his conviction, holding that none of Defendant's allegations of error warranted reversal of his convictions. View "State v. Liggins" on Justia Law