Justia Iowa Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the district court convicting Defendant of first-degree murder, holding that a new trial was required because the marshaling instruction for that charge failed to cross-reference Defendant's insanity defense.On appeal, Defendant argued that his trial counsel provided ineffective representation by failing to object to the instruction at issue. The Supreme Court agreed, holding (1) the jury instructions were materially misleading without the cross-reference to the insanity defense in the marshaling instruction for first-degree murder and that trial counsel breached an essential duty by failing to object; and (2) this significant error in that marshaling instruction for the main offense undermines this Court's confidence in the verdict, requiring a new trial. View "State v. Davis" on Justia Law

The Supreme Court reversed the order of the district court revoking Defendant's deferred judgment, holding that the district court failed to include sufficient factual findings to support revocation.Defendant pled guilty to child endangerment. The district court ordered the judgment deferred and Defendant to pay a civil penalty, court costs, and attorney fees. Thereafter, the State filed an application to revoke deferred judgment and pronounce sentence, alleging that Defendant had not paid the balance due. The court found that Defendant had violated the terms of her probation and revoked the deferred judgment. The Supreme Court reversed, holding (1) the holding in State v. Damme, 944 N.W. 2d 98 (Iowa 2020), that a defendant who is not challenging her guilty plea or conviction has good cause to appeal an alleged sentencing error when the sentence was neither mandatory nor agreed to in the plea bargain extends to appeals from orders revoking deferred judgments; and (2) the district court's factual findings were insufficient. The Court remanded the case to the district court for a new hearing on the State's application to revoke Defendant's deferred judgment. View "State v. Thompson" on Justia Law

The Supreme Court affirmed the ruling of the district court entering judgment for Defendant, holding that Plaintiff's present challenge to the judgment was already conclusively resolved in his prior appeal.While the jury was deliberating, the parties agreed with limit their risks with a deal that put caps on what Plaintiff would receive and what Defendant would pay. The jury returned a verdict for Defendant. The district court dismissed the case consistent with the verdict. The Supreme Court affirmed the district court's order that entered judgment for Defendant. Thereafter, Defendant refused to pay the amount agreed upon, and so Plaintiff filed a motion to enforce the agreement. The district court denied Plaintiff's motion to enforce the agreement. Plaintiff appealed. The Supreme Court affirmed, holding that Plaintiff made no attack on the judgment that couldn't have been raised in the prior appeal. View "Freer v. DAC, Inc." on Justia Law

The Supreme Court affirmed Defendant's conviction of homicide by intoxicated operation of a vehicle, holding that the district court did not err by denying his requested instruction for homicide by reckless driving as a lesser included offense and by excluding certain evidence.Defendant drove his pickup through a stop sign and broadsided a minivan. One of the passengers in the minivan, a six-month-old infant who wasn't secured in a child restraint system, died from injuries suffered in the crash. Defendant was convicted of homicide by intoxicated operation, and the trial court denied his motion for a new trial. The Supreme Court affirmed, holding (1) the district court did not err in refusing to give to the jury Defendant's requested homicide by reckless driving instruction because it was not a lesser included offense; and (2) the district court did not err in preventing Defendant from offering evidence that the infant wasn't secured in a child restraint seat. View "State v. Johnson" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court denying Defendant's motion for new trial based on a claim of newly discovered evidence, holding that the district court did not abuse its broad discretion in denying Defendant's motion for new trial.In 2014, Defendant registered as a sex offender in Iowa. In 2016, Defendant failed to appear at the sheriff's office to verify his registration information. Defendant was subsequently convicted of failure to comply with the sex offender registry. Thereafter, Defendant filed a motion for new trial based on newly discovered evidence. The district court denied the motion, finding that the newly discovered evidence was not material and would not have changed the jury's verdict. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying the motion for new trial. View "State v. Uranga" on Justia Law

