Justia Iowa Supreme Court Opinion Summaries

The Supreme Court reversed Defendant's conviction for wanton neglect of a resident of a health care facility, holding that the admission of a certain exhibit, when coupled with a certain instruction, posed a serious risk of misleading or confusing the jury.Defendant's conviction arose out of his alleged failure to properly ensure that a facility resident as ordered by the patient's physician. On appeal, Defendant argued that the trial court's admission of the standard of care in the nursing profession and the subsequent instructions related to the use of the standard of care in this case were improper. The Supreme Court agreed and reversed the conviction, holding that the professional standards should have been excluded under Iowa R. Evid. 5.403 and that the court's jury instructions did not mitigate the problem. View "State v. Buman" on Justia Law

The Supreme Court affirmed the judgment of the district court denying a citizen's quo warranto action asserting that a district judge was holding his office unlawfully, holding that this case presented a nonjusticiable controversy.In 2018, two finalists were sent to the Governor for a district judge position. Iowa law provides that, if the Governor fails to make an appointment within thirty days after a list of nominees has been submitted, the appointment shall be made by the Chief Justice of the Supreme Court. On a Thursday, the thirtieth day, the Governor communicated to her chief of staff the her selected nominee's identity - Jason Besler. The following Monday the Governor told Besler that he had been selected. The Chief Justice accepted the Governor's view that the appointment was timely. Gary Dickey, a private citizen, filed an application for leave to file a petition for writ of quo warranto alleging that Besler was holding the office of district judge unlawfully because the Governor failed to appoint Besler by the deadline for making an appointment. The district court denied the application. The Supreme Court affirmed, holding that because both the Governor and the Chief Justice deferred to and accepted the view that the appointment was timely, this quo warranto action was nonjusticiable. View "State ex rel. Dickey v. Besler" on Justia Law

The Supreme Court affirmed Defendant's convictions for attempting to obtain a prescription drug by deceit, as a habitual offender, and conspiracy to commit a nonforcible felony, holding that Defendant's constitutional challenge to Iowa Code 814.6A was unavailing.Specifically, the Supreme Court held (1) the district court did not abuse its broad discretion in admitting, over Defendant's objections, evidence regarding Defendant's residential address, which was offered to prove Defendant's knowledge, motive, and intent; and (2) section 814.6A, a newly-enacted law that prohibits a represented defendant from filing pro se documents, does not violate the constitutional separation-of-powers doctrine. The Court then denied Defendant's motion to accept his pro se supplemental brief. View "State v. Thompson" on Justia Law

The Supreme Court affirmed Defendant's sentence imposed following his pleas of guilty to possession of a firearm by a felon, interference with official acts while armed with a firearm, and carrying weapons, holding that there was no error.On appeal, Defendant argued that the prosecutor breached the parties' plea agreement by failing to recommend the bargained-for sentence and that the district court improperly considered his juvenile offense history as an aggravating factor. The Supreme Court affirmed, holding (1) Defendant failed to establish a breach of the plea agreement; and (2) the district court did not consider an improper sentencing factor in considering Defendant's juvenile adjudications and dispositions. View "State v. Boldon" on Justia Law

The Supreme Court affirmed Defendant's conviction for attempted burglary with intent to commit theft, holding that the State's evidence, and all reasonable inferences from that evidence, was sufficient to support Defendant's conviction.The court of appeals reversed Defendant's attempted burglary conviction, concluding that the circumstantial evidence was too speculative to support his conviction because it required a stacking of inferences. The Supreme Court vacated the court of appeals' decision after noting that this Court does not categorically prohibit stacking of inferences, holding that Defendant's conviction was supported by substantial evidence. View "State v. Ernst" on Justia Law

The Supreme Court vacated Defendant's sentence for domestic abuse assault while displaying a dangerous weapon, holding that the district court exceeded its statutory sentencing authority in this case.The district court sentenced Defendant to an indeterminate term of incarceration not to exceed two years, suspended all but six days of the sentence, and placed Defendant on probation for two years. On appeal, the court of appeals noted that the imposed sentence appeared to be an illegal split sentence but declined to resolve the issue. The Supreme Court exercised its discretion to correct the illegality in this case, holding that the district court imposed a statutorily unauthorized sentence by suspending a portion of Defendant's indeterminate sentence. View "State v. Wieneke" on Justia Law

The Supreme Court reversed the order of the district court denying Defendant's motion to set aside a default judgment awarding Plaintiff immediate and exclusive possession of Defendant's home, holding that the district court erred in denying Defendant's motion to set aside the default judgment.Plaintiff obtained title to Defendant's home by way of a tax sale deed and, after filing a petition for recovery of real property, obtained a default judgment awarding it possession of Defendant's home. Defendant filed a motion to set aside the default judgment, asserting that he was legally disabled and exempt from paying property taxes and that he had been trying to resolve the property tax issue for some time. The district court denied the motion. The Supreme Court reversed, holding that Defendant established good cause to set aside the default judgment. View "No Boundry, LLC v. Hoosman" on Justia Law

The Supreme Court reversed the restitution order of the district court, holding that the State failed to prove the full amount of restitution was caused by the crime of conviction.Defendant pled guilty to ongoing criminal conduct and admitted that the victim bank's losses totaled $288,000. The bank obtained a civil deficiency judgment of $988,636. The district court ordered Defendant to pay restitution in the full amount of the bank's loss rather than the amount Defendant admitted converting. The Supreme Court vacated the restitution amount in excess of $288,000 and remanded the case for entry of an amended restitution award in that amount, holding that the district court's order was not supported by substantial evidence. View "State v. Waigand" on Justia Law

The Supreme Court provided answers to certified questions of law in a federal case brought against the State and a Department of Natural Resources (DNR) officer who shot and killed Plaintiff's son during an armed standoff, concluding that the legislature intended the Iowa Tort Claims Act (Act) to serve as the gateway for all tort litigation against the State.The federal court dismissed all claims against the State and the DNR officer in his official capacity, finding as a matter of law that the officer was acting within the scope of his employment when he shot and killed Plaintiff's son. The federal court dismissed Plaintiff's negligence claims for failure to exhaust administrative remedies under the Act but declined to dismiss Plaintiff's claims against the DNR officer in his individual capacity. The Supreme Court answered the federal court's certified questions of law by holding (1) the Act applies to Plaintiff's state constitutional tort causes of action; (2) the available remedy under the Act for excessive force by a law enforcement officer is adequate; (3) Plaintiff's claims under the Iowa Constitution are subject to the administrative exhaustion requirement in Iowa Code 669.5(1); and (4) plaintiffs are required to bring their Iowa constitutional claims in the appropriate Iowa district court under Iowa Code 669.4. View "Wagner v. State" on Justia Law

The Supreme Court affirmed the restitution order of the district court in this criminal matter, holding that this Court had jurisdiction to review the restitution order and that Defendant did not meet his burden to overturn the restitution order.Defendant pled guilty to possession of methamphetamine. He was sentenced to ten years in prison and ordered to pay a $1000 fine. The district court then ordered a "second category" of restitution apart from the fine totaling $593 for court costs and attorney fees. Defendant appealed, arguing that the second category of restitution was excessive. The Supreme Court affirmed, holding (1) this Court has jurisdiction to consider Defendant's appeal; and (2) the district court did not abuse its discretion in determining the amount of restitution Defendant had the ability to pay. View "State v. Hawk" on Justia Law