Justia Iowa Supreme Court Opinion Summaries

Chad Allen Staton was convicted by a jury of incest and sexual abuse of his daughter. He appealed his conviction, arguing that the evidence was insufficient, the district court erred by allowing his daughter to testify about a prior uncharged incident, and his right to allocute was violated when the sentencing court disallowed discussion of rejected plea offers. Staton contended that the rejected plea offers demonstrated his sincerity in professing innocence, which should mitigate his lack of remorse at sentencing.The Iowa District Court for Black Hawk County, presided over by Judge Linda M. Fangman, sentenced Staton to indeterminate prison sentences totaling forty years with a mandatory minimum of seventeen and a half years. Staton appealed, and the Iowa Court of Appeals affirmed his conviction and sentence, finding the evidence sufficient and the admission of the prior incident appropriate. The court also concluded that Staton’s right to allocute was not violated as he and his counsel had opportunities to address mitigation.The Iowa Supreme Court reviewed the case to address whether the defendant’s right to allocute was violated by disallowing discussion of rejected plea offers. The court held that the district court correctly cut off discussion of rejected plea offers during allocution, as such offers are inadmissible under Iowa Rule of Criminal Procedure 2.10(5). The court reasoned that allowing discussion of rejected plea offers could deter prosecutors from making plea offers. The court affirmed the decision of the Iowa Court of Appeals and the judgment of the district court, concluding that Staton’s right to allocute was not violated since he and his counsel were allowed to argue his professed innocence to explain his lack of remorse. View "State v. Staton" on Justia Law

Reuben Schooley was convicted of child endangerment causing bodily injury after an incident where he slapped his nine-year-old daughter, spanked her, yanked her by the shirt, and told her to leave the house. The child was found with marks on her collar and bruising on her buttocks. Schooley admitted to spanking her frequently and acknowledged that his actions were inappropriate. The jury found him guilty based on the evidence presented.The Iowa District Court for Emmet County sentenced Schooley to five years of incarceration. Schooley appealed, arguing that there was insufficient evidence to support his conviction and that his sentence was improperly influenced by a victim-impact statement from the guardian ad litem (GAL). He contended that the GAL was not authorized to provide such a statement and that it contained unproven allegations.The Iowa Supreme Court reviewed the case and found that sufficient evidence supported the jury's verdict. The court noted that the reasonableness of corporal punishment is generally a question for the jury and that the evidence showed Schooley's actions were excessive and abusive. The court also addressed Schooley's challenge to the GAL's victim-impact statement, concluding that Schooley had waived this issue by not raising it in the district court. Additionally, the court found no affirmative showing that the district court relied on improper information from the GAL's statement when sentencing Schooley.The Iowa Supreme Court affirmed Schooley's conviction and sentence, holding that the evidence was sufficient to support the jury's verdict and that the district court did not abuse its discretion in considering the GAL's statement. View "State of Iowa v. Schooley" on Justia Law

A couple with older children volunteered to care for the newborn child of an incarcerated mother struggling with methamphetamine addiction. The mother relapsed multiple times, and the couple eventually became the child's guardians. The mother later sought to terminate the guardianship and raise her child, but the guardians had moved out of state with the child, who had become integrated into their family. The guardians sought to adopt the child, while the mother had made significant improvements in her life and wanted to regain custody.The Iowa District Court for Polk County denied the guardians' petition to terminate the mother's parental rights, finding that the guardians' restrictions on visitation and communication justified the mother's lack of contact with the child. The court noted that the guardians had moved out of state without informing the mother or the court, preventing her from maintaining regular contact.The Iowa Court of Appeals reversed the district court's decision, finding that the mother had abandoned the child under Iowa Code section 600A.8(3)(b) by failing to maintain substantial and continuous or repeated contact. The court of appeals determined that the guardians had not placed excessive restrictions on the mother's ability to communicate with the child and that the mother had not exerted sufficient effort to maintain contact.The Iowa Supreme Court affirmed the decision of the court of appeals, concluding that the mother had abandoned the child and that termination of her parental rights was in the best interests of the child. The court noted that the child had become integrated into the guardians' family and that granting the petition for termination would provide the child with stability and permanency. The case was remanded for further proceedings consistent with the opinion. View "In the Interest of J.V., Minor Child" on Justia Law

