Justia Iowa Supreme Court Opinion Summaries

The Supreme Court vacated in part Defendant's sentence, holding that because the district court did not have the benefit of the procedures outlined in State v. Albright, __ N.W.2d __ (Iowa 2019), when it entered its order regarding restitution, the part of the sentencing order regarding restitution must be vacated and the case remanded to the district court to impose restitution consistent with Albright.Defendant pled guilty to driving while her license was barred. On appeal, Defendant argued that the district court erred in ordering her to pay restitution for attorney fees and correctional costs without determining the amounts of those obligations or her ability to pay court costs. The Supreme Court vacated the part of the sentencing order regarding restitution, holding that remand was necessary for reconsideration in light of Albright. View "State v. Perry" on Justia Law

The Supreme Court affirmed the judgment of the district court dissolving an injunction that had precluded a sale after ruling that the City of Waterloo had complied with Iowa Code 306.23 in transferring land from an unused right-of-way to a developer of a residential subdivision.Plaintiffs, adjacent landowners and taxpayers, alleged that the City violated the requirements set forth in section 306.23 imposing notice and appraisal requirements when transferring land from the unused right-of-way. The district court entered an injunction precluding the sale but later lifted its injunction after finding that the City complied with section 306.23. The district court subsequently refused to hold the City in contempt and dismissed Plaintiffs' mandamus claim and application for sanctions. The Supreme Court affirmed, holding that the City complied with section 306.23. View "Hartog v. City of Waterloo, Iowa" on Justia Law

The Supreme Court affirmed Defendant's conviction, holding that the district court did not err in denying Defendant's motion to suppress the results of a chemical breath test where the officer administering the test allegedly violated Defendant's statutory right to obtain additional chemical testing.On appeal, Defendant argued that the district court erred in denying his motion to suppress evidence allegedly obtained in violation of his statutory right under Iowa Code 321J.11. The statute creates a right for a detainee or arrestee to have an independent chemical test administered at the person's own expense in addition to any test administered at the direction of an officer. A detainee or arrestee invokes the statutory right by making "any statement that can be reasonably construed as a request for an independent chemical test." The Supreme Court affirmed, holding that substantial evidence supported the district court's finding that Defendant did not inquire about his right to take an independent test, and therefore, the district court did not err in denying Defendant's motion to suppress evidence. View "State v. Smith" on Justia Law

The Supreme Court affirmed Defendant's conviction but vacated the portion of Defendant's sentence regarding restitution, holding that remand was required because the district court did not have the benefit of the procedures outlined in State v. Albright, __ N.W.2d __ (Iowa 2019).The court of appeals affirmed Defendant's conviction, holding that Defendant's counsel was not ineffective for failing to challenge the sufficiency of the evidence. The court further found that the district court did not err in assessing restitution for appellate attorney fees. The Supreme Court granted further review and affirmed Defendant's conviction, letting the court of appeals decision stand as this Court's final decision regarding Defendant's ineffective assistance of counsel claims. As to Defendant's argument that the district court erred in ordering him to pay restitution in the form of appellate attorney fees without first determining his reasonable ability to pay those fees, the Court held that the restitution part of Defendant's sentence regarding those fees should be vacated and the case remanded to the district court to impose restitution consistent with this Court's decision in Albright. View "State v. Dieckmann" on Justia Law

The Supreme Court affirmed Defendant's sentencing procedure but vacated the portion of Defendant's sentence regarding restitution, holding that remand was necessary for the district court to impose restitution consistent with this Court's decision in State v. Albright, __ N.W.2d __ (Iowa 2019).Defendant was convicted of domestic abuse assault causing bodily injury. The court of appeals affirmed Defendant's sentence. The Supreme Court granted further review and let the court of appeals decision stand as this Court's final decision regarding the issue of whether the district court gave Defendant his right of allocution. As to Defendant's argument that the district court erred in ordering him to pay restitution without first determining his reasonable ability to pay, the Supreme Court held that Defendant's sentence regarding restitution should be vacated and the case remanded for the district court to impose restitution consistent with Albright. View "State v. Weston" on Justia Law

