Justia Iowa Supreme Court Opinion Summaries

The Supreme Court vacated Defendant's sentence and remanded this case for resentencing, holding that where the sentencing court indicated that it lacked "wiggle room" regarding whether to reduce Defendant's sentence, the court failed to exercise its discretion under Iowa Code 901.10(1), which expressly provided the court with discretion to reduce Defendant's sentence.Defendant was convicted of intimidation with a dangerous weapon (count one) and reckless use of a firearm. The court sentenced Defendant to a term of incarceration of up to ten years with a mandatory minimum of five years on count one. The Supreme Court vacated the sentence, holding that the district court was unaware that it had discretion under section 901.10 to reduce the five-year minimum term, and therefore, the court failed to exercise its discretion. View "State v. Moore" on Justia Law

The Supreme Court reversed the order of the district court denying Defendants' motion for judgment notwithstanding the verdict on Plaintiff's claim for the common law tort of wrongful discharge in violation of public policy and affirmed the district court's rulings on Plaintiff's wrongful discharge claim based in a violation of Iowa Code 730.5, holding that a common law wrongful discharge claim was not available.Plaintiff brought a claim under section 730.5, which provides civil remedies against employers for violating the workplace drug-testing provisions, and further asserted a claim for wrongful discharge in violation of public policy. Defendant moved for summary judgment, arguing that the common law claim was preempted by the civil case of action provided under the statute. The district court denied the motion and granted summary judgment for Plaintiff. After a trial on the common law wrongful discharge claim the jury awarded Plaintiff damages. The Supreme Court reversed in part, holding (1) the civil cause of action provided by section 730.5 is the exclusive remedy for a violation of section 730.5; and (2) the portions of the jury's award that would be available under section 730.5 are upheld. View "Ferguson v. Exide Technologies, Inc." on Justia Law

The Supreme Court affirmed Defendant's conviction for carrying a firearm on the grounds of a school, holding that a school district-owned athletic complex that is not contiguous to a classroom building does not qualify as grounds of a school under Iowa Code 724.4B and that the district court did not err in giving the jury an instruction defining "grounds of a school."Specifically, the Supreme Court held (1) the "grounds of a school" as used in Iowa Code 724.4B can include school district-owned athletic facilities that are not contiguous to the classroom building, and there was substantial evidence that the parking lot where Defendant was carrying a firearm qualified as grounds of a school; and (2) the district court properly instructed the jury that the grounds of a school may include recreational and cultural facilities. View "State v. Mathias" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the judgment of the district court convicting Defendant of willful injury resulting in serious injury, in violation of Iowa Code 708.4(1), holding that this Court had jurisdiction to hear the appeal.After the court of appeals affirmed Defendant's conviction Defendant asked the Supreme Court for further review, which the Court granted on June 18, 2019. On July 1, 2019, an amendment to Iowa Code 814.6(1) became effective. The amendment denies a defendant the right of appeal from a guilty plea, except for a guilty plea to a class "A" felony or in a case where a defendant establishes good cause. At issue in this appeal was whether this Court had jurisdiction of the appeal regarding Defendant's guilty plea or the district court's denial of Defendant's motion in arrest of judgment under the amendment. The Supreme Court affirmed, holding (1) this Court has jurisdiction of this appeal; and (2) the court of appeals decision stands as the final decision as to Defendant's claims on appeal. View "State v. Draine" on Justia Law

In this postconviction relief case, the Supreme Court affirmed the judgment of the district court dismissing Appellant's claim without an evidentiary hearing that he was actually innocent of robbery in the first degree and that his conviction should be vacated, holding that Appellant was not innocent in any sense of the word.Appellant pleaded guilty to robbery in the first degree, in violation of Iowa Code 711.21. This case arose out of Appellant's second application for postconviction relief. Appellant argued in his application that he was actually innocent of robbery in the first degree because a BB gun is not a dangerous weapon. The district court summarily denied application. The Supreme Court affirmed, holding (1) actual innocence requires proof of factual innocence with respect to the challenged conviction, including any lesser included offenses; and (2) Appellant did not establish a claim of actual innocence upon clear and convincing evidence that he was factually innocent of the offense of conviction. View "Dewberry v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction for sexual abuse in the second degree and lascivious acts with a child, holding that there was no error in the trial court's evidentiary rulings.Specifically, the Supreme Court held (1) the district court did not abuse its discretion in excluding certain evidence proffered by Defendant; (2) the district court did not err in admitting certain hearsay testimony under the medical diagnosis or treatment exception to the general rule; and (3) even if defense counsel breached an essential duty in failing to object to certain hearsay testimony the admission of the testimony did not amount to constitutional prejudice. View "State v. Walker" on Justia Law

