Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction for operating while intoxicated (OWI) and eluding, holding that the district court did not abuse its discretion in admitting evidence about a preliminary breath test (PBT) and that the evidence was sufficient to support the convictions.During the underlying jury trial, the district court admitted a portion of an officer body cam video showing Defendant agreeing to a PBT, after which the edited video jumped to Defendant's arrest for OWI. The Supreme Court held (1) this juxtaposition of the PBT and arrest violated Iowa R. Evid. 5.403 because it had minimal probative value while strongly implying that Defendant had failed the PBT, but the error was harmless; and (2) there was sufficient evidence to sustain Defendant's eluding conviction. View "State v. Amisi" on Justia Law

The Supreme Court held that the district court and court of appeals did not err in finding that Defendant was not seized before the law enforcement officer who eventually arrested him discovered his probable intoxication and that Defendant was lawfully detained on grounds of probable intoxication.In his motion to suppress, Defendant argued that he had been seized when the officers partially blocked him in while he was parked in a parking lot, trained a spotlight on him, and shined flashlights into his car from both sides. The trial court concluded that Defendant had not been "seized" before the police discovered his intoxication. The court of appeals affirmed, concluding that the officers' actions were not "sufficiently coercive" to constitute a seizure. The Supreme Court affirmed, holding that Defendant was lawfully detained because the officers did not seize him before his intoxication was observed. View "State v. Wittenberg" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the trial court denying Defendant's motion to suppress and convicting him of firearm violations, holding that the law enforcement officer who arrested Defendant did not unlawfully seize Defendant.After a woman called the police to report a suspicion car parked in front of her home an officer responded in a patrol car and pulled alongside the parked car. The officer walked over to talk to the driver, smelled a strong odor of burnt marijuana, and searched Defendant and the car. In his suppression motion, Defendant argued that the officer did not unlawfully seize him. The court of appeals concluded that the trial court did not err in denying the motion to suppress. The Supreme Court affirmed, holding that the officer's conduct in this case did not constitute a seizure, and once the officer detected the odor of burnt marijuana he had a lawful ground to detain and search Defendant and the car. View "State v. Cyrus" on Justia Law

The Supreme Court reversed the judgment of the district court granting Defendant's motion to suppress evidence obtained during a traffic stop, holding that because Defendant's license plate cover violated Iowa Code 321.37 it was reasonable for Iowa State Patrol troopers to stop his SUV, the stop was not unconstitutional, the exclusionary rule did not apply, and there were no grounds to suppress evidence from the stop.Because Defendant's rear license plate was shrouded with a tinted plastic cover troopers found it difficult to read the plate. The troopers stopped Defendant to warn him that the cover violated Iowa law and during the stop uncovered evidence leading to Defendant's charges for operating while intoxicated and child endangerment. The district court granted Defendant's motion to suppress, concluding that the traffic stop was unconstitutional. The Supreme Court reversed, holding (1) the traffic stop was constitutional because the license plate cover violated an Iowa traffic statute; and (2) therefore, the district court erred in suppressing evidence from the stop. View "State v. Griffin" on Justia Law

The Supreme Court affirmed Defendant's judgment of sentence and confirmed what it held in State v. Wilbourn, 974 N.W.2d 58 (Iowa 2022) and State v. Treptow, 960 N.W.2d 98 (Iowa 2021), that if good cause is lacking to bring a criminal appeal, an appellate court has no jurisdiction, and the appeal must be dismissed.Defendant pleaded guilty to second-degree theft and was sentenced to three consecutive five-year sentences of imprisonment. The court of appeals affirmed the sentence after finding good cause to address Defendant's challenge to his sentence under Iowa Code 814.6(1)(a)(3). The court declined to address Defendant's assertion that there was an inadequate factual basis to support his guilty plea to theft based on a lack of good cause. The Supreme Court affirmed in part and vacated the judgment in part, holding (1) because the court of appeals had jurisdiction over this appeal it should have also addressed Defendant's challenge to the factual basis supporting his guilty plea; and (2) even though this Court had jurisdiction over Defendant's appeal, it lacked the authority to resolve his factual basis challenge. View "State v. Rutherford" on Justia Law

The Supreme Court affirmed the judgment of the district court ruling that an Employer's refusal to collect dues from Union members' paychecks was a breach of certain collective bargaining rights and awarding money damages to Union, holding that there was no error.Union brought suit against Employer alleging that Employer breached its contracts by failing to deduct dues. The district court granted summary judgment in favor of Union as to Employer's liability for breach of contract for refusing to deduct dues. After a bench trial on the issue of damages the court awarded $1,046,835 to Union. The Supreme Court affirmed, holding (1) Employer breached the contracts' written terms by failing to collect dues; and (2) the money damages remedy was appropriate and without legal error. View "UE Local 893/IUP v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant, following a jury trial, of murder in the second degree, obstructing prosecution, and abusing a corpse, holding that the district court did not abuse its discretion by giving a verdict-urging instruction in this case.On appeal, Defendant argued that the district court coerced the jury's verdict by giving a verdict-urging instruction after the court was informed that the jury was divided 11-1 and that one juror was not following the judge's instructions. The court of appeals vacated Defendant's convictions, concluding that the jury's verdict was coerced. The Supreme Court vacated the court of appeals' opinion and affirmed Defendant's convictions, holding that the court of appeals erred in its coercion analysis and that the jury's verdict was not coerced under the circumstances. View "State v. Church" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions for first-degree robbery and willful injury causing serious injury, holding that Defendant was not entitled to relief on his allegations of error.Defendant's convictions stemmed from his role in the baseball bat attack of a man outside his apartment complex, and a surveillance camera captured some of the altercation. The Supreme Court held (1) there was sufficient evidence to convict Defendant of first-degree robbery based on the victim's testimony and the corroborating surveillance video evidence of the attack; (2) the district court's failure to merge the convictions was not erroneous; and (3) Defendant was not prejudiced by the district court's decision to continue the trial for nine days due primarily to juror illness. View "State v. Brown" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of first-degree robbery and willful injury causing serious injury, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued, among other things, that the district court imposed an illegal and unconstitutional sentence by failing to merge his two convictions. The Supreme Court affirmed, holding (1) there was sufficient evidence to convict Defendant of willful injury causing serious injury; and (2) the district court did not err by not merging the willful injury causing serious injury conviction with the first-degree robbery conviction because there are additional elements of willful injury causing serious injury that are not encompassed within the elements of first-degree robbery under the dangerous weapon alternative. View "State v. Cook" on Justia Law

The Supreme Court affirmed the judgment of the district court ordering Respondent's continued hospitalization following his court-ordered psychiatric treatment, holding that respondents in proceedings brought under Iowa Code chapter 229 do not have a federal constitutional right to represent themselves and forego the legal representation required by the statute.Respondent, who had a history of self-harm, suicide threats, and refusal to take his medications, was ordered to be involuntarily hospitalized under chapter 229. A series of subsequent court orders left Respondent's commitment in place for the next two years. Thereafter, Respondent moved to terminate his commitment and asked to proceed pro se. The district court denied Respondent's motion to proceed pro se and ordered his continued hospitalization. The Supreme Court affirmed, holding (1) the Sixth Amendment right to counsel and right to self-representation in criminal cases do not apply to Chapter 229 proceedings; and (2) the district court's factual findings were supported by substantial evidence and binding on appeal. View "In re V.H." on Justia Law