Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's convictions but vacated his sentence and remanded the case for resentencing by a different judge, holding that the prosecutor breached the parties' plea agreement by failing to recommend a suspended sentence in the manner required by precedent.Defendant pleaded guilty pursuant to an Alford plea to lascivious acts with a child and indecent contact with a child. The court, without mentioning the plea agreement or the State's recommendation, sentenced Defendant to a combined seven-year prison sentence that was not suspended. Defendant appealed, but the court of appeals dismissed the appeal. The Supreme Court affirmed Defendant's convictions and vacated his sentence, holding (1) the court of appeals erred by dismissing Defendant's appeal for lack of jurisdiction; and (2) the prosecutor breached the plea agreement by not actually recommending that the district court suspend the sentences. View "State v. Davis" on Justia Law

The Supreme Court further modified a hybrid traditional and rehabilitative alimony award that the court of appeals modified in this case, holding that this Court hereby adopts transitional alimony as another tool to do equity in calculating spousal support.In this divorce action, the district court entered a decree dissolving the parties' seventeen-year marriage, ordering shared custody and physical care of the children, and diving the marital property. On appeal, the court of appeals increased the spousal support award and recalculated Husband child support obligation. On appeal, Husband argued that the increase in the spousal support award and duration was excessive and unnecessary. The Supreme Court affirmed the decision as modified, holding that the alimony is modified as to the amount and duration and that this modification required a recalculation of child support. View "In re Marriage of Pazhoor" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court convicting Defendant of failure to affix a drug tax stamp, interference with official acts causing bodily injury, and possession of heroin following a jury trial, holding that the appellate court did not err in reviewing the sufficiency of the evidence supporting Defendant's conviction.On direct appeal, Defendant challenged the sufficiency of the evidence supporting his conviction for failure to affix a drug tax stamp. Defendant acknowledged that he failed to file a motion for judgment of acquittal to preserve error but contended that the court of appeals could nonetheless review the sufficiency of the evidence. The court of appeals disagreed and affirmed. The Supreme Court affirmed, holding (1) a defendant can challenge the sufficiency of the evidence on direct appeal without first filing a motion for judgment of acquittal; and (2) substantial evidence supported the jury's verdict. View "State v. Crawford" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court convicting Defendant of various drug-related crimes and sentencing him to a total of forty-two years in prison, holding that the district court did not err in denying Defendant's motion to suppress.At issue on appeal was whether the grant of a search warrant to search Defendant's residence and vehicles for evidence of drug dealing had a substantial basis under the totality of the circumstances, as disclosed in the warrant application. The Supreme Court held that the magistrate's determination that the information was sufficient to justify a search warrant for the house had a substantial basis, and therefore, the district court did not err in denying Defendant's motion to suppress. View "State v. Bracy" on Justia Law

The Supreme Court reversed the judgment of the juvenile court terminating the parental rights with respect to two Indian children under the Indian Child Welfare Act (ICWA), 25 U.S.C. 1903(4), and Iowa Code chapter 232B (Iowa ICWA), holding that the juvenile court erred in considering the best interests of the children on the narrow question of transfer to the tribal court.In 2018, the State commenced child-in-need-of-assistance proceedings involving the older child, and in 2019, the Sate commenced CINA proceedings against the younger child. The Omaha Tribe of Nebraska & Iowa (Tribe) was granted intervention and subsequently filed a motion to transfer the case to tribal court. The juvenile court denied the motion to transfer on the ground that it would not be in the best interests of the children. The court then terminated the parental rights of both parents. The Supreme Court reversed, holding that the juvenile court erred in denying the Tribe's motion to transfer jurisdiction. View "In re T.F." on Justia Law

The Supreme Court reversed the decision of the district court ordering an Iowa limited liability company (LLC) to pay its former manager the attorney fees he incurred litigating against the LLC pursuant to Iowa Code 489.408(1), holding that, under the plain language of the statute, a manager or former manager cannot recover from the LLC fees incurred litigating against the company.The district court ruled that the LLC was liable to the manager for indemnification of attorney fees and expenses he incurred defending himself against claims brought against him by the LLC for alleged breach of his duties as manager. The district court awarded the manager attorney fees and expenses but declined to award him "fees on fees," or the additional fees incurred enforcing the statutory fee claim. The Supreme Court reversed the award of attorney fees, holding that the the fees and expenses at issue were not incurred on behalf of the LLC, and therefore, the manager could not recover them from the LLC under section 489.408(1). View "Goche v. WMG, L.C." on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court convicting Defendant, following a guilty plea, of lascivious acts with a child, holding that Defendant was not entitled to relief.On appeal, Defendant argued (1) his plea counsel provided ineffective assistance in allowing him to plead guilty without first requesting a competency hearing; and (2) the district court erred by failing, sua sponte, to order a competency hearing. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Defendant's claim of ineffective assistance of counsel was not a legally sufficient reason that could serve as "good cause" to establish a statutory right to appeal; and (2) the district court did not err by failing, sua sponte, to order a competency hearing. View "State v. Newman" on Justia Law

The Supreme Court remanded this case for a new trial, holding that the district court misapplied changes to the Iowa Rules of Civil Procedure when it excluded certain evidence in this case, and the ruling may have affected the outcome of trial.In 2014, the amendments to the Iowa Rules of Civil Procedure were adopted, inspired by prior changes to the federal rules. In the instant case, the district court excluded certain expert opinions of Plaintiff's treating chiropractor on the grounds that the chiropractor had not formed those opinions during treatment and Plaintiff had not submitted a timely expert report required under Iowa R. Civ. P. 1.500(2)(b). The Supreme Court reversed, holding that because the 2014 rule changes allow parties to submit more limited rule 1.500(2)(c) disclosures for experts who have not been retained for purposes of litigation the district court abused its discretion in its evidentiary ruling. View "Mengwasser v. Comito" on Justia Law

The Supreme Court affirmed Defendant's plea-based conviction for a drug offense, a class "C" felony, holding that Defendant's challenges to the validity of his plea were unavailing.At issue was this Court's supervisory orders promulgated in response to the COVID-19 global pandemic temporarily allowing written pleas. On appeal, Defendant argued that the rules of criminal procedure, precedent, and due process required an in-person plea colloquy in open court and that the supervisory orders violated due process and separation of powers principles. The Supreme Court affirmed, holding (1) Defendant met the good cause requirement by presenting questions of first impression as the the validity of this Court's supervisory orders and Defendant's written guilty plea to a felony; but (2) this Court's supervisory orders are lawful exercises of this Court's constitutional and inherent authority during the pandemic. View "State v. Basquin" on Justia Law

The Supreme Court reversed Defendant's conviction for sexually abusing a client during a Reiki treatment session, holding that the district court erred in allowing evidence about the investigation by the Iowa Board of Massage Therapy into allegations that Defendant had inappropriately touched other clients, and Defendant was entitled to a new trial.On appeal, Defendant argued that the district court erred by introducing evidence about the Board's investigation that ultimately led to the loss of his massage license and by allowing testimony from his complaining former clients. The Supreme Court reversed, holding that the district court properly admitted some evidence from Defendant's former massage clients about their experiences but improperly failed to identify which issues that were truly disputed, leading to the admission of more testimony from the former clients than was permissible. Because the errors were not harmless, the district court remanded the case for a new trial. View "State v. Thoren" on Justia Law