Justia Iowa Supreme Court Opinion Summaries

A special restitution law provides that the court may order restitution paid to any public agency for the costs of the “emergency response” resulting from the actions constituting a violation of the operating while intoxicated (OWI) statute. In this case, Defendant pled guilty to OWI, first offense. The State requested that Defendant pay “victim restitution” to the City of Davenport and requested “emergency response restitution” on behalf of the Davenport Police Department. The district court denied the State’s claim for restitution, concluding that this case involved only police department services provided to investigate and effect the routine arrest and processing of a person for OWI. The Supreme Court affirmed, holding that, for the reasons set forth in today’s decision in State v. District Court, Iowa Code 321J.2(13)(b) did not authorize recovery of the costs of the routine law enforcement activities involved in this case. View "State v. Iowa District Court for Scott County" on Justia Law

A special restitution law provides that the court may order restitution paid to any public agency for the costs of the “emergency response” resulting from the actions constituting a violation of the operating while intoxicated (OWI) statute. In this case, Defendant was arrested for and convicted of OWI, second offense. The State sought restitution for the costs of the traffic stop, which was conducted by an officer while on regular nighttime parole. The district court denied the request on the grounds that there was no emergency in this case. Thereafter, the State filed a petition for writ of certiorari with the Supreme Court. The Supreme Court affirmed, holding (1) routine law enforcement activities do not qualify as an “emergency response”; and (2) there was no emergency response by law enforcement in this case. View "State v. Iowa District Court for Scott County" on Justia Law

Plaintiff in this case was a municipal waterworks that provides drinking water to central Iowans. Plaintiff sued Defendants - upstream drainage districts and their trustees - in federal court for money damages and other remedies to recover its costs to remove nitrates from the water of Raccoon River. The federal court certified questions of Iowa law to the Supreme Court. The Court answered (1) under Iowa law, drainage districts are granted unqualified immunity from damages claims; (2) Iowa precedent recognizes that drainage districts are immune from injunctive relief claims other than mandamus; (3) Plaintiff cannot assert protections afforded by the Iowa Constitution’s inalienable rights, due process, equal protection, and takings clauses against drainage districts as alleged in the complaint; and (4) Plaintiff does not have a property interest that may be the subject of a claim under the Iowa Constitution’s takings clause as alleged in the complaint. View "Board of Water Works Trustees of the City of Des Moines v. Sac County Board of Supervisors" on Justia Law

The district court granted a request for entry of a charging order against a personal guarantor and judgment debtor’s transferable interest in an LLC. The judgment debtor and intervenor filed a motion to quash alleging that multiple levies and garnishments were improper. The district court granted the motion to quash. The Supreme Court affirmed in part and reversed in part, holding (1) the entry of the charging order was proper; but (2) the district court erred in granting the motion to quash because it is proper to have multiple levies and garnishments at the same time so long as they are under a single execution. Remanded. View "DuTrac Community Credit Union v. Hefel" on Justia Law

Defendant appealed his convictions and sentences following two bench trials, challenging the underlying searches in each of the two cases. Specifically, Defendant argued that the district court erred in denying his motions to suppress firearms and drugs seized by his stepfather, a police officer with the Davenport Police Department, while his stepfather was off duty. Defendant argued that the searches were unconstitutional because his stepfather conducted the searches while exercising state action as a law enforcement official. The district court denied each motion to suppress. After bench trials, Defendant was found guilty of the charges. The Supreme Court affirmed the denial of the motions to suppress, holding that Defendant’s off-duty police officer stepfather was acting in his private capacity, and not in his governmental capacity as a law enforcement officer, when he conducted the searches of Defendant’s person and vehicle. View "State v. Brown" on Justia Law

In this ongoing civil litigation, the Supreme Court decided two prior appeals, referred to as Mueller I and Mueller II. After procedendo issued in Mueller II, Plaintiffs were successful in persuading the district court to proceed with an antitrust claim they had previously stipulated was not included in their fourth amended petition. Defendant filed a petition for a writ of certiorari. The Supreme Court sustained the writ of certiorari, holding that the district court’s summary judgment in Mueller II, and the Court’s subsequent decision affirming that judgment without any remand, ended this civil action such that a rule-of-reason claim against Defendant can only be pursued in a separate lawsuit. View "Wellmark, Inc. v. Iowa District Court for Polk County" on Justia Law

Defendant pleaded guilty to attempted murder. Defendant was sixteen years old at the time of the offense. Defendant was sentenced to twenty-five years in prison, including a mandatory minimum term of incarceration. Defendant was also ordered to pay $150,000 in mandatory restitution to the victim’s estate. Defendant was later resentenced and received immediate parole eligibility because the mandatory minimum period of incarceration had been deemed unconstitutional. The restitution was left in place. Defendant appealed, challenging the $150,000 in restitution to the victim’s estate. The Supreme Court affirmed, holding (1) the $150,000 mandatory restitution for juvenile homicide offenders is not facially unconstitutional; and (2) the $150,000 mandatory restitution was not unconstitutional as applied to Defendant. View "State v. Breeden" on Justia Law

Defendant pleaded guilty to second-degree murder. Defendant was fifteen years old at the time of the offense. The district court sentenced Defendant to an indeterminate term of incarceration and ordered Defendant to pay $150,000 in mandatory restitution to the victim’s estate. Defendant appealed, challenging the $150,000 restitution award. The Supreme Court affirmed, holding (1) Iowa Code 901.5(14) does not authorize the district court to modify a restitution award otherwise required by Iowa Code 910.3B(1), and restitution under chapter 910 is mandatory; and (2) section 910.3B is not unconstitutional either as applied to all juvenile homicide offenders or as applied to Defendant. View "State v. Richardson" on Justia Law

After a jury trial, Defendant was convicted of going armed with intent and willful injury causing bodily injury. Defendant appealed, arguing that defense counsel provided ineffective assistance by failing to challenge the sufficiency of the evidence supporting submission of the going-armed-with-intent charge to the jury and failing to object to the jury instruction on going armed with intent on the ground that it omitted an element of the charged offense. The Supreme Court reversed, holding (1) defense counsel was not ineffective in failing to challenge the sufficiency of the evidence; but (2) defense counsel breached a duty in failing to object to the marshaling instruction for the going-armed-with-intent offense, and Defendant suffered prejudice as a result. Remanded. View "State v. Harris" on Justia Law

Mother, who was sixty-nine years old, filed a petition for relief from elder abuse, naming her son John Wilkinson as the defendant. After a hearing, the district court entered a final protective order against Wilkinson, finding that Wilkinson committed elder abuse by financial exploitation as an adult child. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the legislature intended that if a person’s age makes a person unable to protect himself or herself from elder abuse, that person is a vulnerable elder as defined by the Iowa Code; and (2) Mother was a vulnerable elder under Iowa Code 235F.1(17). View "In re Petition of Judith Ann Chapman" on Justia Law