Justia Iowa Supreme Court Opinion Summaries

Defendant pled not guilty to the charge of delivering methamphetamine. During jury selection, the prosecutor posed hypothetical questions approximating the facts of the case, intimated the State possessed additional evidence supporting guilt but could only present some of it, and implied that the State only prosecutes guilty people. The jury later returned a verdict finding Defendant guilty. Defendant filed a motion in arrest of judgment and motion for new trial. The trial court denied the motion, concluding that the State’s comments and questions were not so inflammatory as to deny Defendant a fair trial. The court of appeals concluded that the prosecutor’s questions ventured into a gray area but concluded that the remarks did not cause juror bias or make the trial unfair. The Supreme Court affirmed, holding (1) of the four lines of voir dire inquiry challenged by objection and preserved for appellate review, two were permissible; and (2) the district court mitigated any prejudice resulting from the two lines of questionable voir dire inquiry, the court’s remediate efforts were adequate under the circumstances presented here. View "State v. Martin" on Justia Law

Employee injured her back during the course of her employment. Employer paid for the cost of care Employee received to treat her injury through September 2009. Employee later brought a workers’ compensation claim seeking workers’ compensation benefits and medical expenses she incurred for additional back treatment between May 2010 and April 2011. The Workers’ Compensation Commissioner concluded that the treatment Employee received between May 2010 and April 2011 was not causally related to her workplace injury but nonetheless awarded Employee medical expenses because Employer failed to notify Employee it was no longer authorizing treatment as required by Iowa Code 85.27(4). The district court reversed in part, concluding that the agency misinterpreted section 85.27(4) and that Employer was not liable for the expenses Employee incurred after September 2009. The court of appeals reversed the portion of the district court judgment reversing the agency’s determination that Employer was liable to Employee for the expenses she incurred from May 2010 through April 2011, concluding that the district court erroneously interpreted section 85.27(4). The Supreme Court affirmed in part and vacated in part the decision of the court of appeals, holding that the Commissioner erroneously interpreted Iowa Code 85.27(4). Remanded. View "Ramirez-Trujillo v. Quality Egg, LLC" on Justia Law

The Iowa Commission on Judicial Qualifications filed an application for imposition of discipline against Joseph Sevcik, a part-time magistrate who also practiced law. The Commission found Magistrate Sevcik violated two of the canons of judicial conduct by requesting and receiving two confidential court files from a clerk of court and then using one of the files during his cross-examination of a witness in a hearing before the district court in which he represented a party in the case. The Supreme Court held that Magistrate Sevcik violated Canons 1 and 3 of the Iowa Code of Judicial Conduct, along with Rules 51:1.2 and 51:3.5, and agreed with the Commission that a public reprimand was the appropriate sanction. View "In re Inquiry Concerning Joseph Sevcik" on Justia Law

The Iowa Commission on Judicial Qualifications filed an application for imposition of discipline against Joseph Sevcik, a part-time magistrate who also practiced law. The Commission found Magistrate Sevcik violated two of the canons of judicial conduct by requesting and receiving two confidential court files from a clerk of court and then using one of the files during his cross-examination of a witness in a hearing before the district court in which he represented a party in the case. The Supreme Court held that Magistrate Sevcik violated Canons 1 and 3 of the Iowa Code of Judicial Conduct, along with Rules 51:1.2 and 51:3.5, and agreed with the Commission that a public reprimand was the appropriate sanction. View "In re Inquiry Concerning Joseph Sevcik" on Justia Law

After a jury trial, Defendant was convicted of three counts of delivery of a controlled substance. The court of appeals reversed, concluding that defendant’s right to a fair trial by an impartial jury was violated due to certain statements a prospective juror made during voir dire. The Supreme Court vacated the decision of the court of appeals and affirmed in part and reversed in part the judgment of the district court, holding (1) the district court did not deny Defendant a fair trial by an impartial jury because the statements the prospective juror made during voir dire were not so prejudicial as to warrant a presumption they tainted at least one member of the jury panel; (2) the district court did not abuse its discretion by declining to holding a hearing to permit defense counsel to show cause for missing an extended discovery and deposition deadline; (3) the record was inadequate to assess whether prejudice resulted from defense counsel’s breach of an essential duty, and Defendant may bring his ineffective assistance claim in a future postconviction relief action; and (4) the district court applied the incorrect standard in denying Defendant’s motion for new trial on the ground the verdicts were contrary to the weight of the evidence. Remanded. View "State v. Ary" on Justia Law

