Justia Iowa Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of possession of a controlled substance and introduction of a controlled substance into a detention facility. Defendant appealed, arguing that the district court entered an illegal sentence because the offenses of introduction and possession merged into a single offense by operation of Iowa’s merger statute. The court of appeals concluded that the offenses did not merge. The Supreme Court affirmed, holding that neither the merger statute nor double jeopardy principles formed a basis for reversing Defendant’s possession conviction and that the crimes may be simultaneously charged in one criminal prosecution. View "State v. Stewart" on Justia Law

Defendant was charged with operating while intoxicated, first offense. Defendant moved to suppress the evidence against her, arguing that the stop of her vehicle was made without probable cause or reasonable suspicion and that the implied consent statute was violated when the transporting deputy failed to administer a blood or urine test instead of insisting on a breath test after acquiring reasonable grounds to believe Defendant was impaired by a prescription drug. The district court overruled the motions to suppress and found Defendant guilty of the charge. The Supreme Court affirmed, holding (1) the investigatory stop of the vehicle did not violate the Fourth Amendment to the United States Constitution or Iowa Const. art. I, VIII; and (2) the legislature did not intend for the implied consent law to mandate a blood or urine test under the circumstances of this case but only intended to impose the implied consent penalty of license revocation for drivers suspected of driving under the influence of drugs other than alcohol who refuse to submit to a urine or blood test when requested by a law enforcement officer. View "State v. McIver" on Justia Law

Petitioner, a prison inmate, was ordered to pay restitution as part of his sentence and was required to pay fifteen percent of his income to his institutional account as restitution. When Petitioner began working for a private employer he petitioned the district court to modify the restitution plan to allow him to pay fifty percent of his earnings as restitution. The district court initially granted the request but then rescinded its prior order, concluding that the modified restitution order violated the state statutory scheme for the distribution of inmate earnings from private-sector employment. The Supreme Court reversed the district court decision to rescind the modified restitution order, holding that the amended restitution order was not contrary to the governing statutory scheme. View "State v. Morris" on Justia Law

After Plaintiff visited her mother at a residential home staff members reported that Plaintiff may have mistreated her mother. The officer who investigated the allegations arrested Plaintiff and charged her with simple misdemeanor assault. A jury acquitted Plaintiff of the charge. Plaintiff then filed this civil action against the arresting officer and the city that employed him, alleging negligence, false imprisonment, and malicious prosecution. The district court granted summary judgment in favor of the defendants. The court of appeals reversed as to the false imprisonment claim. The Supreme Court vacated the decision of the court of appeals, concluding that reasonable ground existed to arrest Plaintiff for the indictable offense of dependent adult abuse, and therefore, Plaintiff’s false imprisonment claim failed as a matter of law. View "Veatch v. City of Waverly" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree and other criminal offenses. The Supreme Court affirmed, holding (1) Defendant failed to preserve for appeal his argument that an instruction given to the jury that it may not consider a lesser offense unless it unanimously found Defendant not guilty of the greater offense was a misstatement of the law; (2) certain instructions concerning the various inferences and conclusions the jury was permitted to draw did not constitute reversible error; and (3) Defendant was not denied effective assistance of counsel for failing to argue that the contested instructions were improper. View "State v. Ambrose" on Justia Law

Defendant was in custody of a residential facility commonly referred to as a halfway house when he was charged with knowingly possessing marijuana on the grounds of a facility “under the management of the department of corrections” pursuant to Iowa Code 719.7(3)(c). After a jury trial, Defendant was convicted. Defendant appealed, arguing that his trial counsel provided ineffective assistance for specifically failing to assert that the evidence was insufficient to establish that the residential facility was an institution under the management of the Department of Corrections (Department). The Supreme Court reversed, holding that defense counsel was ineffective as a result of his failure to assert that there was insufficient evidence to show the residential facility was an institution under the management of the Department, and Defendant was prejudiced by the failure to his counsel to assert the claim. View "State v. Halverson" on Justia Law

Appellant was the established father of J.C., although he was not the child’s biological father. After the juvenile court adjudicated J.C. a child in need of assistance (CINA), the State filed a petition to terminate the parental rights of Mother and the child’s biological father. The juvenile court dismissed Appellant as a party, concluding that because he was neither the child’s biological father nor her adoptive father, Appellant was not a necessary party in the pending CINA proceedings and termination of parental rights proceedings. The Supreme Court affirmed, holding that the juvenile court correctly dismissed Appellant as a necessary party to the juvenile proceedings because, although Appellant was J.C.’s established father, he was not her parent under Iowa law. View "In re Interest of J.C." on Justia Law

Defendant pled guilty to two counts of incest and was sentenced to two consecutive terms of incarceration not to exceed five years. The Supreme Court remanded the case for resentencing on the grounds that the district court had relied upon an improper sentencing consideration. Upon resentencing, the district court again sentenced Defendant to two consecutive terms of incarceration not to exceed five years. In so doing, however, the court again referred to the impermissible sentencing factor. The Supreme Court vacated the sentence, holding that although the district court attempted to disclaim the reference to the impermissible sentencing factor, Defendant’s sentence must be vacated and remanded for resentencing to protect the integrity of the judicial system from the appearance of impropriety. View "State v. Lovell" on Justia Law

Kevin Fink filed a petition requesting alternate medical treatment for knee injuries allegedly sustained during the course of his employment with Denison Municipal Utilities (DMU). The workers’ compensation commissioner sent DMU a notice providing that DMU was required to file a first report of injury pursuant to Iowa Code 86.12. When DMU failed to file the first report of injury, the deputy commissioner assessed $1,000 against DMU. The district court reversed the $1,000 assessment, concluding that the deputy commissioner incorrectly interpreted section 86.12 as authorizing the commissioner to demand DMU to file a first report of injury, that the first report of injury was not required by section 86.11, and therefore, the record lacked substantial evidence to support the assessment against DMU. The Supreme Court reversed, holding (1) in this case, DMU was required to file a first report of injury; and (2) the deputy commissioner’s decision that DMU failed to make a sufficient showing of good cause to avoid the $1,000 assessment pursuant to section 86.12 was supported by substantial evidence. View "Denison Mun. Utils. v. Iowa Workers’ Comp. Comm’r" on Justia Law

This case involved three small school districts, Northeast Community School District, East Central Community School District, and Preston Community School District. In 2010, the school boards of Northeast and East Central entered into a whole grade sharing agreement. Thereafter, citizens from Preston and East Central voted to reorganize their districts and merge the districts together into a new school district called Easton Valley Community School District (Easton). The Easton school board subsequently sent a notification of cancellation of the agreement to the superintendent of Northeast, claiming that when East Central ceased to exist the agreement was null. Northeast filed a petition for declaratory action and mandamus and then amended its petition alleging repudiation of the agreement. The district court granted summary judgment for Easton, concluding (1) the agreement and the reorganization were valid but that the two were in direct conflict, and (2) the East Central school board did not have the ability to bind Easton as its successor corporation. The Supreme Court reversed, holding that the agreement could bind the reorganized school district. View "Northeast Cmty. Sch. Dist. v. Easton Valley Cmty. Sch. Dist." on Justia Law