Justia Iowa Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the district court denying Defendant's motion for a new trial, holding that the district court erred in applying too strict a standard in determining whether Defendant was entitled to a new trial under the circumstances of this case.Defendant, who was charged with sexual abuse of a child, requested the child's privileged mental health and counseling records. The district court denied the request. The court of appeals remanded the case, ruling that Defendant should have been granted access to the child's mental health and counseling records because they contained exculpatory information. On remand, the district court denied the motion for new trial after applying a weight of the evidence standard. The Supreme Court reversed, holding (1) the appropriate standard for a new trial determination after a district court fails to order production of exculpatory medical records is the material standard in Brady v. Maryland, 373 U.S. 83 (1963); and (2) because the district court applied the incorrect standard in denying the motion for new trial, the case must be remanded. View "State v. Barrett" on Justia Law

The Supreme Court affirmed the district court's judgment dismissing this case on the pleadings, except for slander of title, holding that slander of title was adequately alleged.Debtor brought this case against Bank, alleging breach of contract, breach of the implied duties of good faith and fair dealing, fraud, and slander of title. The district court granted Bank's motion to dismiss, ruling that the contract and fraud claims were time-barred, rejecting Debtor's discovery rule and equitable estoppel arguments, and concluding that the slander of title claim failed to allege publication to a third party. The court of appeals reversed and reinstated all claims. The Supreme Court vacated the decision of the court of appeals in part and affirmed the district court's judgment except as to the slander of title claim, holding (1) the contract, good faith, and fraud claims were time-barred, and the equitable estoppel argument failed as a matter of law; and (2) the slander of title claim was adequately alleged. View "Benskin, Inc. v. West Bank" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the juvenile court's dismissal of the State's petition to adjudicate a child, N.C., in need of assistance pursuant to Iowa Code 232.2(6)(b), (d), and (p), but revering the dismissal on the ground set forth in (d), holding that the State satisfied its burden of proof to adjudicate N.C. a child in need of assistance pursuant to Iowa Code 232.2(6)(d).Section 232.2(6)(d) defines a child in need of assistance as a child who "has been, or is imminently likely to be, sexually abused by the child's parent, guardian, custodian, or other member of the household in which the child resides." The Supreme Court held that N.C.'s report of sexual abuse in this case was credible and that the State satisfied its burden of proof. View "In re N.C." on Justia Law

The Supreme Court vacated the decision of the court of appeals and affirmed the order of the juvenile court terminating Father's parental rights, holding that the State proved the grounds for termination of Father's parental rights and that termination was in the child's best interests.Father had a history of involvement with the Iowa Department of Human Services due to his issues with domestic violence, substance abuse, cognitive functioning, and mental health, leading to the termination of his parental rights to ten other children. In this case, Father's issues led to the removal of another child upon birth. When the child developed serious health issues, Father showed no interest in the child's medical care and failed to gain understanding of how to care for the child's medical needs. Ultimately, the juvenile court terminated Father's parental rights. The Supreme Court affirmed, holding that Father remained incapable of safely caring for the child, and there was no indication that his parenting abilities would adequately improve in the foreseeable future. View "In re J.H." on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming one of Defendant's two convictions of sexual abuse in the third degree based on an aiding-and-abetting theory, holding that the contested count was supported by a factual basis.Defendant raped a woman, G.S., and then forced his companion, J.C., to have sex with the same woman against both of their wills. Defendant pled guilty to two counts of sexual abuse in the third degree. The victim in count I was identified as G.S., and the victim in count II was identified as J.C. On appeal, Defendant argued that there was no evidence that he committed a sex act against J.C. The court of appeals affirmed. The Supreme Court affirmed, holding that J.C. was a victim because Defendant forced him to commit a sex act against his will. View "State v. El-Amin" on Justia Law

