Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's sentence to an indeterminate term of incarceration not to exceed five years imposed in connection with his plea of guilty to operating while intoxicated, holding that there was no error.While represented by counsel, Defendant filed a time pro se notice of appeal from his conviction and sentence. Thereafter, Defendant's appellate counsel filed an untimely notice of appeal. In his appeal, Defendant argued that the district court denied him the right of allocution at sentencing and requested remand for resentencing. The Supreme Court affirmed, holding (1) even assuming Iowa Code 814.6A prohibited Defendant from filing a pro se notice of appeal Defendant established good cause to appeal as a matter of right; and (2) Defendant was provided the right of allocution. View "State v. Davis" on Justia Law

The Supreme Court affirmed Defendant's conviction entered upon his Alford plea to the charges of intimidation with a dangerous weapon with intent to injure, willful injury resulting in bodily injury, assault with a dangerous weapon, and driving while barred, holding that the district court had jurisdiction to enter the judgment.In 1948, Congress gave the State criminal jurisdiction over offenses committed by or against "Indians" on the Meskwaki Settlement, and in 2018, Congress took back that jurisdiction. In the instant case, Defendant entered an Alford plea to several charges. After Defendant violated his probation, the Tama County Attorney filed an application for entry of judgment on the counts for which Defendant had previously received deferred judgments. Before the court granted Defendant deferred judgments but before the county attorney sought entry of judgment on those counts Congress repealed the 1948 Act. Defendant filed a motion to dismiss the application for entry of judgment for lack of jurisdiction. The district court denied the motion. The Supreme Court affirmed, holding that Congress's repeal of the state's jurisdiction did not affect criminal cases pending at the time of the repeal. View "State v. Cungtion" on Justia Law

The Supreme Court affirmed the judgment of the district court finding Defendant guilty of domestic abuse assault and criminal mischief in the fourth degree, holding that the district court had jurisdiction to enter the judgment.The conduct giving rise to the charges against Defendant occurred on the Meskwaki Settlement, and both Defendant and the victim were Indians for purposes of the relevant statutory schemes. In 2018, Congress took back the criminal jurisdiction it gave to the State of Iowa in 1948 over offenses committed by or against "Indians" on the Meskwaki Settlement. On appeal, Defendant argued that Congress's repeal of the 1948 Act divested the district court of jurisdiction to enter judgment. The Supreme Court affirmed, holding that Congress's repeal of the State's jurisdiction did not affect criminal cases pending at the time of the repeal. View "State v. Bear" on Justia Law

The Supreme Court affirmed Defendant's conviction for sexual abuse in the second degree arising out of the sexual abuse of his daughter, N.F., holding that the trial court erred in instructing the jury but that the error was not prejudicial.On appeal, Defendant argued that the district court erred in instructing the jury that there was "no requirement that the testimony of a complainant of sexual offenses be corroborated." Defendant argued that the instruction violated Iowa Code 709.6 and unduly emphasized N.F.'s testimony. The court of appeals affirmed, ruling that the instruction was erroneous but that the error was not prejudicial. The Supreme Court affirmed, holding (1) the instruction at issue unduly emphasized the complainant witness's testimony; but (2) Defendant's rights were not injuriously affected and that he had not suffered a miscarriage of justice, despite the erroneous noncorroboration instruction. View "State v. Kraai" on Justia Law

The Supreme Court reversed the judgment of the trial court convicting Defendant of two counts of suborning perjury and two counts of obstructing prosecution, holding that a defendant cannot violate Iowa Code 719.3 and "induce" a witness to fail to testify by unsuccessfully offering or attempting to produce the witness's unavailability.While being detained on a parole violation and pending charges Defendant told his former girlfriend that she should not go to "church" and that she would not be in trouble if she did not go to church. The girlfriend understood Defendant to be making a coded request that she should not attend a subpoenaed deposition in which she was expected to give testimony incriminating Defendant. Although the girlfriend attended the deposition and gave testimony incriminating Defendant. Based on his coded requests, Defendant was charged with suborning perjury and obstructing prosecution. The jury found Defendant guilty. The Supreme Court reversed, holding that there was insufficient evidence to support Defendant's convictions. View "State v. Hall" on Justia Law

