Justia Iowa Supreme Court Opinion Summaries

Fifteen-year-old D.S. was accused of harassing a peer during an after-school confrontation. The State filed a petition alleging that D.S. had committed a delinquent act, specifically harassment in the third degree. After an adjudicatory hearing, the juvenile court concluded that the State had proven beyond a reasonable doubt that D.S. committed harassment in the third degree by means of intimidation. The court then adjudicated D.S. to have committed a delinquent act. The Supreme Court reversed, holding that there was insufficient evidence in the record to support the finding that D.S. committed harassment, and therefore, the juvenile court erred when it adjudicated D.S. delinquent under the harassment statute. Remanded for an order dismissing the petition. View "In re Interest of D.S." on Justia Law

When he was seventeen years old, Appellant committed the crime of first-degree robbery. Appellant was sentenced to a term of imprisonment not to exceed twenty-five years. Appellant was sentenced under a statute that required him to serve at least seventy percent of his sentence before he was eligible for parole. Appellant appealed, arguing that his sentence constituted cruel and unusual punishment. The Supreme Court vacated the sentence and remanded to the district court for resentencing, holding that, for the reasons express in State v. Lyle, filed on this same date, the mandatory sentence violated the prohibition against cruel and unusual punishment under the Iowa Constitution. View "State v. Taylor" on Justia Law

Appellant was a seventeen-year-old high school student when he took a small plastic bag containing marijuana from a fellow student outside the high school. After a jury trial, Appellant was convicted of robbery in the second degree. Appellant was prosecuted as an adult and was sentenced under a statute that required the imposition of a mandatory seven-year minimum sentence of imprisonment. Appellant appealed, arguing that the mandatory minimum was unconstitutional as applied to him. During the pendency of the appeal, the United States decided Miller v. Alabama. The court of appeals affirmed the sentence. The Supreme Court granted review to consider whether Appellant’s sentence was constitutional in light of the cases the Court handed down subsequent to Miller. The Supreme Court vacated the sentence and remanded for resentencing, holding that a statute mandating a sentence of incarceration in a prison for juvenile offenders with no opportunity for parole until a minimum period of time has been served is unconstitutional under the Iowa Constitution. View "State v. Lyle" on Justia Law

When she was sixteen years old A.J.M. was adjudicated delinquent by the juvenile court. The delinquency was based on the crime of sexual abuse in the second degree, an offense covered under the sex offender registry statute. The juvenile court opted to wait to decide whether A.J.M. should be required to register as a sex offender until she successfully completed sexual offender treatment. After a final review hearing, the juvenile court discharged A.J.M. and waived the requirement for her to register as a sex offender, concluding that A.J.M.’s failure to overcome her problems was the fault of the State. The Supreme Court affirmed the decision of the juvenile court to discharge A.J.M. but concluded that the record was not sufficient for the Court to properly review the juvenile court’s exercise of discretion to waive the requirement for A.J.M. to register as a sex offender. Remanded. View "In re Interest of A.J.M." on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to second-degree murder and first-degree robbery. Defendant was sixteen years old at the time he committed the offenses. The district court imposed a seventy-five-year aggregate sentence, of which Defendant was required to serve 52.5 years. Defendant's alleged actions took place before the Supreme Court's decision in Miller v. Alabama. On appeal, the Supreme Court affirmed Defendant's convictions but vacated his sentence, holding (1) Defendant's 52.5-year minimum prison term triggered the protections to be afforded under Miller - namely, an individualized sentencing hearing to determine the issue of parole eligibility; and (2) a district court must recognize and apply the core teachings of Roper v. Simmons, Graham v. Florida, and Miller in making sentencing decisions for long prison terms involving juveniles. Remanded.View "State v. Null" on Justia Law

Anthony Geltz was prosecuted as a juvenile and adjudicated delinquent for sexual abuse in the second degree for an offense he committed when he was fourteen years old. After Geltz turned eighteen, the State petitioned to have him declared a sexually violent predator (SVP) under Iowa Code 229A.2(11). The district court ordered Geltz confined as an SVP based on Geltz's previous offense. The Supreme Court reversed, holding (1) a juvenile adjudication does not constitute a predicate conviction required to commit an offender as an SVP pursuant to section 229A.2; and (2) therefore, the district court erred in committing Geltz as an SVP solely on the basis of his juvenile adjudication for the offense he committed at age fourteen. View "In re Detention of Geltz" on Justia Law

The State filed a petition alleging that fifteen-year-old J.W.R. committed delinquent acts of incest. J.W.R. entered an Alford plea to the incest allegation. A juvenile court officer recommended J.W.R. be adjudicated a delinquent and placed in a residential treatment facility for sex offenders. The juvenile court issued a consent decree withholding adjudication that J.W.R. had committed a delinquent act. Over the State's objection, the court placed J.W.R. in the legal custody of juvenile court services, with the Department of Human Services as payment agent, for purposes of placement in a residential facility. The court of appeals sustained the State's writ of certiorari. The Supreme Court affirmed, holding that the legislature did not grant this authority to juvenile courts in Iowa Code 232.46. View "State v. Dist. Court" on Justia Law

Two petitions were filed alleging that fifteen-year-old A.K. was a delinquent child for committing three counts of sexual abuse in the second degree and four counts of assault with intent to commit sexual abuse involving three different children. After a hearing, the juvenile court adjudicated A.K. a delinquent on all seven counts. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) the State proved beyond a reasonable doubt that A.K. committed three acts of sexual abuse in the second degree and three acts that would constitute assaults with intent to commit sexual abuse; but (2) the State did not meet its burden to prove A.K. committed one count of assault with intent to commit sexual abuse. View "In re A.K." on Justia Law

Defendant Jesse Pearson, a seventeen-year-old, robbed and beat an elderly man. After he was apprehended, Pearson refused to waive his Miranda rights. The next morning, however, he confessed to his social worker, Marie Mahler, without his attorney present. The district court denied Pearson's motion to suppress his confession, concluding that Mahler's interview was not a custodial interrogation implicating Miranda safeguards. A jury convicted Pearson of first-degree robbery, willful injury, and going armed with intent. The court of appeals reversed Pearson's conviction on the going armed charge and otherwise affirmed. At issue on appeal was whether Pearson's confession to Mahler was admissible. The Supreme Court affirmed, holding that Mahler's interview of Pearson was not a custodial interrogation for Miranda purposes and that his confession to her was voluntary and admissible. View "State v. Pearson" on Justia Law