Justia Iowa Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of sexual exploitation by a school employee in violation of Iowa Code 709.15(3)(a) and (5)(a). At the time of the offense, Defendant was a worker at a local pipe manufacturer who, while not a licensed teacher, coached high school basketball under a coaching authorization. Defendant appealed, arguing that he was not a school employee as the term is used under section 709.15(3)(a), and therefore, he was not subject to criminal prosecution under this statute. The Supreme Court reversed and remanded with instructions to dismiss the case, holding that a coach who holds a teaching or other professional license is subject to the statute, but a mere holder of a coaching authorization without a professional license within the meaning of Iowa Code 272.1(7) does not fall under the sexual exploitation statute. View "State v. Nicoletto" on Justia Law

Appellant was a registered sex offender who was not permitted to loiter within 300 feet of a public library. In 2012, Appellant was arrested for sitting on a park bench located across the street from the main entrance of a public library. Appellant was facing the library and had been sitting on the bench, which was seventy-two feet from the front door of the library, for approximately forty-five minutes. The district court subsequently convicted Defendant of loitering within 300 feet of a public library in violation of Iowa Stat. 692A.113(1)(g). On appeal, Appellant contended that there was insufficient evidence was “loitering” within the meaning of the statute. The Supreme Court reversed the conviction and remanded for new findings, conclusions, and judgment because it was unclear whether the district court applied the appropriate legal standard in this case. View "State v. Showens" on Justia Law

After a jury trial in 2007, Tammy Smith was convicted of child endangerment resulting in serious injury against her four-year-old son. The court of appeals affirmed on appeal. In 2009, Smith applied for postconviction relief based on evidence that her son communicated that his injury occurred when he placed his arm in the washing machine. The court of appeals held that this was newly discovered evidence and remanded for a new trial. On remand, the district court vacated Smith’s conviction and dismissed the case against Smith. In 2011, Smith filed a petition for wrongful imprisonment. The district court found that Smith did not establish by clear and convincing evidence neither she nor anyone else committed the crime of child endangerment. The court of appeals affirmed. The Supreme Court affirmed, holding that substantial evidence supported the district court’s finding that Smith did not establish her wrongful imprisonment action by clear and convincing evidence. View "Smith v. State" on Justia Law

After taking self-care leave under the Family and Medical Leave Act (FMLA), Plaintiff was terminated from her employment with the State. A jury found the State terminated Plaintiff in violation of her rights under the FMLA. The district court awarded Plaintiff money damages and ordered the State to reinstate Plaintiff to her former position. The State appealed and successfully requested a stay of Plaintiff’s reinstatement pending the outcome of the appeal. The Supreme Court subsequently held that sovereign immunity precluded Plaintiff’s judgment for money damages against the State. On remand, the district court once again ordered Plaintiff reinstated and awarded lost wages and benefits from the date of the original reinstatement order, concluding that the State had waived its sovereign immunity by seeking a stay of the reinstatement order and promising to pay Plaintiff’s interim wages and benefits if the Court affirmed the original order. The Supreme Court affirmed, holding (1) Plaintiff’s pleadings were sufficient to preserve her right to Ex parte Young remedies, and the parties litigated the reinstatement remedy by consent; and (2) the Eleventh Amendment to the U.S. Constitution does not bar an award of wages and benefits for the period during which a reinstatement order was stayed. View "Lee v. State" on Justia Law

Elmer Gaede, who owned a 120-acre farm together with his wife, died testate on February 2005. Elmer’s daughter, Diean, was named executor under the will. Diean designated Ivan Ackerman to render legal services in the administration of the estate. During the pendency of the probate proceedings, Elmer’s son James and his wife, who were leasing the farm, exercised the option under the lease agreement to purchase the farm. Diean later filed this legal malpractice lawsuit against Ackerman, alleging that Ackerman failed to adequately protect her personal interests relating to the enforceability of the option. The district court granted summary judgment for Ackerman, determining that Ackerman did not have a duty to protect Diean’s personal interests. The court of appeals reversed, holding that a factual dispute existed over the question of whether Diean had a reasonable expectation that Ackerman was representing her personal interests. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding that insufficient facts supported Diean’s claim that Ackerman reasonably understood that Diean expected him to protect her personal interests in challenging the option. View "Sabin v. Ackerman" on Justia Law

