Justia Iowa Supreme Court Opinion Summaries

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

The Supreme Court affirmed Defendant's conviction of a class C felony drug offense and prison sentence, holding that immigration status per se is not an appropriate sentencing consideration but that immigration status may be taken into account to the extent it affects an otherwise relevant sentencing factor.Defendant, a Mexican national, pled guilty to a felony drug offense and was placed on immigration hold for likely deportation. Defendant sought probation, but the district court imposed a prison sentence, expressing the view that it would not be feasible to order probation for a defendant who was going to be deported to Mexico. The Supreme Court affirmed, holding (1) a defendant's immigration status may not be the basis for a sentence, but to the extent it affects an otherwise relevant sentencing factor it may be taken into account; and (2) on the record, the district court properly determined that probation would not be appropriate for someone whose probation would need to be supervised in Mexico. View "State v. Valdez" on Justia Law

The Supreme Court conditionally remanded this case involving Defendant's conviction for assault with attempt to commit sexual abuse; pattern, practice, or scheme to engage in sexual exploitation by a counselor or therapist; and child endangerment, holding that the trial court should have conducted a Iowa R. Evid. 5.412 hearing to determine whether one of the alleged victims made false accusations of sexual abuse against her parents.Defendant, the former owner of a school for troubled youth, was convicted of two offenses involving acts of sexual misconduct against a former female student and a third offense relating to the school's physical mistreatment of two former male students. The Supreme Court affirmed on condition and remanded with directions, holding (1) the evidence was sufficient to sustain Defendant's convictions; (2) the district court did not err in declining to consider ineffective assistance claims as part of motion for new trial proceedings; but (3) the district court erred by failing to conduct a rule 5.412 hearing before or during trial to determine whether the female student made false accusations of sexual abuse against her adoptive or foster parents. View "State v. Trane" on Justia Law

The Supreme Court affirmed the district court's judgment convicting Defendant of first-degree murder, holding that Defendant's Sixth Amendment rights of confrontation or compulsory process were not violated when the district court refused to permit Defendant during trial to call a witness who intended to invoke his Fifth Amendment privilege against self-incrimination on all questions.In his retrial for murder, Defendant sought to call a witness so that the jury could him him "take the Fifth" and thus infer the witness's guilt. The district court refused to permit Defendant to call the witness because, pursuant to State v. Bedwell, 417 N.W.2d 66 (Iowa 1987), the jury is not entitled to draw inferences favorable to the defense from a witness's decision to exercise his constitutional privilege. The court of appeals reversed, distinguishing Bedwell on grounds that the witness had testified in Defendant's prior trial and the district court failed to ascertain the scope of his privilege question by question. The Supreme Court vacated the court of appeals' decision and affirmed the district court, holding (1) under the circumstances, Bedwell provides a categorical rule against compelling the witness to assert his Fifth Amendment privilege in front of the jury; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "State v. Heard" on Justia Law

The Supreme Court reversed the magistrate's dismissal of three pending misdemeanor charges against Defendant based on the legal proposition that Iowa courts lack jurisdiction over crimes committed on the Meskwaki Settlement, holding that the State may assert jurisdiction involving crimes committed on tribal lands by non-Indians involving either victimless crimes or non-Indian victims.An officer of the Meskwaki Nation Police Department filed two cases in district court alleging that Defendant committed the misdemeanor crimes of trespass, possession of drug paraphernalia, and violation of a no-contact order while on the Meskwaki Settlement. The magistrate dismissed the charges, concluding that recent federal legislation removed state jurisdiction for crimes committed on the Settlement. The Supreme Court reversed the dismissal of the charges and vacated the remaining portions of the district court's order, holding that the recent legislation left undisturbed state court criminal jurisdiction involving criminal acts involving non-Indians. View "State v. Stanton" on Justia Law

The Supreme Court vacated Defendant's sentence in connection with her Alford plea to four counts of child endangerment entered pursuant to a plea agreement, holding that the State breached the plea agreement with Defendant and that Defendant's original counsel was ineffective for failing to object.On appeal, Defendant argued that, pursuant to the plea agreement between the parties, the State was obligated to jointly recommend a deferred judgment. Instead, at the sentencing hearing, the State recommended, and the court imposed, a two-year suspended prison sentence without objection from defense counsel. The court of appeals affirmed Defendant's conviction and sentence. Thereafter, amendments to Iowa Code 814.6 and 814.7, enacted in Senate File 589, were signed into law and became effective. The State argued before the Supreme Court that Senate File 589 foreclosed relief in this appeal. The Supreme Court held (1) sections 814.6 and 814.7, as amended, do not apply to a direct appeal from a judgment and sentence entered before July 1, 2019; and (2) the State breached the plea agreement and Defendant's counsel was ineffective. The Supreme Court remanded the case for the State's specific performance of the plea agreement and resentencing by a different judge. View "State v. Macke" on Justia Law

The Supreme Court affirmed in part and vacated in part the decision of the court of appeals affirming Defendant's conviction and sentence for child endangerment resulting in serious injury, holding that the part of the sentencing order regarding restitution must be remanded for the district court to impose restitution consistent with the Court's decision in State v. Albright, 925 N.W.2d 144 (Iowa 2019).On appeal, Defendant argued that his counsel provided ineffective assistance and that the district court erred in ordering him to pay restitution without first determining his reasonable ability to pay. The court of appeals affirmed. The Supreme Court held (1) the court of appeals' decision stands as this Court's final decision regarding Defendant's ineffective assistance of counsel claims; and (2) because the district court did not have the benefit of the procedures outlined in Albright when it entered its order regarding restitution the sentencing order must be remanded. View "State v. Moore" on Justia Law