Justia Iowa Supreme Court Opinion Summaries

Defendant was charged with first-degree kidnapping. The trial information included a proposed enhancement based on Defendant’s prior Ohio conviction of a sexually predatory offense. A jury ultimately found Defendant guilty of the lesser included offense of third-degree kidnapping. Thereafter, the district court ruled that the third-degree kidnapping conviction did not qualify as a sexually predatory offense within the meaning of Iowa Code 901A.1(1) and thus denied the enhancement. The court of appeals vacated Defendant’s sentence and remanded for resentencing, holding that Defendant’s third-degree kidnapping conviction was a sexually predatory offense because during trial the jury had found that Defendant had committed kidnapping with the specific intent to subject the victim to sexual abuse. The Supreme Court affirmed, holding that a jury finding that the defendant committed kidnapping with intent to subject the victim to sexual abuse can serve as the basis for an enhanced sentence. View "State v. Walker" on Justia Law

Plaintiff, a limited liability company, contracted with Defendant, a utility bill review consultant. After Defendant reviewed four utility bills and informed Plaintiff it was entitled to a substantial refund for sales tax overpayments, Plaintiff terminated the contract. Plaintiff filed a petition for declaratory judgment requesting a determination that it had no remaining contractual obligation to Defendant. Defendant counterclaimed for breach of contract. The district court granted summary judgment for Plaintiff, concluding that Plaintiff’s liability under the contract was limited to services Defendant provided prior to termination, and no payment was owed to Defendant until Plaintiff actually received a refund. The Supreme Court reversed, holding that Defendant had a viable claim for breach of contract. Remanded. View "Shelby County Cookers, LLC v. Utility Consultants Int’l, Inc." on Justia Law

Tenant leased certain property from Landlord. Landlord filed a petition for a declaratory judgment seeking a ruling that it could have reasonable access to the property to show it to prospective buyers. The district court found the lease to be unambiguous and granted summary judgment to Tenant, concluding that Tenant could exclude Landlord from showing the property until ninety days remained in the term of the lease. The Supreme Court reversed the judgment of the district court, holding that lease provisions that gave Landlord the right to sell the property at any time during the lease term encompassed the right to access the property temporarily at reasonable times to show the property to prospective buyers. View "Alta Vista Props., LLC vs. Mauer Vision Ctr., PC" on Justia Law

Defendant was charged with four counts of unintentionally causing serious injury by intoxicated use of a motor vehicle. Before trial, the State moved to allow three out-of-state victims of the car accident and three lab analysts employed by the State to testify remotely via two-way videoconferencing technology rather than physically appearing in court. After a hearing, the district court granted the State’s motion for distance testimony. Defendant appealed, arguing that the trial court’s decision to permit the State’s witnesses to testify remotely violated his Sixth Amendment right to be confronted with the witnesses against him. The Supreme Court reversed, holding (1) before permitting a witness to testify via two-way videoconference, a court must make a case-specific determination that the denial of the defendant’s confrontation right is necessary to further an important public interest; and (2) applying this standard to the instant case, the district court erred in allowing the videoconference testimony. View "State v. Rogerson" on Justia Law

The Workers’ Compensation Commission found Employee to be totally and permanently disabled under the odd-lot doctrine and denied Employer and its Insurer (collectively, Employer) certain credits for disability payments previously received by Employee from other sources. The district court affirmed the Commission’s finding that Employee was totally and permanently disabled but reversed on the credit issue. The court of appeals reversed, holding (1) substantial evidence did not support the Commission’s award of permanent total benefits, and (2) the Commission was correct in its decision concerning the credits. On further review, the Supreme Court (1) affirmed the district court’s finding that substantial evidence supported the Commission’s findings that Employee was totally and permanently disabled under the odd-lot doctrine; and (2) reversed the district court’s judgment regarding the issues concerning the credit due Employer. View "Gits Mfg. Co. v. Frank" on Justia Law

Based on a complaint from a district court judge alleging that District Associate Judge Emily Dean arrived at a courthouse in an intoxicated state and could not perform her judicial duties, the Iowa Commission on Judicial Qualifications filed a notice of charges against Judge Dean. After a hearing, the Commission concluded that Judge Dean had violated the rules of judicial conduct and recommended that the judge be suspended for three months without pay. The Supreme Court granted the application of the Commission and held that Judge Dean should be suspended from her judicial without pay but limited the suspension to thirty days. View "In re Dean" on Justia Law

Defendant was a pastor who had sexual relations with four women in his congregation. Defendant was convicted of four counts of sexual exploitation by a counselor or therapist and one count of a pattern or practice to engage in sexual exploitation by a counselor or therapist. The court of appeals reversed and remanded for a new trial, holding that the district court failed properly to instruct the jury on the sexual exploitation statute and that the district court abused its discretion in excluding expert testimony concerning differences between pastoral care and pastoral counseling. The Supreme Court vacated the decision of the court of appeals, concluding that the district court did not err in instructing the jury and excluding the proffered expert testimony. The Court then held (1) the district court erred in denying Defendant’s discovery request for one of the victim’s counseling records and erred in the amount of restitution awarded; and (2) the district courts judgment was correct in all other respects. Remanded. View "State v. Edouard" on Justia Law

The State charged Defendant, a probationer, with burglary and theft after police officers conducted a warrantless search of Defendant’s home. Defendant filed a motion to suppress contending that the search warrant was invalid because it inaccurately described the house to be searched and because an alteration of the warrant based upon a verbal conversation with the issuing judge violated the statutory requirement that search warrant applications be in writing. The district court overruled the motion to suppress, concluding that the search warrant was inadequate but that the warrant was valid because the search was within the contemplation of the probation agreement. The court of appeals affirmed, concluding that the search of the probationer based upon reasonable suspicion of criminal activity and based upon the limited scope of the search was valid under the search and seizure provision of Iowa Const. art I, 8. The Supreme Court reversed, holding that, in accordance with State v. Cullison, the search of Defendant’s home by general law enforcement authorities was unlawful under the Iowa Constitution because the search was based on an invalid warrant. View "State v. Short" 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