Justia Iowa Supreme Court Opinion Summaries

The Supreme Court vacated the decision of the court of appeals reversing Defendant's conviction of second-degree murder, holding that Defendant was not entitled to a new trial on any of his allegations of error.After trial, Defendant filed a motion for a new trial alleging, among other things, that the trial court erred in refusing to disqualify a juror who allegedly made out-of-court statements regarding Defendant's guilt and misconduct and bias related to extraneous information reaching the jury about a possible riot if a certain verdict was not returned. The district court denied the motions for a new trial and entered judgment. The court of appeals reversed, concluding that juror misconduct and bias warranted a new trial. The Supreme Court vacated the decision of the court of appeals and affirmed the district court judgment, holding that Defendant was not entitled to a new trial under the facts of this case. View "State v. Christensen" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming in part and reversed in part the judgment and sentence of the district court convicting Defendant of operating while intoxicated (OWI) second offense, holding that the clause of the OWI statutes that makes it unlawful for a person to operate a motor vehicle with any amount of a controlled substance in his or her person does not violate the Due Process Clause of either the United States or Iowa Constitution as applied to the facts of this case.The court of appeals found Iowa Code 321J.2(a)(c), which makes it unlawful for a person to operate a motor vehicle "[w]hile any amount of a controlled substance is present in the person," does not violate due process guarantees but reversed the judgment and sentence after concluding that the district court failed to engage in a proper colloquy before accepting a stipulation relating to the prior conviction for OWI. The Supreme Court only addressed the due process claim and affirmed the court of appeals as to the remaining issues, holding that section 321J.2(1)(c) does not violate the requirements of due process under the federal or state Constitutions as applied to this case. View "State v. Newton" on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's application for postconviction relief, holding that a factual basis did not exist for the element of confinement to support Defendant's guilty plea to the crime of kidnapping in the second degree.In her postconviction relief application Defendant asserted that her trial counsel was ineffective for permitting her to plead guilty to kidnapping because no facts were presented to show that she impeded the victim's movement by pointing a handgun at the victim for a period of time before shooting and killing him. The district court denied Defendant's application, finding that a factual basis for confinement existed to support the plea of guilty. The Supreme Court reversed, holding that the record did not contain a factual basis to demonstrate that Defendant confined the victim in a manner to support an independent kidnapping charge. View "Sauser v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Petitioners' petitions for judicial review of a decision of the Iowa Utilities Board (IUB) approving constructing of an underground crude oil pipeline in Iowa and approving the use of eminent domain where necessary to condemn easements along the pipeline route, holding that the district court did not err in its judgment.The proposed pipeline would run from western North Dakota across South Dakota and Iowa to an oil transportation hub in southern Illinois. After the IUB approved the construction of the pipeline Petitioners, several landowners and an environmental organization, sought judicial review. The district court denied the petitions. The Supreme Court affirmed, holding (1) the IUB's weighing of benefits and costs supported its determination that the pipeline served the public convenience and necessity; (2) the pipeline was not barred by Iowa Code 6A.21 and 6A.22 from utilizing eminent domain because it was both a company under the jurisdiction of the IUB and a common carrier pipeline; (3) the use of eminent domain for a traditional public use such as an oil pipeline does not violate the Iowa Constitution or the United States Constitution; and (4) the IUB's determinations regarding two of the landowners' personal claims were supported by substantial evidence. View "Puntenney v. Iowa Utilities Board" on Justia Law

The Supreme Court affirmed in part and vacated in part the decision of the court of appeals affirming the judgment of the district court modifying a judgment for civil conspiracy following a jury trial, holding that the district court did not abuse its discretion in granting the motion to amend the judgment.Jeffrey Anderson commenced an action against Dean and Carol Anderson and Anderson Tooling, Inc. (ATI) alleging, among other claims, tortious discharge. Dean, Carol, and ATI filed several counterclaims. ATI sued Lori and brought a claim against Lori and Fabrication & Construction Services Inc. (FabCon) for, among other claims, conspiracy. Damages against Jeff totaled $772,297.72. The district court subsequently granted ATI's motion to modify the judgment to make Lori and FabCon jointly and severally liable for the $772,297.72 judgment. As relevant to this appeal, the court of appeals reversed the district court's order imposing joint and several liability on Lori and FabCon, determining that a conspiracy did not exist for Lori and FabCon to join. The Supreme Court vacated the court of appeals's judgment in part, holding that the district court did not abuse its discretion in granting the motion to amend the judgment. View "Anderson v. Anderson Tooling, Inc." on Justia Law