Pursuant to a plea agreement, Defendant pled guilty to three counts of intimidation with a dangerous weapon with intent and one count of a felon in possession of a firearm. Defendant appealed, arguing, inter alia, that his counsel was ineffective for allowing him to plead guilty to three counts of intimidation with a dangerous weapon with intent, as there was no factual basis to support three separate and distinct acts. The Supreme Court reversed the judgment of the district court on the three separate charges of intimidation with a dangerous weapon, holding that trial counsel was ineffective for allowing Defendant to plead guilty to the three separate charges when no factual basis existed to establish Defendant's shooting of his gun in the air was three separate and distinct acts. Remanded. View "State v. Gines" on Justia Law

Defendant approached two separate tellers at a bank and demanded that each teller give him money from their cash drawers. After a jury trial, Defendant was convicted of two counts of robbery in the second degree. On appeal, Defendant contended that only one robbery occurred and that substantial evidence did not support the two robbery convictions. The court of appeals affirmed. The Supreme Court also affirmed, holding (1) the district court did not impose an illegal sentence by failing to combine the two robbery convictions into a single count, as the record contained substantial evidence that Defendant had the intent to commit two separate and distinct thefts; and (2) substantial evidence supported the two robbery convictions. View "State v. Copenhaver" on Justia Law

After a jury trial, Defendant was convicted of voluntary manslaughter and five counts of intimidation with a dangerous weapon with intent. The Supreme Court vacated Defendant’s convictions on three counts of intimidation with a dangerous weapon with intent and affirmed his remaining convictions, holding (1) trial counsel was ineffective for failing to move for a judgment of acquittal after the verdict on the intimidation counts because the evidence did not support the verdicts that Defendant committed five separate and distinct acts of intimidation with a dangerous weapon with intent; (2) however, substantial evidence supported two separate and distinct crimes of intimidation with a dangerous weapon with intent; (3) the record was inadequate to decide Defendant’s separate allegation of ineffective assistance of counsel; and (4) the district court did not abuse its discretion in failing to admit certain photographs into evidence. Remanded. View "State v. Ross" on Justia Law

Plaintiff was terminated from his employment as dean of students and vice president of student services at the University of Iowa by the University's president, Sally Mason, after a report from the Stolar Partnership (Stolar), a law firm retained by the Board of Regents (Regents) to investigate the University's response to a sexual assault of a student athlete by other student athletes, came out highly critical of Plaintiff. Plaintiff sued the University, Mason, the Regents, and Stolar for wrongful termination and related causes of action. The district court granted summary judgment for Defendants on all claims. The Supreme Court affirmed, holding that the district court did not err (1) in denying Plaintiff's motion to compel discovery of written communications between Stolar and the Regents based on its finding that the attorney-client privilege protected the communications from disclosure; and (2) in granting summary judgment to Defendants on Plaintiff's various claims.View "Jones v. Univ. of Iowa" on Justia Law

After a jury trial, Defendant was convicted of six counts of child endangerment and sentenced to fifty years in prison. The victim was Defendant's seven-week-old son. The baby suffered fifteen rib fractures, a broken arm, and a permanent brain injury over a three-week period. The victim's mother (Mother) pled guilty to child endangerment. On appeal, the Supreme Court (1) vacated Defendant's convictions as to two counts for the baby's broken ribs, holding that the evidence was insufficient to sustain the convictions; (2) reversed the trial court's denial of Defendant's motion for an in camera review of Mother's mental health records under Iowa Code 622.10(4), a statute the Court upheld as constitutional; and (3) otherwise affirmed. View "State v. Neiderbach" on Justia Law