After a jury trial, Defendant was convicted of three counts of delivery of a controlled substance. The court of appeals reversed, concluding that defendant’s right to a fair trial by an impartial jury was violated due to certain statements a prospective juror made during voir dire. The Supreme Court vacated the decision of the court of appeals and affirmed in part and reversed in part the judgment of the district court, holding (1) the district court did not deny Defendant a fair trial by an impartial jury because the statements the prospective juror made during voir dire were not so prejudicial as to warrant a presumption they tainted at least one member of the jury panel; (2) the district court did not abuse its discretion by declining to holding a hearing to permit defense counsel to show cause for missing an extended discovery and deposition deadline; (3) the record was inadequate to assess whether prejudice resulted from defense counsel’s breach of an essential duty, and Defendant may bring his ineffective assistance claim in a future postconviction relief action; and (4) the district court applied the incorrect standard in denying Defendant’s motion for new trial on the ground the verdicts were contrary to the weight of the evidence. Remanded. View "State v. Ary" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to possession of a controlled substance first offense. The judgment and sentence provided that Defendant’s driver’s license shall be revoked for 180 days and provided for several surcharges on top of the fine. Defendant appealed, arguing that his written plea was defective because it failed to disclose the statutory minimum sentence of two days in jail, the mandatory six months’ revocation of his driver’s license, and the surcharges that were added to his fine. The court of appeals affirmed Defendant’s plea and sentence. The Supreme Court vacated the decision of the court of appeals and vacated the judgment and sentence imposed by the district court, holding (1) Defendant’s plea was involuntary because revocation of the driver’s license of a person convicted of a drug possession offense is mandatory, immediate, and part of the punishment for that offense, and therefore, the court must inform the defendant of this consequence before accepting his guilty plea; and (2) Defendant had a right to be informed of fine surcharges. Remanded. View "State v. Fisher" on Justia Law

An SUV was being driven in the wrong direction on a highway when it collided with a semi-tractor-trailer. The SUV was totaled, and the SUV’s driver was killed. Second later, a motorcyclist ran into the SUV that was still in the middle of the highway. The drivers of both the semi and the motorcycle suffered injuries. The drivers jointly filed a petition for declaratory judgment against the insurer of the SUV asking the district court to declare that there had been two accidents for purposes of the insurance policy’s per-accident limit on bodily injury liability. The district court granted summary judgment for the insurer, concluding that the injuries suffered by the plaintiffs arose from one accident. The Supreme Court affirmed, holding that, under the terms of the SUV driver’s insurance policy, there was only one accident. View "Hughes v. Farmers Auto. Ins. Ass’n" on Justia Law

An SUV was being driven in the wrong direction on a highway when it collided with a semi-tractor-trailer. The SUV was totaled, and the SUV’s driver was killed. Second later, a motorcyclist ran into the SUV that was still in the middle of the highway. The drivers of both the semi and the motorcycle suffered injuries. The drivers jointly filed a petition for declaratory judgment against the insurer of the SUV asking the district court to declare that there had been two accidents for purposes of the insurance policy’s per-accident limit on bodily injury liability. The district court granted summary judgment for the insurer, concluding that the injuries suffered by the plaintiffs arose from one accident. The Supreme Court affirmed, holding that, under the terms of the SUV driver’s insurance policy, there was only one accident. View "Hughes v. Farmers Auto. Ins. Ass’n" on Justia Law

The juvenile court adjudicated J.C. a delinquent child after finding beyond a reasonable doubt that J.C. committed assault with intent to commit sexual abuse. The court of appeals affirmed. At issue before the Supreme Court was whether the juvenile court violated J.C.’s constitutional right to confrontation by admitting the out-of-court statements made by a four-year-old victim to a physician during a medical assessment and to a forensic interviewer. The Supreme Court affirmed, holding (1) admission of the physician’s testimony and report did not violate J.C.’s confrontation rights under either the Sixth Amendment or the Iowa Constitution; and (2) any error in admission of the forensic interviewer’s testimony was harmless beyond a reasonable doubt. View "In re J.C." on Justia Law