Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court denying Defendant's motion to suppress and convicting him of being a felon in possession of a firearm, holding that there was no error in the denial of the motion to suppress.Defendant was a passenger in a Lyft vehicle that was stopped for traffic violations. The officers recognized Defendant from past eluding incidents and ordered him out of the vehicle to conduct a pat-down for weapons. Defendant moved to suppress the evidence, arguing that the officer lacked reasonable and articulable facts to justify ordering him out of the vehicle and patting him down. The district court denied the motion to suppress, and the court of appeals affirmed. The Supreme Court affirmed, holding that the officer had reasonable suspicion to justify ordering Defendant out of the vehicle and subsequently patting him down for weapons. View "State v. Williams" on Justia Law

In this case involving Democrat Abby Finkenauer's candidacy for U.S. Senate the Supreme Court sustained the State Objections Panel's decision to reject objections as to the signatures of three electors who had provided either no date or a clearly incorrect date, holding that there was no error.If the objectors' position as to the signatures in this case had been sustained, Finkenauer would have failed to meet the requirements to be placed on the June 7, 2022 Democratic primary ballot. The Panel allowed Finkenauer's nomination petition. The district court reversed, holding that the three undated or improperly dated signatures should not have been counted. At issue was Iowa Code 43.15(2), which makes the date a legal requirement when an eligible elector signs a nomination petition, and recent legislation passed last year, Iowa Code 43.24(2)(a), which did not include missing or incorrect dates as one of the grounds for sustaining an objection to a petition. The Supreme Court reversed, holding that the recent legislation prevailed. View "Schmett v. State Objections Panel" on Justia Law

The Supreme Court reversed the district court's of restitution against Defendant, holding that the restitution was constitutionally impermissible.Under Iowa Code 910.3B, an award of at least $150,000 is required when "the offender is convicted of a felony in which the act or acts committed by the offender caused the death of another person." On appeal from his conviction for assault causing serious injury and conspiracy to commit a forcible felony, Defendant argued that the district court erred in ordering him to pay $150,000 in restitution because the jury did not find beyond a reasonable doubt that he caused the death of another. The Supreme Court agreed, holding (1) section 910.3B does not require a jury finding that the defendant caused the death of another person; (2) because the $150,000 restitution in punitive in part, awards of such restitution must be based on findings determined by the jury; and (3) because no jury found that Defendant caused the death of the victim of the shooting, the restitution award must be reversed. View "State v. Davison" on Justia Law

The Supreme Court affirmed the ruling of the juvenile court that the Indian Child Welfare Act (ICWA) did not apply to the termination of parental rights proceedings below, holding that the juvenile court did not err in determining that Z.K. was not an "Indian child" under ICWA.After holding a hearing on the applicability of ICWA the juvenile court concluded that ICWA remained inapplicable to Z.K. Turning to the merits, the juvenile court found that the State's reasonable efforts to avoid the out-of-home placement had been unsuccessful and proceeded to terminate the parents' parental rights to Z.K. The court of appeals affirmed. The Supreme Court affirmed, holding that the juvenile court properly determined that Z.K. did not meet the definition of "Indian child" under the applicable ICWA statutes. View "In re Z.K." on Justia Law

The Supreme Court affirmed the decision of the district court affirming the conclusion of the workers' compensation commissioner that Claimant's rotator cuff injury was a scheduled shoulder injury rather than an unscheduled whole body injury under Iowa Code 85.34(2), holding that there was no error.Claimant sustained a work-related injury that was diagnosed as a "full thickness rotator cuff tear that has retracted to the level of the glenoid, severe AC arthrosis, tendonitis and tearing of the biceps tendon." In seeking permanent partial disability benefits, Claimant argued that her injury qualified as an unscheduled injury to the body as a whole, entitling her to industrial disability benefits. The commissioner concluded that Claimant's rotator cuff injury was a scheduled injury to the shoulder, and the district court affirmed. The Supreme Court affirmed, holding that the district court properly determined (1) Claimant's rotator cuff injury was a scheduled shoulder injury under Iowa Code 85.34(2)(n); and (2) substantial evidence supported the commissioner's finding that Claimant failed to prove her biceps tear resulted in a permanent disability to her arm under section 85.34(2)(m). View "Chavez v. MS Technology LLC" on Justia Law

