Justia Iowa Supreme Court Opinion Summaries

Lukouxs Brown was charged with first-degree murder after allegedly killing a coworker. Before his arraignment, his counsel observed signs of mental illness, including hearing voices and a history of schizophrenia. The district court found probable cause to believe Brown was not competent to stand trial and ordered a psychiatric evaluation. Dr. Arnold Andersen diagnosed Brown with a schizophrenia-like disorder and substance abuse disorders, concluding he was not competent but could potentially be restored to competency. Brown was committed to the Iowa Medical and Classification Center (IMCC) for treatment.After eight months of treatment, Dr. Andersen reported that Brown remained incompetent and unlikely to be restored to competency within a reasonable time. The district court, however, allowed the State to obtain a separate psychiatric evaluation, which concluded that Brown was competent. The district court found Brown competent to stand trial and reinstated the criminal proceedings. Brown filed an interlocutory appeal, arguing the district court erred in its competency determination and in allowing the State to obtain a separate evaluation.The Iowa Court of Appeals reviewed the case de novo, found Brown was not competent, and remanded the case for further treatment. The State sought further review, challenging the standard of review and the district court's decision to allow a separate evaluation. The Iowa Supreme Court reaffirmed the de novo standard of review for competency determinations, emphasizing the protection of constitutional rights. The court also held that Iowa Code does not permit separate psychiatric evaluations at the dispositional phase of competency proceedings. The court vacated the Court of Appeals decision, reversed the district court order, and remanded the case for further proceedings consistent with its opinion. View "State of Iowa v. Brown" on Justia Law

Alison Dorsey ran an in-home daycare in Cass County, Iowa. In 2019, an eleven-week-old baby at her daycare died, leading to Dorsey being charged with first-degree murder and child endangerment resulting in death. Her first trial in Cass County ended in a hung jury. The State then requested a change of venue, which the district court granted, moving the second trial to Pottawattamie County. Dorsey was subsequently convicted of second-degree murder and child endangerment resulting in death.The Iowa District Court for Cass County initially handled the case, where the first trial ended in a mistrial due to a hung jury. Following this, the State filed a motion to change the venue, citing concerns about pretrial publicity and the difficulty of seating an impartial jury in Cass County. The district court granted the motion, and the second trial was held in Pottawattamie County, where Dorsey was convicted. Dorsey appealed the decision, challenging the change of venue among other issues.The Iowa Supreme Court reviewed the case and concluded that the district court abused its discretion by granting the State's motion for a change of venue without attempting to seat a second jury in Cass County. The court emphasized that the district court should have used the voir dire process to assess potential juror bias before deciding to move the trial. The court found that the pretrial publicity was not sufficiently pervasive or inflammatory to justify the venue change without this step. Consequently, the Iowa Supreme Court reversed Dorsey's conviction and remanded the case for a new trial in Cass County. View "State of Iowa v. Dorsey" on Justia Law

Orange City passed an ordinance requiring periodic inspections of rental properties. If entry for inspection is refused, the ordinance allows the city inspector to seek legal remedies, including obtaining an administrative search warrant. Certain owners and renters of rental units challenged the ordinance, claiming it violated article I, section 8 of the Iowa Constitution because it did not require the city to show traditional probable cause before seeking a warrant.The Iowa District Court for Sioux County ruled in favor of the challengers, declaring the ordinance's mandatory inspection requirement unconstitutional and enjoining the city from seeking administrative warrants under the ordinance. The court awarded nominal damages to the plaintiffs.The Iowa Supreme Court reviewed the case and disagreed with the lower court's ruling. The court noted that in a facial challenge, the challenger must prove that the ordinance is unconstitutional in all its applications. The court found that there are scenarios where the ordinance could operate constitutionally, such as when traditional probable cause is present, when non-warrant legal remedies are pursued, or when inspections are conducted by certified third-party inspectors, exempting the property from city inspections. Therefore, the facial challenge could not succeed.The Iowa Supreme Court reversed the district court's decision and remanded the case for further proceedings consistent with its opinion. The main holding was that the ordinance's inspection regime could operate constitutionally in certain circumstances, thus the facial challenge to the ordinance failed. View "Singer v. City of Orange City" on Justia Law

