Justia Iowa Supreme Court Opinion Summaries

Upon stopping Defendant for an expired license plate, a police officer smelled marijuana and confiscated a marijuana blunt from Defendant. After arresting Defendant for the possession of marijuana the police searched the passenger compartment where a locked safe was held. An officer opened the safe without a search warrant. Based upon the evidence of the search, Defendant was charged with possession of marijuana with intent to deliver, failure to affix a drug tax stamp, and knowingly transporting a revolver in a vehicle. The district court denied Defendant’s motion to suppress the evidence obtained from a search of the locked container and convicted him of the charges. The Supreme Court reversed, holding that the warrantless search of the safe was not a valid search incident to Defendant’s arrest because Defendant could not access anything inside the vehicle or the locked safe when the search occurred. View "State v. Gaskins" on Justia Law

Defendant was convicted of murder in the second degree for the death of her newborn son (Baby Tyler). The Supreme Court affirmed in part and reversed in part, holding (1) the district court abused its discretion in allowing the medical examiner to testify to the cause and manner of Baby Tyler’s death and in admitting the unredacted autopsy report into evidence; (2) the district court erred in denying Defendant’s motion to suppress evidence obtained by the police during the search of Defendant’s hotel room on the basis that Defendant had no reasonable expectation of privacy in the room because she obtained it for the purpose of committing a crime; and (3) the district court did not err in denying Defendant’s motion to suppress statements she made to police. Remanded for a new trial. View "State v. Tyler" on Justia Law

After a jury trial in 1988, Defendant was convicted of first-degree murder. Defendant was sentenced to life imprisonment without parole (LWOP), as required by Iowa law at that time. At the time she committed the crime, Defendant was seventeen years old. After Miller v. Alabama was decided, the Iowa Governor commuted Defendant’s LWOP sentence, along with the sentences of several other juvenile offenders, to life imprisonment with the possibility of parole after sixty years in prison. After the Iowa Supreme Court decided State v. Ragland, the Court summarily vacated Defendant’s sentence and remanded the case for an individualized sentencing hearing. After a hearing, the district court resentenced Defendant to a definite term of twenty-five years with credit for time served, thereby discharging her from prison immediately and releasing her to correctional supervision for no more than two years. The court also imposed an alternative sentence of life in prison with the possibility of parole after twenty-five years. The Supreme Court vacated the sentence, holding that the district court (1) lacked authority to impose a determinate sentence of twenty-five years, but (2) did have authority to impose a sentence of life in prison with eligibility for parole. View "State v. Louisell" on Justia Law

Defendant was seventeen years old when he committed first-degree murder. Defendant was sentenced to life without parole, as required by Iowa law. Defendant later filed a motion to correct an illegal sentence. Before the trial court heard the motion and shortly after Miller v. Alabama was decided, Iowa’s Governor commuted the sentences of all juveniles previously convicted of first-degree murder to a life sentence with the possibility of parole after sixty years. The trial court then granted Defendant’s motion to the extent his sentence was imposed without “individualized consideration of the circumstances.” The court upheld Defendant’s sentence of life with parole eligibility after sixty years as commuted by the Governor. The Supreme Court vacated the sentence, holding (1) a court must use certain factors when it sentences a juvenile offender for first-degree murder; and (2) because the district court did not have the benefit of this decision when it sentenced Defendant, this case must be remanded for resentencing. View "State v. Seats" on Justia Law

In this battle between two domestic producers of chondroitin sulfate, Plaintiffs filed suit claiming trade-secrets violations against Defendants. Before the Supreme Court was an interlocutory appeal on a discovery issue. The district court entered a protective order requiring the redesignation of Plaintiffs’ standard operating procedures from “attorneys’ eyes only” to “confidential,” which would allow these materials to be disclosed to the defendants themselves. The Supreme Court reversed, holding that, while removing the “attorneys’ eyes only” designation may have been appropriate, the district court’s rationale for ordering redesignation was insufficient. Remanded for further consideration. View "Sioux Pharm, Inc. v. Eagle Labs., Inc." on Justia Law

In 2010, two teenage boys drowned at the Pella Aquatics Center. Plaintiffs, the parents of the children, filed a claim for negligence against the City of Pella under the state-created danger doctrine. The district court granted summary judgment for the City on all of Plaintiffs’ negligence claims with one exception, concluding that the City was entitled to immunity under Iowa Code 670.4(12). The court denied summary judgment on that part of the claim in which the parents alleged that the City’s employee’s acts constituted the criminal offense of involuntary manslaughter. The Supreme Court reversed in part, holding (1) Plaintiffs adequately alleged that the City violated administrative rules constituting criminal offenses under the Iowa Code, and if the City violated these rules, is was not entitled to immunity; and (2) Plaintiffs must prove by a preponderance of the evidence that the City’s acts or omissions constituted involuntary manslaughter to remove it from the immunity granted by section 670.4(1). View "Sanon v. City of Pella" on Justia Law

After Defendant was released on parole, Defendant’s parole officer made a home visit to check on Defendant and conducted a search of Defendant’s bedroom. The search uncovered evidence used to prosecute and convict Defendant of the crime of possession of a controlled substance as a habitual offender. Defendant appealed the denial of his motion to suppress, arguing that the evidence was obtained in violation of the State Constitution. The Supreme Court adopted a special-needs exception that authorizes parole officers to search the home of a parolee without a warrant for purposes of parole supervision and then affirmed, holding that, under the special-needs exception to allow narrowly tailored parolee searches, Defendant’s constitutional rights were not violated in this case. View "State v. King" on Justia Law

In 2013, the Iowa Board of Medicine passed a rule establishing standards requiring physicians who prescribe or administer abortion-inducing drugs to personally perform a physical examination and to be physically present when the abortion-inducing drug is provided. Planned Parenthood challenged the rule as both improperly enacted and in violation of the Iowa Constitution. The district court denied Planned Parenthood’s claims and upheld the rule addressing each of Planned Parenthood’s challenges. The Supreme Court reversed, holding (1) the Board’s rule violates the controlling “undue burden” test announced by the U.S. Supreme Court as the federal constitutional test; and (2) therefore, the rule violates the Iowa Constitution under the less stringent Iowa constitutional standard advanced by the Board. View "Planned Parenthood of the Heartland, Inc. v. Iowa Bd. of Med." on Justia Law

After a jury trial, Defendant was found guilty of theft in the first degree. Defendant appealed the denial of his motion to suppress the search of his trailer, arguing that there was no probable cause to support the search warrant. Defendant also raised numerous claims of ineffective assistance of trial counsel. The court of appeals reversed and remanded the case for a new trial, concluding that there was no probable cause to support the search warrant. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding (1) the district court properly denied the motion to suppress because the issuing judge had a substantial basis for concluding there was probable cause to support the search warrant; and (2) the record was inadequate to reach the merits of Defendant’s ineffective-assistance-of-counsel claims. View "State v. McNeal" on Justia Law

After a jury trial, Defendant was found guilty of second-degree murder. Defendant appealed, arguing that his conviction should be vacated because of juror misconduct and juror bias and because of assorted errors in the district court’s evidentiary rulings. The court of appeals reversed Defendant’s conviction on the issue of juror bias. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the trial court, holding (1) the evidence does not support a finding of juror misconduct in this case; (2) the district court did not abuse its discretion in finding that a juror was not actually biased when, prior to the verdict, the juror clicked “like” on a Facebook comment by the victim’s stepmother which stated, “Give me strength”; and (3) the district court did not commit prejudicial error in its evidentiary rulings. View "State v. Webster" on Justia Law