A credit union filed a claim in probate court, asserting that the decedent owed money on a car loan. The estate mailed a notice of disallowance to the credit union, but the credit union claimed it never received the notice. The estate argued that the claim was time-barred because the credit union did not request a hearing within twenty days of the notice. The credit union conducted an internal investigation and submitted an affidavit stating it never received the notice and that the person who signed for it was not an employee of the credit union but an agent of the U.S. Postal Service.The Iowa District Court for Linn County imposed sanctions on the credit union and its attorneys for violating Iowa Rule of Civil Procedure 1.413(1), which requires that filings be well-grounded in fact and law after reasonable inquiry. The court found that the credit union's investigation was insufficient and that the attorneys made incorrect assertions about the mailing. The Iowa Court of Appeals upheld the sanctions.The Iowa Supreme Court reviewed the case and concluded that the district court abused its discretion in awarding sanctions. The Supreme Court found that the credit union and its counsel conducted a reasonable investigation under the circumstances, given the time constraints and the information available. The court emphasized that the reasonableness of the investigation should be assessed based on the time of the filing, not with hindsight. The Supreme Court vacated the decision of the Court of Appeals, sustained the writ of certiorari, vacated the sanctions, and remanded the case for further proceedings. View "Dupaco Community Credit Union v. Iowa District Court for Linn County" on Justia Law

The defendant engaged in online conversations with an undercover police officer posing as a fifteen-year-old girl. He arranged to meet the girl for sex at a gas station shower room. Upon arrival, he was arrested and charged with solicitation of commercial sexual activity under Iowa Code section 710A.2A. The defendant argued that there was insufficient evidence to support the charge because he did not offer or promise anything of value in exchange for sexual activity. The district court rejected these arguments, and a jury convicted him.The Iowa District Court for Polk County denied the defendant's motion for a new trial and sentenced him to five years in prison. The Iowa Court of Appeals conditionally affirmed the conviction but remanded the case for the district court to reconsider the motion for a new trial under the correct standard. The defendant sought further review.The Iowa Supreme Court reviewed the case and found that the evidence was insufficient to show that the defendant was attempting to engage in commercial sexual activity. The court noted that while the defendant's behavior was reprehensible, he did not give or promise the undercover officer any item of value in exchange for a sex act. The court concluded that the statutory definition of "commercial sexual activity" requires an express or implied quid pro quo, which was not present in this case. Consequently, the court vacated the decision of the court of appeals, reversed the district court's judgment, and remanded the case for dismissal. View "State v. Fenton" on Justia Law

A baby, S.K., was injured during labor and delivery, allegedly due to the negligence of the delivering doctor, Dr. Goodman, who used a Mityvac obstetrical vacuum delivery system. The plaintiff, S.K.'s conservator, claimed that the use of the vacuum caused brain damage to S.K. and sought damages from Dr. Goodman’s employer, Obstetric & Gynecologic Associates of Iowa City and Coralville, P.C. (the clinic).A jury in the Iowa District Court for Johnson County found in favor of the plaintiff, awarding substantial damages. The clinic appealed, arguing that the district court erred in admitting a package insert from the vacuum, which contained hearsay statements about when the vacuum should not be used and potential harms from its use. The clinic contended that the insert's admission violated Iowa’s hearsay rule and prejudiced the trial's outcome.The Iowa Supreme Court reviewed the case and agreed with the clinic. The court found that the package insert contained hearsay and did not fit within any recognized exceptions, including the residual exception and the market reports exception. The court noted that the insert's admission was prejudicial, as it directly addressed a central dispute in the case and was emphasized in the plaintiff's closing argument. The court concluded that the erroneous admission of the insert deprived the clinic of a fair trial.The Iowa Supreme Court reversed the district court's judgment and remanded the case for a new trial. The court also addressed a procedural issue raised by the clinic regarding the plaintiff's certificate of merit affidavit, ultimately denying the clinic's motion to reverse on those grounds. View "S.K. v. Obstetric & Gynecologic Associates of Iowa City and Coralville, P.C." on Justia Law