Artell Young, a federal supervised releasee, was subject to a search condition allowing federal probation officers to search his person, vehicle, or home upon reasonable suspicion of contraband or release condition violations. After receiving information that Young was dealing drugs and possessing a firearm, federal probation officers searched his home, finding small amounts of crack cocaine, powdered cocaine, and marijuana. The federal authorities turned the case over to Iowa authorities, leading to Young's conviction on several drug offenses.In the Iowa District Court for Polk County, Young moved to suppress the evidence from the search, arguing it violated the Fourth Amendment and article I, section 8 of the Iowa Constitution. The district court upheld the search, citing the "special needs" exception under both the Fourth Amendment and article I, section 8. The court also noted that the search was conducted by federal officers under federal standards, thus not subject to Iowa constitutional standards. Young was convicted by a jury of three counts of possession of a controlled substance and sentenced to six years in prison.The Iowa Supreme Court reviewed the case, focusing on whether the search violated article I, section 8 of the Iowa Constitution. The court held that the constitutionality of the search should be evaluated by the law of the sovereign that conducted the search—in this case, federal law. The court affirmed the district court's decision, concluding that the search was lawful under federal standards and that the evidence obtained was admissible in the state prosecution. The court rejected Young's claim of an illegal search and affirmed his convictions. View "State of Iowa v. Young" on Justia Law

On the night of October 9, 2021, Wichang Chawech was at a bar in Des Moines with friends. After altercations between his friends and other patrons, Chawech pulled out a 9 mm pistol and fired a shot, grazing a man's jaw and fatally wounding a woman. Chawech was charged with first-degree murder, attempted murder, willful injury causing serious injury, and intimidation with a dangerous weapon. He pleaded not guilty and raised defenses of justification, self-defense, and defense of others. The jury found him guilty of lesser included offenses for the first two counts and the charged offenses for the latter two counts. They also found that he was in possession of a dangerous weapon during the offenses.The Iowa District Court for Polk County sentenced Chawech to consecutive terms for counts I, III, and IV, totaling twenty-two years, with a mandatory minimum of ten years due to the dangerous weapon enhancement under Iowa Code section 902.7. The court ordered the sentence for count II to run concurrently. Chawech appealed, arguing insufficient evidence, improper merger of counts II and III, and an illegal mandatory minimum sentence due to the enhancement not being charged in the trial information.The Iowa Court of Appeals affirmed the convictions and sentences, except for agreeing that counts II and III should merge. They vacated the sentence for count II and remanded for an appropriate order. Chawech sought further review, focusing on the sufficiency of evidence and the mandatory minimum sentence.The Iowa Supreme Court reviewed the case, focusing on the mandatory minimum sentence. They concluded that the challenge to the sentencing enhancement was an illegal-sentence challenge, not subject to error preservation principles. However, they found that the trial information and jury instructions met the requirements of Iowa Rule of Criminal Procedure 2.6(6) and the U.S. Constitution. Thus, the mandatory minimum sentence was upheld. The court affirmed the decision of the Court of Appeals in part, vacated in part, and remanded the case for further proceedings consistent with their opinion. View "State of Iowa v. Chawech" on Justia Law

Regena Strable, a marketing director at Altoona Nursing and Rehabilitation Center, injured her left ankle at work, leading to permanent partial disability. This injury caused further physical injuries to her hip and lower back, as well as mental injuries such as post-traumatic stress disorder and anxiety. Strable had previously suffered carpal tunnel injuries to both wrists a decade earlier. After settling with her employer for the ankle injury and the sequela injuries, Strable sought benefits from the Second Injury Fund of Iowa based on her prior carpal tunnel injuries.The deputy commissioner denied Strable’s request for benefits from the Fund, concluding that Iowa Code section 85.64 imposes liability on the Fund only when the second injury is limited to a scheduled injury. The Iowa Workers’ Compensation Commissioner disagreed and granted benefits. On judicial review, the Iowa District Court for Polk County reversed the Commissioner’s decision, agreeing with the deputy commissioner that awarding benefits from the Fund would result in double recovery for Strable.The Iowa Supreme Court reviewed the case and reversed the district court’s order. The court held that the Fund is liable under Iowa Code section 85.64 if the first and second qualifying injuries caused a compensable injury to an enumerated member, regardless of whether the injuries caused other non-enumerated or unscheduled injuries. The court found that the Commissioner erred in calculating the Fund’s liability by not including the employer’s liability for the sequela injuries. The case was remanded to the Commissioner for a determination of the amount and timing of the Fund’s liability, consistent with the court’s opinion. View "Second Injury Fund of Iowa v. Strable" on Justia Law

Silvia Cianzio, a retired professor from Iowa State University, filed a lawsuit against the university, the Iowa Board of Regents, and the State of Iowa, alleging wage discrimination in violation of Iowa Code section 216.6A. She claimed that male professors in her department were paid significantly more than female professors, including herself. After conducting a survey on departmental salaries, she discovered that her annual pay was substantially less than that of her male counterparts. She reported these findings to university officials, who dismissed her concerns. Cianzio retired in December 2020 and subsequently filed a complaint with the Iowa Civil Rights Commission (ICRC) in August 2021, followed by a lawsuit in January 2022.The Iowa District Court for Polk County partially granted the university's motion to dismiss, ruling that Cianzio could only seek damages for wage discrimination occurring within the two-year statute of limitations for wage claims, as set forth in Iowa Code section 614.1(8). The court rejected the university's argument that damages should be limited to the 300-day period preceding the filing of her ICRC complaint.The Iowa Supreme Court reviewed the case and reversed the district court's decision. The court held that Iowa Code section 216.15(9)(a)(9) allows a claimant to recover damages for the entire period of wage discrimination, not limited to the two-year statute of limitations or the 300-day period before filing the ICRC complaint. The court emphasized that the statute's language permits recovery for the entire period of discrimination, as long as the complaint is filed within the statutory time frame. The case was remanded for further proceedings consistent with this interpretation. View "Cianzio v. Iowa State University" on Justia Law