In this criminal action, the Supreme Court affirmed the ruling of the district court on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury, holding that Defendant's conviction of second-degree murder stands.On appeal, Defendant, an African-American, argued that his right to an impartial jury under the United States Constitution had been violated because his jury pool contained only two African-Americans, one of whom was later excused. The Supreme Court made refinements to how a defendant must prove a fair-cross-section constitutional violation and remanded the case to give Defendant an opportunity to develop his impartial-jury arguments. On remand, the district court rejected Defendant's further-developed claims. The Supreme Court affirmed, holding that the district court did not err in ruling on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury. View "State v. Williams" on Justia Law

In this criminal action, the Supreme Court affirmed the ruling of the district court on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury, holding that Defendant's conviction of two counts of murder in the first degree and one count of attempted murder stands.On appeal, Defendant, an African-American, argued that his right to an impartial jury under the United States Constitution had been violated because, although his jury pool contained five African-Americans, the jury that decided his case contained no African-Americans. The Supreme Court made refinements to how a defendant must prove a fair-cross-section constitutional violation and remanded the case to give Defendant an opportunity to develop his impartial-jury arguments. On remand, the district court rejected Defendant's further-developed claims. The Supreme Court affirmed, holding that the district court did not err in ruling on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury. View "State v. Veal" on Justia Law

The Supreme Court affirmed the judgment of the district court imposing a six-day jail sentence and ordering Defendant to pay restitution costs for operating a motor vehicle while her license was barred as a habitual offender, holding that there was no error.On appeal, Defendant challenged the district court's discretion to sentence her to jail and the constitutionality of the sentence, arguing that the court (1) improperly considered her financial situation in imposing the jail sentence over Defendant's requested sentence of a fine or probation, and (2) erred by ordering restitution for court costs and court-appointed attorney fees under recent legislation codified in Iowa Code chapter 910. The Supreme Court affirmed, holding (1) the district court properly evaluated all of the facts before imposing jail time instead of a fine or probation; and (2) Defendant waived any challenges to the court's finding that she had a reasonable ability to pay court costs and court-appointed attorney fees. View "State v. McCalley" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court denying Employer's motion for a new trial and motion for judgment notwithstanding the verdict following a jury trial on Employee's claims of sex and gender identity discrimination and dismissing Employee's claims against a third-party administrator on summary judgment, holding that the court erred in part.Specifically, the Supreme Court (1) reversed the district court's denial of Employer's motion for judgment notwithstanding the verdict and dismissed the jury's verdict as to Employee's sex discrimination claims, holding that the district court erred in submitting the sex discrimination claim to the jury; (2) affirmed the jury's verdicts as to employee's gender identity discrimination claims; (3) affirmed the jury's damages award in favor of Employee in the full amounts that the jury entered; and (4) affirmed the district court's grant of summary judgment in favor of Employer. View "Vroegh v. Iowa Department of Corrections" on Justia Law

The Supreme Court affirmed Defendant's conviction, rendered after a second jury trial, of second-degree murder, holding that Defendant was not entitled to relief on her allegations of error.Over twenty-five years after the murder in this case, a woman told a cold-case investigator about a murder confession she witnessed as a girl from Defendant. Defendant was ultimately charged with and convicted of murder. The Supreme Court affirmed, holding (1) as to Defendant's argument that the prosecution failed to timely disclose that certain evidence had been determined unsuitable for standard DNA testing, Defendant could have sought DNA testing prior to trial but chose not to do so, and Defendant may still pursue specialized DNA testing in a postconviction proceeding; (2) the twenty-six year delay in prosecution did not prejudice Defendant's ability to make her case, and there was no bad faith on the part of the prosecution; (3) the district court did not err in allowing the jury to scrutinize the credibility of witnesses; and (4) there was sufficient evidence for the jury to find Defendant guilty of second-degree murder. View "State v. Cahill" on Justia Law