The Supreme Court affirmed in part and vacated in part the decision of the court of appeals reversing Defendant's conviction and remanding the case for a new trial, holding that trial counsel was not ineffective for failing to object to a jury instruction on the outdated version of the "stand your ground" justification and that the district court did not abuse its discretion in excluding character evidence of the victim.A jury found Defendant guilty of murder. During trial, Defendant asserted the justification of self-defense and defense of others. On appeal, the court of appeals held (1) the district court did not abuse its discretion in excluding certain character evidence of the victim, (2) there was sufficient evidence to support the conviction, but (3) the outdated justification instruction was prejudicial. The Supreme Court vacated the court of appeals' decision in part and affirmed the judgment of the district court, holding (1) trial counsel was not ineffective for not objecting to the instruction because engaging in an illegal activity disqualified Defendant from asserting stand-your-ground justification; and (2) the character evidence at issue was properly excluded because Defendant was unaware of the victim's specific conduct. View "State v. Baltazar" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the decision of the O'Brien County Board of Supervisors determining that two newspapers under common ownership and published in the same city could not be combined for purposes of determining circulation because the publications were not offered for sale or delivered "in the same geographic area" under Iowa Code 349.6, holding that the district court did not err.The two newspapers at issue were the Sanborn Pioneer and the O'Brien County's Bell-Times-Courier, both owned by Marcus News, Inc. Marcus News and Iowa Information, Inc. both submitted applications to the Board requesting that their newspapers be selected as official county publications. The Board concluded that the two newspapers of Marcus News should not be considered as one newspaper and, as a result, did not select the publications as official newspapers for O'Brien County. The district court affirmed. The Supreme Court also affirmed, holding that the district court correctly concluded that the two publications should not be combined and considered as one publication in the same geographic area. View "Marcus News, Inc. v. O’Brien County Board of Supervisors" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the order of the district court approving a sheriff's claim for reimbursement of jail room and board for Defendant's pretrial detention, holding that because the sheriff did not ask that the fees be included in restitution the district court was not required to take into account Defendant's reasonable ability to pay.Defendant was convicted of arson in the second degree. Thereafter, the sheriff sought recovery of fees under Iowa Code 356.7 for Defendant's 197 days of incarceration at the county jail but did not ask that the fees be included in restitution. The district court ordered Defendant to pay the requested amount. Defendant appealed, arguing that the court should have determined his reasonable ability to pay the jail fees before awarding them. The court of appeals affirmed the order. The Supreme Court affirmed, holding that because the fees were not awarded as part of restitution the amount was not subject to the "reasonable ability to pay" limitations on restitution set forth in Iowa Code chapter 910. View "State v. Gross" on Justia Law

The Supreme Court affirmed the judgment of the district court declining to modify a restriction on alienability of paintings painted by artist Grant Wood and donated in 1976 to Coe College in Cedar Rapids, holding that the 1976 gift was restricted.A foundation donated the paintings to the college, and the gift letter stated that "this would be their permanent home, hanging on the walls of Stewart Memorial Library." While the college traditionally treated the paintings on its books as an unrestricted gift that could be sold or otherwise alienated, in 2016, an auditor determined the paintings should be treated as a restricted gift. The college subsequently filed a petition seeking a judicial interpretation of the gift's terms. The district court ruled that there existed a restriction on the alienability of the paintings and declined to modify the restriction. The Supreme Court affirmed, holding (1) the language in the gift letter did restrict the gift; (2) the Uniform Prudent Management of Institutional Funds Act does not apply; and (3) it was premature to consider the application of the common law doctrine of cy pres because there was no showing the gift restrictions cannot be carried out at present. View "In re Application of Coe College for Interpretation of Purported Gift Restrictions v. Coe College" on Justia Law