Justia Iowa Supreme Court Opinion Summaries

The Supreme Court dismissed this appeal from a 2019 order that declined to modify Defendant's court-ordered restitution in a criminal case, holding that Senate File 457 (S.F. 457) required dismissal of this appeal.Defendant was serving a life sentence for kidnapping when he requested a restitution hearing, alleging that the state had failed to comply with a prior court order finding that Defendant lacked a reasonable ability to pay attorney fees. The district court denied relief. The Supreme Court dismissed Defendant's appeal, holding that Defendant's remedies in district court had not been exhausted and that, under section 80 of S.F. 457, this Court was precluded from hearing this appeal. View "State v. Holmes" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction and sentence for two counts of indecent contact with a child, holding the trial court did not err by allowing the jury to see a video recording of a child's forensic interview where the child discussed Defendant's sexual abuse of her.Long before the time the child reported the abuse and long before criminal charges were brought, the video interview at issue was recorded. During trial, the State filed a notice of intent to present the video interview. The video was shown the the jury after defense counsel cross-examined the child victim and suggested that she had fabricated her criminal trial testimony. After showing the jury the video the district court instructed the jury that the video could only be used as a tool to assess the child's credibility. Defendant appealed, arguing that the court's admission of the interview was in error. The Supreme Court affirmed, holding that the video was admissible as a prior consistent statement. View "State v. Fontenot" on Justia Law

The Supreme Court affirmed Defendant's conviction for assault "us[ing] any object to penetrate the genitalia or anus of another person" in violation of Iowa Code 708.2(5), holding that there was sufficient evidence to support the conviction and that Defendant's remaining claims of error were unavailing.Defendant's conviction stemmed from his act of penetrating the victim's vagina with his finger while the victim was unconscious. On appeal, Defendant argued that his finger did not constitute an "object" under section 708.2(5). The Supreme Court affirmed, holding (1) the evidence was sufficient to prove that Defendant committed assault by penetration with an object; and (2) the district court did not err in restricting Defendant from impeaching the complaining witness with otherwise inadmissible evidence. View "State v. Zacarias" on Justia Law

The Supreme Court affirmed Defendant's conviction for child endangerment and remanded the case to the district court for resentencing, holding that the court of appeals properly vacated the restitution portion of the sentencing order due to the court's failure to make a proper reasonable-ability-to-pay determination regarding Defendant's restitution costs.The court of appeals affirmed Defendant's conviction but vacated the restitution portion of Defendant's sentence. The Supreme Court affirmed, holding (1) certain challenged statements fell under the excited utterance exception to the rule against hearsay; (2) Defendant's argument that her Confrontation Clause rights were violated by the admission of certain evidence was not preserved; and (3) the proper resolution of Defendant's appeal of the restitution order was to remand the case to the district court with instructions to allow Defendant to follow the procedures required by Iowa Code 910.2A and then to hold a hearing under section 910.7 on the remaining restitution issues in this case. View "State v. Dessinger" on Justia Law

In this defamation action, the Supreme Court affirmed the district court's order granting Defendant's motion for summary judgment, holding that the district court did not err in concluding that the statement at issue was a constitutionally protected opinion.Plaintiff, a manager of an apartment building, sued Defendant for defamation in connection with a social media post in which Defendant called Plaintiff a slumlord. In his complaint, Plaintiff argued that Defendant asserted a false statement of fact in alleging that he was an actual unscrupulous landlord of a slum area. The district court granted summary judgment for Defendant. The court of appeals affirmed. The Supreme Court affirmed, holding that any reasonable reader of Defendant's social media post would understand that the use of the term "slumlord" was only rhetorical hyperbole; and (2) therefore, there was insufficient evidence that anyone thought Defendant asserted a factual statement about Plaintiff as a landlord. View "Bauer v. Brinkman" on Justia Law

