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Defendant was required to register as a sex offender under Iowa Code 692A.103(1) upon his conviction of lascivious conduct with a minor and release on bond, notwithstanding this appeal. Defendant argued that he had no obligation to register after posting an appeal bond to stay execution of the underlying criminal judgment and before he began serving any prison sentence or was placed on probation. The district court concluded that Defendant was required to register as of the date he was sentenced to prison for the sex offense and was released on the appeal bond. Defendant’s conviction was later affirmed on appeal. Now Defendant faced new criminal charges for violating chapter 692A’s sex offender residency restrictions before his conviction was affirmed. The Supreme Court affirmed the judgment of the district court, holding (1) the stay of execution on Defendant’s criminal judgment did not delay the automatic administrative registration requirement for convicted sex offenders; and (2) Defendant’s release on the appeal bond constituted a “release from incarceration” within the meaning of section 692A.103(1). View "Maxwell v. Iowa Department of Public Safety" on Justia Law

Posted in: Criminal Law

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In this will contest, the district court did not abuse its discretion in denying the unsuccessful will contestant’s motion to amend the pleadings to conform to the proof at the close of his case. The contestant’s motion at issue sought to broaden the contestant’s undue influence claim to include all of the testator’s prior wills and codicils. The Supreme Court held that the last-minute amendment would have broadened the issues and the proof. In addition, this issue fell within precedent upholding denials of motions to amend under Iowa R. Civ. P. 1.457 when the motion is based on facts the movant knew or should have known before trial. As to the contestant’s other issue asking the Supreme Court to overturn a ruling on burden of proof that was incorporated within a pretrial order denying summary judgment, this issue was not preserved for review. Accordingly, the Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court. View "In re Estate of Margaret E. Workman" on Justia Law

Posted in: Trusts & Estates

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Under the circumstances of this case, Defendant was denied procedural protections for determining his status as an habitual offender at trial, and Defendant did not need to preserve error by filing a motion in arrest of judgment. After a bench trial, Defendant was convicted of indecent exposure and sentenced as a habitual offender. Defendant also pled guilty to indecent exposure. On appeal, the State conceded that the plea colloquy was insufficient. However, contrary to Defendant’s arguments, the State argued that the stipulation relating to Defendant’s prior convictions was sufficient. The court of appeals concluded that Defendant failed to preserve error on his claim that the stipulation concerning his prior convictions was deficient and that Defendant was required to challenge the sufficiency of the proceedings either by filing a motion in arrest of judgment or by another means. The Supreme Court vacated the decision of the court of appeals and reversed the judgment and sentences of the district court, holding (1) requirements of the enhanced-penalty hearing were not followed by the district court; and (2) the error preservation rule established in State v. Harrington, 893 N.W.2d 36 (Iowa 2017) was not in existence at the time. View "State v. Steiger" on Justia Law

Posted in: Criminal Law

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The Iowa Department of Corrections (IDOC) may not forfeit earned time an inmate accrued before his refusal of or removal from the Sex Offender Treatment Program (SOTP). For more than a decade, the IDOC policy stopped only the ongoing accrual of earned time for inmates upon a refusal or removal from SOTP without forfeiting previously accrued earned time. This interpretation was upheld by the Supreme Court in Holm v. State, 767 U.W.2d 409 (Iowa 2009). In 2016, the IDOC changed its policy to additionally forfeit all previously accrued earned time upon a refusal or removal from SOTP and applied that change retroactively. The district court concluded that the new IDOC policy interpretation and application to a certain inmate whose release was delayed by more than three years due to the new policy was contrary to Holm and violated the state and federal Ex Post Facto Clauses. The Supreme Court applied stare decisis and the interpretation fixed in Holm and affirmed. View "State v. Iowa District Court for Jones County" on Justia Law