An employee, Ashley Koester, worked as a mobile crisis counselor for Eyerly-Ball Community Health Services. She believed she was entitled to overtime compensation for her on-call hours and filled out timesheets accordingly, which were approved by her supervisor. Later, her employer objected to the overtime payments and terminated her employment. Koester sued her employer under Iowa Code chapter 91A and for wrongful discharge in violation of public policy, claiming she was terminated for asserting her right to overtime pay.The Iowa District Court for Polk County dismissed Koester's claims, ruling that she did not have a claim under chapter 91A because she had been paid in full, including for the overtime hours she claimed. The court also found her statutory claim time-barred. Koester appealed, and the Iowa Court of Appeals reversed the dismissal of her public policy claim but affirmed the dismissal of her statutory claim.The Iowa Supreme Court reviewed the case and concluded that Koester did not state a claim for relief under chapter 91A or the common law tort of wrongful discharge in violation of public policy. The court held that chapter 91A is a wage collection law, not a generalized fair practices law, and since Koester did not have a claim for unpaid wages, she was not entitled to relief. The court also determined that Koester's public policy claim failed because she was not engaged in protected activity under the statute, as she did not file a complaint or claim unpaid wages before her termination. The Iowa Supreme Court vacated the decision of the Court of Appeals and affirmed the District Court's judgment dismissing Koester's claims. View "Koester v. Eyerly-Ball Community Mental Health Services" on Justia Law

John Feller was charged in 2011 with lascivious acts with a child and third-degree sexual abuse after his stepdaughter reported abuse. He pleaded guilty to two counts of lascivious acts with a child and was sentenced to concurrent five-year prison terms, a ten-year special sentence, and required to register as a sex offender. Initially, he was informed he needed to register for ten years, but later was told he had to register for life due to a procedural error resulting in two separate case numbers.The Iowa District Court for Dubuque County denied Feller's application to modify his sex offender registration requirements, citing his decision to testify by affidavit, his courtroom demeanor, and letters he sent to his daughter. The Iowa Court of Appeals affirmed this decision.The Iowa Supreme Court reviewed the case and found that the district court abused its discretion by considering improper factors, such as Feller's choice to testify by affidavit and his demeanor. The court noted that Feller had completed sex offender treatment, had no criminal charges since his release, and was evaluated as a low risk to reoffend. The court also found that the letters Feller sent to his daughter, which were sent with permission, did not indicate a risk of reoffense.The Iowa Supreme Court vacated the decision of the Court of Appeals, reversed the district court's judgment, and remanded the case for an order granting Feller's application to end his lifetime registration. The court emphasized that Feller's successful adjustment to the community and low risk of reoffense did not justify the continuation of his registration requirements. View "Feller v. State" on Justia Law

A police officer initiated a traffic stop of Ashlee Mumford because the vehicle's license plate was obscured by dirt and grime. During the stop, a drug detection dog conducted a sniff around the vehicle, briefly touching the passenger door and momentarily breaking the plane of the passenger window. The dog alerted to the presence of controlled substances, leading to a search that uncovered methamphetamine in the glove compartment and marijuana and a methamphetamine pipe in Mumford's purse. Mumford was arrested and charged with possession of methamphetamine, marijuana, and drug paraphernalia. She was acquitted of methamphetamine possession but convicted of marijuana and drug paraphernalia possession.In the Iowa District Court for Madison County, Mumford moved to suppress the evidence obtained from the traffic stop, arguing it violated her constitutional rights against unreasonable searches and seizures. The district court denied her motion, concluding the traffic stop was supported by probable cause and the use of the drug detection dog did not violate the Federal or State Constitution. Mumford was convicted of possession of marijuana and drug paraphernalia following a bench trial.The Iowa Supreme Court reviewed the case and affirmed the district court's decision. The court held that the traffic stop was supported by probable cause due to the obscured license plate, and the use of the drug detection dog did not constitute an unlawful search. The court also found sufficient evidence to support Mumford's conviction for possession of marijuana, rejecting her argument that lab testing was required to prove the substance was marijuana. The court concluded that the district court did not err in denying Mumford's motion to suppress evidence or her motion in arrest of judgment. View "State v. Mumford" on Justia Law