Justia Iowa Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant’s conviction for failure to comply with the sex offender registry but vacated the district court sentence, which included sentencing enhancements, and remanded for further sentencing proceedings. The court held (1) despite the legislature’s ambiguous language in Iowa Code 692A.105, the legislature intended for registered sex offenders to provide notification of a change to temporary lodgings within five business days of that change; (2) the evidence was sufficient to show Defendant failed to comply with section 692A.105; (3) the district court properly instructed the jury regarding the applicable law; (4) any alleged prosecutorial misconduct did not prejudice Defendant; (5) Defendant’s stipulations to the sentencing enhancements were meaningless without a factual basis establishing whether he was represented by counsel for his prior convictions, and therefore, the case should be remanded to establish a factual basis on this sentencing issue; and (6) Defendant’s remaining claims of ineffective assistance of counsel failed. View "State v. Coleman" on Justia Law

The Supreme Court reversed Defendant’s conviction for indecent exposure due to ineffective assistance of counsel and vacated the portion of the district court’s sentence imposing a surcharge for Defendant’s stalking conviction and remanded for the entry of a corrected sentence.Defendant was convicted of indecent exposure and stalking. As relevant to this appeal, the trial court imposed a $100 surcharge on Defendant’s stalking conviction under Iowa Code 911.2B. The Supreme Court reversed the judgment in part and vacated the sentence in part, holding (1) Defendant’s counsel was ineffective as a matter of law by failing to challenge, in a motion for judgment of acquittal, the sufficiency of the evidence of indecent exposure; and (2) the imposition of the second 911.2B surcharge violated the Ex Post Facto Clause. View "State v. Lopez" on Justia Law

The Supreme Court vacated Defendant’s second-degree robbery conviction and remanded for entry of a judgment of conviction for third-degree robbery and resentencing. On appeal, Defendant argued that the district court erred in giving jury instructions on second- and third-degree robbery that failed to differentiate between those offenses. On review, the court held (1) the instruction on second-degree robbery as given did not accurately state the law; (2) the evidence was sufficient to support a finding of simple assault and conviction for third-degree robbery but insufficient to support the conviction for second-degree robbery; and (3) Defendant’s vagueness challenge to the robbery statutes failed. View "State v. Ortiz" on Justia Law

The district court abused its discretion by awarding attorney fees beyond those caused by violations of Iowa R. Civ. P. 1.413 or necessary to deter similar misconduct and by relying on a letter the sanctioned party’s president sent to the Supreme Court after it denied review in in the first appellate decision in this case.In this quiet-title action, the district court awarded attorney fees and expenses of $145,427 as a sanction for frivolous court filings in violation of Rule 1.413. The appellate court affirmed in part the rulings and remanded the case. On remand, the district court made more specific factual findings. On appeal, the court of appeals affirmed the sanction award. At issue before the Supreme Court was whether the amount awarded was excessive. The Supreme court vacated the decision of the court of appeals and modified the district court’s sanction award, holding that the appropriate sanction was $30,000. View "First American Bank v. Fobian Farms, Inc." on Justia Law

The juvenile court did not err in terminating Mother’s parental rights after Mother’s three-month-old daughter was sexually abused by Father, with whom Mother had left the child knowing he was intoxicated.The juvenile court found that the State had proven the grounds for termination of Mother’s parental rights and that termination was in the child’s best interests. The court of appeals reversed. The Supreme Court vacated the decision of the court of appeals and affirmed the juvenile court’s judgment, holding that, where Mother remained incapable of raising the child safely with no indication that her parenting abilities would sufficiently improve in the foreseeable future despite the extensive services provided by social workers with the Iowa Department of Human Services, the juvenile court properly terminated Mother’s parental rights. View "In re A.S." on Justia Law

The Supreme Court reversed the order of the district court awarding Plaintiff her attorney fees and expenses.In this action alleging wrongful discharge and retaliation, the district court entered judgment in favor of Plaintiff. The district court awarded Plaintiff fees and expenses. After several appeals, the court ultimately awarded Plaintiff a total sum of $223,792. The Supreme Court set the fee award at $241,700 and the expense award at $5664, holding (1) the district court did not abuse its discretion by using Plaintiff’s attorneys’ currently hourly rates or by using the percentage reduction method to reduce the total requested fees and expenses; but (2) the district court abused its discretion in the manner it used the percentage reduction method and by not awarding Plaintiff any of the expenses she requested in her application for fees and expenses. View "Lee v. State" on Justia Law

The Supreme Court reversed the decision of the district court reversing the Iowa Department of Economic Development’s (IDED) decision (the 2016 action) to revoke tax credits that had previously been awarded by IDED to Ghost Player, LLC (the 2012 action). On appeal, IDED argued that the district court erred in ruling that the 2016 action revoking the tax credits was an invalid collateral attack on the agency’s 2012 action and was barred under the doctrine of claim preclusion. The Supreme Court agreed, holding that the IDED’s decision to award tax credits to Ghost Player in the 2012 action was not entitled to preclusive effect that would prohibit IDED from attempting to revoke those tax credits in light of the discovery of fraud. View "Ghost Player, LLC v. Iowa Department of Economic Development" on Justia Law

Law enforcement officers executing a search warrant violated Defendant’s rights under Iowa Const. art. I, 8 by searching her purse while she was a visitor present at the premises to be searched but where the search warrant made no motion of her.Prior to trial, Defendant filed a motion to suppress, which the district court denied. Defendant was subsequently found guilty of possessing marijuana. The Supreme Court reversed the district court’s ruling on the motion to suppress and remanded the case to the district court, holding (1) a search of the possessions of a third party at a residence is unconstitutional when the warrant does not support probable cause to search that particular person; and (2) under this court’s applicable caselaw, the search of Defendant’s purse could not be supported based on any of the State’s theories independent of the search warrant. View "State v. Brown" on Justia Law

The district court erred in ruling that the coguarantors of a loan were not entitled to contribution from other guarantors of an underlying debt because the funds used to make the payments on the debt were provided to them by their respective parents.Here, the parents of the coguarantors provided funds to their children to pay part of the underlying debt. The funds were placed in accounts owned or co-owned by the coguarantors, who then paid down a debt with funds drawn from these accounts. The coguarantors sought contribution from the other guarantors of the underlying debt. The district court and court of appeals ruled against the coguarantors. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the district court, holding that the coguarantors were entitled to contribution from other guarantors on the undisputed facts of this case. View "Shcharansky v. Shapiro" on Justia Law

Defendant was entitled to withdraw his guilty plea to assault causing bodily injury because the district court did not substantially comply with Iowa R. Crim. P. 2.8(2)(b)(2) during the guilty plea colloquy. Specifically, the district court did not substantially comply with Rule 2.8(2)9b)(2) because the written guilty plea form failed to inform Defendant about the mandatory thirty-five precent criminal penalty surcharge applicable to the offense. The Supreme Court thus affirmed the decision of the court of appeals, which, based the district court’s noncompliance with the rule, applied a bright-line rule of automatic reversal. View "State v. Diallo" on Justia Law