The Supreme Court affirmed the part of the district court's judgment sentencing Defendant to five years' imprisonment but vacated the restitution part of his sentence, holding that remand was required for the district court to impose restitution consistent with this Court's decision in State v. Albright, __ N.W.2d __ (Iowa 2019).Defendant was sentenced to five years' imprisonment for theft in the second degree. The district court also assessed financial obligations to him. The court of appeals affirmed Defendant's sentence. The Supreme Court granted transfer and let the court of appeals decision stand as this Court's final decision regarding Defendant's term of imprisonment. As to Defendant's argument that the district court erred in ordering him to pay restitution in the form of appellate attorney fees without first determining his reasonable ability to pay those fees, the Court held that the restitution part of Defendant's sentence should be vacated and the case remanded for the district court to impose restitution consistent with Albright. View "State v. Steenhoek" 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 vacating the part of Defendant's sentence dealing with restitution, holding that there was no error in Defendant's conviction but that the case must be remanded to the district court to impose restitution consistent with State v. Albright, __ N.W.2d __ (Iowa 2019).Defendant was convicted of second-degree murder. On appeal, Defendant argued (1) the district court erred in denying his motion to continue the trial and admitting a video recording of his police interview into evidence, and (2) the court erred in requiring him to make restitution of appellate attorney fees without first determining his reasonable ability to pay those fees. The court of appeals vacated the portion of the sentence dealing with restitution and remanded the case for entry of a corrected sentencing order. The Supreme Court affirmed Defendant's conviction but found that the restitution part of his sentence should be vacated. The Court held that because the district court did not have the benefit of the procedures outlined in Albright when it entered its order regarding restitution, the portion of the sentencing order regarding restitution must be vacated and remanded. View "State v. Crawford" on Justia Law

The Supreme Court affirmed Defendant's conviction but vacated that part of the sentencing order regarding restitution and remanded the case to the district court to impose restitution consistent with State v. Albright, __ N.W.2d __(Iowa 2019), holding that remand was necessary because the district court did not have the benefit of the procedures outlined in Albright when it entered its order regarding restitution.Defendant was convicted of second-degree sexual abuse of a child under the age of twelve. On appeal, Defendant argued, among other things, that the district court erred in imposing the jail fee without first determining the amount of the fee. The court of appeals affirmed Defendant's conviction but vacated that portion of the sentence dealing with restitution. The Supreme Court let the court of appeals' decision stand as the Court's final decision, thus affirming Defendant's conviction. As to Defendant's sentence, the Court held that the restitution part of Defendant's sentence should be vacated because Albright, which clarified restitution requirements, was filed after the court of appeals decision in this case. View "State v. Tournier" 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 the district court order requiring Defendant to pay restitution for court costs and attorney fees, holding that the part of the sentencing order regarding restitution must be vacated and remanded for resentencing consistent with this Court's decision in State v. Albright, __ N.W.2d __ (Iowa 2019).The court of appeals affirmed Defendant's conviction for first-degree burglary and assault causing bodily injury but remanded the case for resentencing because it found the assault causing bodily injury conviction merged with the first-degree burglary conviction. The court of appeals also affirmed the part of the sentencing order requiring Defendant to pay restitution for court costs and attorney fees. The Supreme Court let the court of appeals' decision stand as the Court's final decision regarding all of Defendant's claims except Defendant's claim that the district court erred in ordering him to pay restitution without first determining his reasonable ability to pay these items of restitution. The Supreme Court vacated the restitution portion of Defendant's sentence, holding that because the district court did not have the benefit of the procedures outlined in Albright when it entered its restitution order, remand was required. View "State v. Mosley" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment for a judgment creditor and dismissed the petition filed by the judgment debtor and his wife to vacate a charging order to execute foreign judgments in Iowa district court against the judgment debtor's membership interests in an Iowa limited liability company (LLC), holding that there was no reason to reverse the judgment of the district court.The judgment debtor and his wife sought to vacate the charging order on the grounds that the creditor could not attach the debtor's interests in the Iowa LLC since the debtor and his wife owned them as a tenancy by the entireties in their domicile of Florida. The Supreme Court affirmed the district court's judgment in favor of the creditor, holding (1) the district court properly applied Iowa law because membership interests in an LLC are located in the state where the LLC is formed; (2) the district court correctly dismissed the petition to vacate the charging order since Iowa law does not recognize the ownership of property by a married couple as tenants in the entireties; and (3) the foreign judgments were properly registered, and the charging order was properly issued. View "Wells Fargo Equipment Finance Inc. v. Retterath" on Justia Law