The Supreme Court affirmed Defendant's conviction of harassment in the first degree, holding that the district court did not err on remand in denying Defendant's motion challenging the representativeness of the jury pool under the fair-cross-section requirements under the Sixth Amendment.On appeal from his conviction, Defendant, an African-American, argued that his constitutional right to an impartial jury had been violated because his jury panel contained only one Africa-American out of forty-nine potential jurors that appeared at the courthouse for trial. The Supreme Court remanded the matter to give Defendant an opportunity to develop his impartial jury arguments, but the district court rejected Defendant's more developed claims on remand. The Supreme Court affirmed, holding that the district court did not err in holding on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury. View "State v. Plain" on Justia Law

The Supreme Court reversed the judgment of the district court entered after the jury returned a no-negligence verdict in favor of a surgeon in this medical malpractice case, holding that the district court erred in ruling on permissible expert opinions, and the error was not harmless.A patient who suffered a disabling stroke after undergoing surgery to relieve stenosis brought a medical malpractice suit against the surgeon. At trial, the patient was allowed to introduce evidence that a neurologist and neuroradiologist, from whom he sought a second opinion following surgery, had read his CT angiogram as showing a lesser degree of stenosis. Other evidence, however, was excluded. The Supreme Court reversed the no-negligence judgment in favor of the surgeon, holding (1) the district court misapplied the pretrial disclosure requirements of Iowa Code 668.11 and Iowa R. Civ. P. 1.500(2); and (2) the error was harmful. View "McGrew v. Otoadese" on Justia Law

The Supreme Court vacated the decision of the court of appeals and affirmed the juvenile court's order terminating a guardianship of a minor child that was established with parental consent, holding that there was no error.Young parents consented to a temporary guardianship for the paternal grandparents to serve as guardians of their minor daughter so that the parents could establish stability in their lives. After achieving that stability, Mother sought to terminate the guardianship. The juvenile court entered a termination order, concluding that the child's long-term interests warranted terminating the guardianship. The Supreme Court affirmed, holding that the juvenile court properly terminated the guardianship and placed the child in Mother's care pending modification of the parents' dissolution decree to establish physical and legal custody. View "In re Guardianship of L.Y." on Justia Law

The Supreme Court reversed Defendant's conviction for possession of cocaine and affirmed her conviction of interference with official acts, holding that the warrantless entry into Defendant's apartment to arrest her was unlawful.After Defendant was charged, she filed a motion to suppress, alleging that law enforcement officers made an illegal entry into her home and then used the information obtained from the legal entry to secure a search warrant. The motion to suppress was denied, and the trial court found Defendant guilty of the interference charge and possession of cocaine charge. The Supreme Court reversed in part, holding (1) evidence related to Defendant's conviction of possession of cocaine obtained from the unlawful warrantless entry into her apartment must be suppressed; and (2) Defendant's conviction of interference with official acts was sufficiently attenuated from the officers' unlawful entry to permit admission of Defendant's own illegal conduct under the "new crime exception" to the exclusionary rule. View "State v. Wilson" on Justia Law

The Supreme Court affirmed the decision of the district court affirming the declaratory order of the Iowa Department of Education interpreting a number of statutes and answering five questions posed by the Keystone Area Education Agency, holding that there was no error or abuse its discretion.The questions at issue concerned whether public agencies are required to release or excuse students to receive behavioral analysis therapy (ABA therapy) and, if so, under what circumstances. The Department's declaratory order determined, among other things, that the decision whether to excuse an absence for ABA therapy is generally up to the school district and that a public agency that does excuse attendance for therapy may violate federal law under some circumstances. The district court affirmed. The Supreme Court affirmed, holding (1) the Department had the authority to issue the declaratory order; and (2) the Department's declaratory order was supported by substantial evidence. View "Hills & Dales Child Development Center v. Iowa Department of Education" on Justia Law