The Supreme Court reversed the decision of the district court holding that a copy of a petition for judicial review sent by email to opposing counsel failed to comply with Iowa Code 17A.19(2), which imposes a jurisdictional requirement for the petitioner in an action for judicial review to timely mail a copy of the petition to attorneys for all the parties in the case, holding that emailing between attorneys in Iowa satisfies the jurisdictional requirement of the statute.Petitioner filed a petition for judicial review after the Iowa Workers' Compensation Commissioner issued a decision in a contested case proceeding against Loyd Ruling Construction. Loyd Roling filed a motion to dismiss the petition for judicial review, arguing that the district court lacked jurisdiction because Petitioner's attorney did not mail the copy of the petition through the postal system until more than ten days after the petition was filed, as required by section 17A.19(2). The district court agreed and dismissed the petition, concluding that electronic mailing did not constitute substantial compliance with the statute. The Supreme Court reversed, holding that the service requirement under the statute is satisfied when a lawyer emails a copy of the petition to opposing counsel. View "Ortiz v. Loyd Roling Construction" on Justia Law

The Supreme Court conditionally affirmed Defendant's conviction and sentence for first-degree murder but remanded for further proceedings consistent with decisions it also filed today in State v. Lilly, __ N.W.2d __ (Iowa 2019), and State v. Veal, __ N.W.2d __ (Iowa 2019), and this opinion, holding that further consideration of Defendant's claim that his jury was not drawn from a fair cross section of the community, in violation of the Sixth Amendment to the United States Constitution and article I, section 10 of the Iowa Constitution, was warranted.Defendant, an African-American, was charged with first-degree murder in a county that was approximately 2.3 percent African-American in population. The jury pool of unexcused jurors, however, contained only one African-American. The Supreme Court held (1) as in Lilly and Veal, the appropriate course of action is to remand the case to offer Defendant a further opportunity to develop his arguments that his Sixth Amendment right to an impartial jury was violated; and (2) Defendant's remaining claims of error did not warrant a new trial. View "State v. Williams" on Justia Law

The Supreme Court conditionally affirmed Defendant's conviction of two counts of first-degree murder while remanding the case for further proceedings consistent with State v. Lilly, __ N.W.2d __ (Iowa 2019), also decided today, holding that further consideration of Defendant's claim of violation of his right to an impartial jury drawn from a fair cross section of the community was warranted.Defendant was an African-American. Although the jury venire contained five African-Americans, no African-American was seated on the jury that heard Defendant's case. On appeal, Defendant asserted a number of trial-related issues, including the claim that his jury was not drawn from a fair cross section of the community in violation of the Sixth Amendment. The Supreme Court held (1) as in Lilly, the appropriate course of action is to remand the case to offer Defendant a further opportunity to develop his arguments that his Sixth Amendment right to an impartial jury was violated; and (2) Defendant's remaining claims did not warrant reversal. View "State v. Veal" on Justia Law

The Supreme Court conditionally affirmed Defendant's conviction for aiding and abetting a bank robbery and remanded for further consideration of Defendant's claim that his jury was not drawn from a fair cross section of the community, in violation of the Sixth Amendment to the United States Constitution and article I, section 10 of the Iowa Constitution, holding that further consideration of this claim was warranted.Defendant, an African-American, was convicted following a trial by a jury that contained no African-Americans. Further, there were no African-Americans in the jury venire that reported that day. On appeal, Defendant argued that the racial composition of the jury pool violated his rights to an impartial jury under both the federal and the state constitution. The Supreme Court held that the typical jury management practices can support a systematic exclusion claim under the framework established in State v. Plain, 898 N.W.2d 801 (Iowa 2017), and Duren v. Missouri, 439 U.S. 357 (1979), where the evidence shows one or more of those practices have produced underrepresentation of a minority group, and this case will be remanded to give Defendant a further opportunity to develop his fair-cross-section claim. View "State v. Lilly" on Justia Law

The Supreme Court affirmed the district court's grant of summary judgment dismissing this action filed by a public employee union seeking to enforce a collective bargaining agreement entered into with the Iowa Board of Regents, holding that the Public Employment Relations Board (PERB) acted within its statutory authority in promulgating Iowa Admin. Code R. 621-6.5(3), which has the force of law, and that the district court correctly applied rule 621-6.5(3) to hold the parties had no enforceable collective bargaining agreement (CBA) without the Board's vote to ratify it.The Board moved for summary judgment on the union's action to enforce the CBA, relying on rule 621-6.5, which requires the Board to meet to vote to accept a tentative voluntary agreement ratified by the union before the contract becomes effective. The union argued that the agency rule was invalid because it imposed a ratification requirement not included in Iowa Code 20.17(4). The district court upheld the validity of the agency rule and dismissed the union's enforcement action. The Supreme Court affirmed, holding (1) rule 621-6.5(3) is valid; and (2) therefore, no enforceable agreement was reached without the requisite vote by the Board to approve the CBA. View "Service Employees International Union, Local 199 v. State" on Justia Law