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The Supreme Court decided not to abandon the automobile exception to the search warrant requirement under Iowa Const. art. I, 8 despite technological advances enabling police to obtain warrants from the scene of a traffic stop. Defendant was convicted of possession with intent to deliver. Defendant appealed the denial of his motion to suppress, arguing that the warrantless search of his vehicle violated the Iowa Constitution because police can now obtain warrants electronically from the side of the road. The Supreme Court elected to retain the automobile exception, consistent with precedent, federal caselaw, and the overwhelming majority of other states. The court thus affirmed Defendant’s conviction. View "State v. Storm" on Justia Law

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In this case, the Supreme Court abandoned the exclusive use of absolute disparity as a test for jury representativeness under the Sixth Amendment and permitted absolute disparity, comparative disparity, and standard deviation analyses to be used. Defendant, a black man, was convicted by an all-white jury of one count of harassment in the first degree. On appeal, Defendant argued that the racial composition of the jury pool violated his Sixth Amendment right to an impartial jury. The Supreme Court conditionally affirmed Defendant’s conviction and remanded the case for development of the record on the Sixth Amendment challenge, holding that the district court erred as a matter of law in concluding that the absolute disparity test must be used in deciding whether the jury pool was drawn from a fair cross-section of the community. View "State v. Plain" on Justia Law

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The Supreme Court declined Defendant’s invitation to overturn State v. Comried, 693 N.W. 2d 773 (Iowa 2005), which interpreted the operating while intoxicated (OWI) statute to ban driving a motor vehicle with any detective amount of a prohibited drug in one’s body, regardless of whether the ability to drive was impaired. Defendant, who was charged with OWI after a drug screen detected a non impairing metabolite of marijuana in his urine, moved to dismiss the OWI charge, arguing that Comried is no longer good law. The district court denied Defendant’s motion to dismiss and convicted him. The Supreme Court affirmed Defendant’s conviction and reaffirmed Comried based on the plain meaning of the statutory text, holding that Defendant’s conviction must be upheld because Comried remained good law. View "State v. Childs" on Justia Law

Posted in: Criminal Law

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The owner of a railroad right-of-way filed a petition for certiorari challenging a district court order finding it in contempt for violating a 1977 judgment imposing an injunction against a previous owner of the right-of-way. Specifically, the district court found the subsequent owner in contempt for failing to reconstruct and maintain a dike. The Supreme Court sustained the writ and vacated the decision of the district court, holding the contempt proceeding was an untimely action brought by the drainage district to enforce the 1977 judgment because the 1977 judgment expired under Iowa Code 614.1(6) before this proceeding to enforce it was commenced. View "Dakota, Minnesota & Eastern Railroad v. Iowa District Court for Louisa County" on Justia Law

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This case involved claims brought against various state officials for damages related to public employment. Plaintiff was an Iowa Workers’ Compensation Commissioner. At issue in this interlocutory appeal were four counts alleging violation of due process and equal protection provisions of the Iowa Constitution. The district court granted summary judgment for Defendants on these claims finding that there are no private causes of action for violations of the Iowa Constitution. The Supreme Court reversed in part and affirmed in part, holding that Defendants were not entitled to summary judgment on Counts VI and VII where (1) the equal protection clause of the Iowa Constitution is self-executing; (2) classic preempt doctrine does not apply to the question of whether a Bivens-type damage remedy is available through the Iowa Constitution; and (3) the different nature of the interests protected weighs in favor of allowing a Bivens-type claim to go forward against Defendants. View "Godfrey v. State" on Justia Law

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The administration of a warrantless breath test to Defendant violated Iowa Const. art. I, 8 because the State failed to prove that Defendant voluntarily consented to the warrantless breath test and failed to prove that the breath test was justified by an exception to the warrant requirement. Defendant was convicted of operating a motorboat while under the influence. Defendant appealed the denial of his motion to suppress all evidence after an officer seized the boat he was operating, including the results of a blood test he submitted to. The Supreme Court reversed, holding (1) the law enforcement officer’s seizure of the boat Defendant was operating was constitutional because the officer had a reasonable, articulable suspicion Defendant was committing a crime; but (2) Defendant did not effectively consent to the warrantless breath test, and therefore, the admission of the breath test results violated article I, section 8. View "State v. Pettijohn" on Justia Law