Justia Iowa Supreme Court Opinion Summaries

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case for a new trial, holding that trial counsel was not ineffective for failing to object to a jury instruction on the outdated version of the "stand your ground" justification and that the district court did not abuse its discretion in excluding character evidence of the victim.A jury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

The Supreme Court reversed the judgment of the district court denying Defendant's motion to suppress all evidence stemming from a stop of his vehicle, holding that the district court erred in finding that the deputy developed reasonable suspicion of other criminal activity before unreasonably prolonging the stop.After Defendant was stopped for violating Iowa Code 321.297(2) the deputy asked Defendant and his passenger questions. Finding the answers suspicious, the deputy sought permission for a consent search. Defendant consented. After a search of the car, the deputy located more than eighty pounds of marijuana in the trunk. Defendant filed a motion to suppress the evidence, which the district court denied. The Supreme Court reversed, holding that the delay of Defendant's stop was measurable, unreasonable, and in violation of Defendant's Fourth Amendment rights. View "State v. Salcedo" on Justia Law

In this personal injury action, the Supreme Court affirmed the ruling of the district court granting a new trial on Plaintiff's claims against the driver of a motorcycle upon which Plaintiff was riding when the motorcycle collided with a farm tractor, holding that the district court correctly omitted the farmer from the new trial.Plaintiff brought negligence claims against both the farmer and the motorcyclist. When the claims were submitted to the jury, the jury answered "no" to the question of whether the farmer was at fault. The verdict form mistakenly instructed the jury to stop there. The jury was then discharged without deciding whether the motorcyclist was at fault. Plaintiff moved for a new trial, and the district court ordered a new trial solely against the motorcyclist. The court of appeals reversed and remanded the case for a new trial involving both defendants. The Supreme Court vacated the decision of the court of appeals, holding that the district court properly granted a new trial on Plaintiff's claims against the motorcyclist alone because the farmer should be excused from retrial where the jury's no-liability finding was untainted by the error affecting the motorcyclist. View "Whitlow v. McConnaha" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Plaintiff's medical malpractice claims against Defendants, holding that there was no reversible error in the proceedings below.Plaintiff, through a conservator, sued Defendants for negligent acts or omissions that occurred during Plaintiff's birth. During the birth, Plaintiff's shoulder became stuck on his mother's pelvis, and while Defendants performed maneuvers to resolve the stuck shoulder, Plaintiff was born with a permanent injury preventing normal use and function of his left arm. Based upon the jury's verdict, the district court entered an order dismissing Plaintiff's claims. The Supreme Court affirmed, holding (1) the district court did not commit reversible error in the specifications of negligence it submitted to the jury; (2) Plaintiff was properly prevented from introducing continuing medical education (CME) records to show a breach in the standard of care; (3) the district court abused its discretion by prohibiting the use of CME records as impeachment evidence, but the error was harmless; (4) Defendants’ expert opinion testimony was properly disclosed and did not reflect an opinion in anticipation of litigation; and (5) the district court did not abuse its discretion in limiting the jury’s access to video evidence during deliberation. View "Eisenhauer v. Henry County Health Center" on Justia Law

The Supreme Court affirmed in part and reversed in part the order of the district court entering an injunction directing Defendants to place on the ballot a measure asking voters whether they approved the demolition of Hoover Elementary School and the use of the proceeds for school district purposes, holding that the district court erred in granting Plaintiffs injunctive relief.The Iowa City Community School District refused to authorize the placement of the ballot issue at an election after a petition bearing more than 2000 signatures had been timely filed with the Board. When the Board refused to direct the county auditor to place the matter on the ballot for the upcoming election, Plaintiffs sought injunctive relief and damages against the school district court individual board members. The district court entered an injunction and directed the district court to place the matter on the next general election ballot. The district court then granted Defendants summary judgment on Plaintiffs' claims for damages. The Supreme Court reversed in part, holding that Defendants were entitled to summary judgment on all claims because the school district was under no legal obligation to require the county auditor to place the matter on the ballot. View "Young v. Iowa City Community School District" on Justia Law