In this appeal from a court of appeals decision affirming Defendant's resentencing without eliminating the jail fees relating to the count on which Defendant was acquitted on appeal, the Supreme Court reversed the assessment of $4935 in posttrial fees, holding that Defendant's reimbursement obligation must be reduced.Defendant was found guilty of two crimes, including a forcible felony. While Defendant was confined in the county jail until his sentencing, the sheriff filed a reimbursement claim for jail fees against Defendant. The court of appeals reversed Defendant's forcible felony conviction. On resentencing, the district court revised Defendant's prison sentence but left untouched the jail fees resulting from the dismissed conviction. The court of appeals affirmed. The Supreme Court reversed in part, holding that Defendant's reimbursement obligation under Iowa Code 356.7 must be reduced by $4935 because the costs for Defendant's confinement in the county jail were clearly attributed to the forcible felony charge on which Defendant ultimately received an acquittal. View "State v. Shackford" on Justia Law

The Supreme Court affirmed Defendant's convictions for assault with a dangerous weapon and third degree criminal mischief, holding that Iowa R. Evid. 5.701 and 5.702 did not require certain testimony concerning historical cell site data to be presented by an expert.Investigating officers used Defendant's cell phone records to place him in the general vicinity at the time of the incident giving rise to Defendant's convictions. On appeal, Defendant argued that his counsel provided ineffective assistance by not challenging the phone records as inadmissible hearsay and by not challenging the testimony provided by an officer as an unqualified expert. The Supreme Court affirmed, holding (1) the testimony at issue was not based on specialized knowledge and thus did not require an expert; and (2) therefore, Defendant's counsel was not ineffective for failing to challenge the phone records or the officer's testimony. View "State v. Boothby" on Justia Law

The Supreme Court reversed the judgment of the district court convicting Defendant of second-degree murder, holding that the exclusion of evidence regarding the victim's mental health records and the limitation of testimony on those records was not harmless error.On appeal, Defendant argued that the district court erred when it excluded his mental health records at trial and limited review of those records and erred in forbidding lay testimony on the victim's suicidal behavior. The court of appeals reversed on the evidentiary rulings regarding Defendant's medical records. The Supreme Court affirmed, holding (1) evidence of a person's suicidal disposition is not properly analyzed as character evidence under the Iowa Rules of Evidence in cases where the defendant alleges suicide; (2) the temporal proximity of the medical records was not too remote to be relevant to Defendant's defense that the victim committed suicide; and (3) the exclusion of the victim's medical records and limitation of related admissible testimony was not harmless error. View "State v. Buelow" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for operating while intoxicated first offense, holding that a peace officer does not violate a duty under Iowa Code 321J.11(2) by agreeing to a detainee's request for a retest on the machine that has already tested the detainee's blood alcohol level without also informing the detainee of the statutory right to an independent test at the detainee's expense.Specifically, the Supreme Court held (1) an officer must inform the detainee of the right to an independent test only in circumstances when the detainee has reasonably asked about that right or when a failure to disclose that right could be misleading; and (2) because neither of those circumstances were present in this case, the district court did not err in denying Defendant's motion to suppress. View "State v. Casper" on Justia Law

The Supreme Court affirmed Defendant's convictions and sentences for eluding while speeding and several unrelated offenses, holding that trial counsel was not ineffective for failing to challenge Defendant's eluding charge on double jeopardy grounds based on his guilty plea to speeding in the same incident.At age seventeen, Defendant pled guilty to a speeding citation without pleading guilty to the accompanying charge of eluding. When Defendant turned eighteen, the State charged him by trial information with eluding while speeding. Defendant pled guilty to the eluding charge. The court of appeals affirmed. The Supreme Court affirmed, holding (1) speeding is a lesser included offense that at trial would merge into a conviction for eluding while speeding, but under the circumstances of this case, Defendant cannot use double jeopardy principles as a sword to defeat his conviction for eluding; and (2) therefore, Defendant's ineffective assistance of counsel claims fail. View "State v. Roby" on Justia Law