The Supreme Court affirmed the ruling of the district court dismissing an employee's gross negligence claim against a coemployee, holding that settlement documents submitted to and approved by the workers' compensation commissioner extinguished the employee's gross negligence claim.Plaintiff, an employee of Lutheran Services in Iowa (LSI) was attacked by one of LSI's clients, causing injuries. Plaintiff filed a workers' compensation claim against LSI and its workers' compensation carrier. The parties settled, and the two settlement documents were approved by the Iowa Workers' Compensation Commissioner. Plaintiff subsequently filed a petition in district court seeking to recover damages from Defendant, Plaintiff's supervisor when he worked at LSI, on a theory of gross negligence. Defendant moved to dismiss the action, relying on release language in the settlement documents. The district court granted summary judgment for Defendant on both contract and statutory grounds. The court of appeals reversed, concluding that a settlement with the commissioner did not release a common law claim of gross negligence against a coemployee. The Supreme Court vacated the court of appeals' judgment and affirmed the district court's summary judgment, holding that the district court properly ruled that, as a matter of contract, the language in the terms of settlement extinguished Plaintiff's gross negligence claim. View "Terry v. Dorothy" on Justia Law

The Supreme Court affirmed the decision of the district court denying Plaintiffs' temporary injunction request seeking to invalidate the legislature's statute providing additional election safeguards, holding that the statute does not impose a significant burden on absentee voters.The state election law at issue requires that county auditors contact an applicant when they receive a defective absentee ballot request that omits or contains incorrect statutorily required identification information in order to obtain the required identification information. Plaintiffs argued that such a requirement, as opposed to county auditors attempting to correct the defective requests without additional contact with the applicant, imposes a severe burden on the right to vote. The Supreme Court declined to set aside the state law for purposes of the November 3, 2020 election, holding that the district court did not err in denying Plaintiffs' temporary injunction request. View "League of United Latin American Citizens Of Iowa v. Pate" on Justia Law

The Supreme Court vacated the orders of the district court staying an emergency election directive issued by the Secretary of State concerning the 2020 general election, holding that the district court abused its discretion in issuing the stay.The directive stated that the Secretary will mail a blank absentee ballot request form with instructions to every Iowa voter for the November 3, 2020 general election. At issue was the second paragraph in the directive stating, "To ensure uniformity and to provide voters with consistent guidance on the absentee ballot application process, County Auditors shall distribute only the blank Official State of Iowa Absentee Ballot Request Form..." When county auditors in three counties began mailing absentee ballot applications to registered voters that were refilled with individual voter information, various Republican campaign organizations filed petitions for injunctive relief. The district courts enjoined the county auditors from accepting prepopulated forms. Several Democratic campaign organizations filed an emergency motion to stay in Polk County seeking to block enforcement of the second paragraph of the directive. The district court granted a statewide stay of enforcement of the Secretary's order. The Supreme Court vacated the stay, holding that Iowa Code 53.2 authorized the Secretary's directive and that other grounds did not support the district court's ruling. View "Iowa Secretary of State v. Democratic Senatorial Campaign Committee" on Justia Law

The Supreme Court affirmed Defendant's convictions for misdemeanor possession of of marijuana and felony eluding with marijuana, holding that the convictions do not merge.After convicting Defendant the district court imposed concurrent sentences. On appeal, Defendant argued that the possession convictions merged with the eluding charges. The State argued in response that the statutory scheme demonstrates that the legislature intended cumulative punishments for these offenses. The Supreme Court affirmed, holding (1) under the legal-elements test, it is impossible to commit felony eluding with marijuana without possessing it; but (2) the legislature prescribed cumulative punishments for the two offenses. View "State v. Johnson" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the order of the juvenile court terminating Father's parental rights to his child, holding that Father was not unfairly penalized for working too hard.After the child was removed from Mother's custody and was adjudicated in need of assistance Father received services. Father worked two full-time jobs on weekdays from 6 a.m. until midnight and lacked a driver's license or the ability to get a driver's license. The juvenile court terminated Father's parental rights to the child under Iowa Code 232.116(1)(h). The Supreme Court affirmed, holding (1) the State proved the child had been removed from the physical custody of the child's parents and that the child could not be placed in Father's custody at the time of the termination hearing; and (2) termination was in the child's best interests. View "In re Z.P." on Justia Law