The Supreme Court reversed the ruling of the district court striking Plaintiff's resistance to a motion for summary judgment and vacated the resulting summary judgment and bench trial judgment, holding that the district court abused its discretion by striking the entire resistance filing without any showing of prejudice or violation of a prior court order.On the last day of an extended deadline Plaintiff filed his resistance and supporting papers. The next day, the clerk of court rejected Plaintiff's filing because of the failure to redact Plaintiff's social security number. The district court granted Defendants' motion to strike the filing as untimely and noncompliant and subsequently granted summary judgment dismissing Plaintiffs' claims. A different judgment ultimately entered judgment for Defendants on their counterclaims. The Supreme Court reversed, holding that the district court abused its discretion by granting Defendants' motion to strike Plaintiff's resistance filings. View "Toney v. Parker" on Justia Law

In this interlocutory appeal, the Supreme Court affirmed the order of the district court prohibiting Defendant from filing any additional pro se supplemental documents in a postconviction relief proceeding, holding that the district court did not err.Under Iowa Code 822.3A, postconviction relief applicants are prohibited from filing "any pro se document, including an application, brief, reply brief, or motion, in any Iowa court." At issue was the constitutionality of the law, which was passed in the spring of 2019 and effective July 1, 2019, to pending postconviction relief proceedings and postconviction relief appeals. Defendant in this case argued that section 822.3A violated his constitutional rights. The Supreme Court rejected the argument, holding that there is no constitutional right to file pro se supplemental documents in postconviction relief proceedings and postconviction appeals. View "Hrbek v. State" on Justia Law

In this case arising out of the discontinuance of the City of Mt. Union, the Supreme Court affirmed the decision of the district court dismissing Plaintiffs' claim against the City Development Board, holding that the district court correctly concluded that a petition for judicial review under Iowa Code chapter 17A was Plaintiffs' exclusive remedy against the Board.Dan and Linda Johnson obtained a default judgment against the City, which had then been discontinued, for defamation, and presented it for payment to the Board, a state agency that supervises the discontinuance of cities. The Board approved the default judgment as a valid administrative claim. Plaintiffs petitioned for judicial review and filed this lawsuit seeking a declaratory judgment. The district court granted summary judgment for Plaintiffs and against the Johnsons in the declaratory judgment action but dismissed Plaintiffs' claim against the Board. The court of appeals reversed the dismissal of the Board. The Supreme Court vacated the court of appeals' decision in part, holding that Iowa Code 368.22 expressly makes chapter 17A "the exclusive means" of judicial review of the Board's actions. View "Marek v. City Development Board of State of Iowa" on Justia Law

The Supreme Court reaffirmed its holding in Schilling v. Iowa Department of Transportation, 646 N.W.2d 69 (Iowa 2002), that a deferred judgment counts as a "final conviction" for purposes of mandatory license revocation under Iowa Code 321.209 and noted that its intervening decision in State v. Tong, 805 N.W.2d 599 (Iowa 2011), did nothing to erode the Schilling.At issue was the use of a deferred judgment as one of the underlying convictions counted by the Iowa Department of Transportation to revoke Appellant's status as a habitual offender. Appellant's driver's license was revoked under section 321.209 for Appellant's having garnered three enumerated convictions in a six-year period, making him a habitual offender under Iowa Code 321.555(1). Appellant argued that the deferred judgment he received on the eluding charge was not a "final conviction" and could not be counted as one of the predicate convictions. The district court upheld the agency's decision, and the court of appeals affirmed. The Supreme Court affirmed, holding that the lower courts correctly declined to depart from Schilling. View "Johnston v. Iowa Department of Transportation" on Justia Law

The Supreme Court reversed the decision of the district court denying Appellant's application to modify his sex offender registry requirements, holding that the district court erred in penalizing Defendant for his years of successful adjustment to sex offender registration.In 2000, Defendant pled guilty to two counts of sexual abuse in the third degree, making him subject to lifetime as a sex offender. Defendant was released in 2009 and, since then, had been on the registry without any violation of the registration requirements. In 2019, Defendant filed an application for modification of his sex offender registry requirements pursuant to Iowa Code 692A.128. The district court denied the application. The Supreme Court reversed, holding that the district court abused its discretion by not putting Defendant's STATIC-99R score into proper context and improperly relied on the absence of a stipulation with the Iowa Department of Correctional Services approving of a modification of the registration requirement. View "Becher v. State" on Justia Law