Sarah Berg, an employee at Casey’s General Store, activated three gift cards without paying for them and used one to purchase gas the next day. She was arrested for fourth-degree theft. The county attorney did not file a trial information for this charge within the required 45 days. Instead, a trial information was later filed for unauthorized use of a credit card.The Iowa District Court for Black Hawk County denied Berg’s motion to dismiss the trial information for unauthorized use of a credit card, despite the missed speedy-indictment deadline for the theft charge. Berg was found guilty following a trial on the minutes. She was sentenced to 120 days in jail (suspended), a fine (suspended), court costs, probation, and potential restitution. Berg appealed, arguing the district court erred in denying her motion to dismiss and that the evidence was insufficient to support her conviction. The Iowa Court of Appeals affirmed her conviction.The Iowa Supreme Court reviewed the case and affirmed the lower courts' decisions. The court held that fourth-degree theft and unauthorized use of a credit card are not the same offense for speedy-indictment purposes. The court reasoned that the charges relied on distinct underlying facts: the theft charge required proof of taking property valued between $300 and $750, while the unauthorized use charge required proof of using a credit card to obtain property or services. Therefore, the State was not precluded from filing the new charge after the 45-day period had elapsed. View "State of Iowa v. Berg" on Justia Law

A sixteen-year-old defendant, concerned that a poor Spanish grade might hinder his plans to study abroad, conspired with a friend to murder his Spanish teacher. They meticulously planned and executed the murder, later bragging about it to classmates. The defendant initially lied to the police but eventually pleaded guilty to first-degree murder, agreeing to challenge only his sentence. At sentencing, the State recommended life imprisonment with parole eligibility after thirty years, while the defendant argued against any minimum term. The district court sentenced him to life with parole eligibility after thirty-five years.The Iowa District Court for Jefferson County rejected the defendant's argument that a minimum sentence required expert testimony. The court considered various factors, including the impact on the victim's family and community, the defendant's role in the crime, and his potential for rehabilitation. The court found that the severity and premeditation of the crime warranted a minimum term of thirty-five years before parole eligibility.The Iowa Supreme Court reviewed the case, focusing on whether sentencing juvenile offenders to a minimum term before parole eligibility violates the Iowa Constitution and whether expert testimony is required to impose such a sentence. The court upheld the district court's decision, ruling that the Iowa Constitution does not categorically ban minimum sentences for juveniles and that expert testimony is not mandatory. The court found that the district court properly considered the relevant factors and did not abuse its discretion in sentencing the defendant to life with the possibility of parole after thirty-five years. The sentence was affirmed. View "State of Iowa v. Miller" on Justia Law

A county auditor filed an administrative complaint against the Secretary of State, alleging that the statewide voter registration file, known as I-Voters, lacked adequate security measures and safeguards to prevent unauthorized access and erroneous removal of eligible voters, thus violating the Help America Vote Act (HAVA). The Secretary of State moved to dismiss the complaint, arguing that it was speculative and that the file complied with federal standards. The administrative body agreed and dismissed the complaint.The county auditor then sought judicial review in the Iowa District Court for Polk County, arguing that the administrative body had erred in dismissing his complaint without an evidentiary hearing. The Secretary of State contended that the county auditor lacked standing and that the complaint was insufficient. The district court dismissed the petition, concluding that the county auditor had not demonstrated an injury in fact.The Iowa Supreme Court reviewed the case and concluded that the county auditor had standing due to his role as the county commissioner of elections, which gave him a specific, personal, and legal interest in the integrity of the voter registration file. The court also found that the administrative body had improperly resolved factual questions without allowing an opportunity for the presentation of evidence. The court held that the county auditor's allegations were sufficient to survive a motion to dismiss and that the administrative body should not have decided factual issues at the motion to dismiss stage.The Iowa Supreme Court reversed the district court's order and remanded the case for further proceedings consistent with its opinion. View "Linn County Auditor v. Iowa Voter Registration Commission" on Justia Law

Eric Harris was arrested on March 25, 2023, on suspicion of arson and other crimes. He had his initial appearance before a magistrate the next day, March 26. The State filed its trial information on May 10, which was the forty-sixth day after Harris's arrest but the forty-fifth day after his initial appearance. Harris moved to dismiss the prosecution, arguing that the State violated the speedy-indictment rule by filing the trial information one day late.The Iowa District Court for Johnson County denied Harris's motion to dismiss. The court interpreted the speedy-indictment rule to mean that the forty-five-day period began on the date of Harris's initial appearance, not the date of his arrest. Consequently, the court found that the trial information filed on May 10 was timely.The Iowa Supreme Court reviewed the case and reversed the district court's decision. The Supreme Court held that under the pre-amendment version of Iowa Rule of Criminal Procedure 2.33, the forty-five-day period for filing a trial information begins on the date of the defendant's arrest, not the initial appearance. Since the State filed the trial information on the forty-sixth day after Harris's arrest, it was untimely. The court concluded that the district court erred in denying Harris's motion to dismiss and remanded the case for dismissal of the prosecution. View "State of Iowa v. Harris" on Justia Law