Justia Criminal Law Opinion Summaries

Articles Posted in Iowa Supreme Court
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The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing Appellant's petition for postconviction relief, holding that the limitations period for challenging Appellant's convictions had expired and that his resentencing did not bring about a new limitations period for attacking his conviction. In 2011, Appellant pled guilty to second-degree robbery and forgery. In 2015, the district court granted Appellant's motion to correct an illegal sentence. Appellant was resentenced. That same, year, Appellant filed the instant petition for postconviction relief. The State moved for summary judgment, arguing that Appellant's petition was time barred under the three-year statute of limitations in Iowa Code 822.3. The district court dismissed the petition. The court of appeals affirmed. The Supreme Court affirmed, holding that the resentencing of Defendant, which did not affect his underlying convictions, did not restart section 822.3's time clock. View "Sahinovic v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court imposing a seventeen and one-half year mandatory minimum prison term before parole eligibility on Defendant's second resentencing for attempted murder during a home invasion after considering the youth sentencing factors under State v. Roby, 897 N.W.2d 127 (Iowa 2017), holding that there was no error in the sentence and that counsel was not constitutionally ineffective. Defendant was seventeen years old at the time of the crime and was since resentenced twice, once in 2014 and once in 2018, as caselaw on juvenile sentencing evolved. In this appeal from his latest resentencing, Defendant argued that the district court failed to follow the Supreme Court's 2017 mandate to apply Roby and that his counsel was constitutionally ineffective for failing to retain a defense expert on the youth sentencing factors. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in applying the Miller/Lyle/Roby factors and deciding to impose the mandatory minimum sentence; and (2) Defendant's defense counsel had no duty to present a defense expert to testify regarding the Roby factors where Defendant decided to forgo retaining a defense expert. View "State v. Majors" on Justia Law

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The Supreme Court vacated in part and affirmed in part the decision of the court of appeals affirming Defendant's conviction of voluntary manslaughter, holding that the court of appeals correctly found that the district court correctly determined that Defendant was not justified in his use of deadly force because he continued the incident which resulted in the victim's death. On appeal from his conviction of voluntary manslaughter Defendant argued that he was justified in his use of deadly force. The district court rejected the argument, finding that Defendant continued the incident with the victim and could have pursued an alternative course of action by retreating. The court of appeals affirmed, concluding that, while Defendant did not continue the incident with the victim, Defendant was not justified in his use of self-defense because he had an alternative course of action available. The Supreme Court held (1) Defendant continued the incident that resulted in the victim's death, and therefore, substantial evidence supported the district court's finding that Defendant was not justified in his use of deadly force; and (2) Defendant was not entitled to relief on his due process and equal protection claims. View "State v. Fordyce" on Justia Law

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In this appeal challenging several district court rulings in a grand jury proceeding the Supreme Court affirmed in part and reversed in part the judgment of the district court, holding that the State cannot subpoena a criminal defense expert but that the prosecution's contact with the expert does not merit recusal and that there was no basis to quash the grand jury proceeding. Before the grand jury proceedings, the prosecutor contacted an expert witness retained by John Doe, who faced possible criminal charges, and asked the expert her opinions about the matter. When the expert declined to substantively respond, the prosecutor served the expert with a subpoena to appear before the grand jury. Doe moved to quash the subpoena and to disqualify the prosecutor from the proceeding. Doe also sought to quash the grand jury proceedings. The district court denied the motion. The Supreme Court affirmed in part and reversed in part, holding (1) the district court erred in not quashing the grand jury subpoena of Defendant's retained expert; (2) the issuance of the subpoena did not amount to the kind of misconduct that requires the disqualification of the prosecutor; and (3) the district court did not err in declining to quash the grand jury. View "In re 2018 Grand Jury of Dallas County v. Doe" on Justia Law

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In this criminal case in which Defendant was charged with sexually abusing his fourteen-year-old daughter, S.V., the Supreme Court reversed the district court's preliminary ruling that a video recording of a forensic interview of S.V. was not admissible under the residual exception to the hearsay rule, holding that the district court committed two overarching error in its analysis of the preliminary question. After the district court granted Defendant's motion to exclude the forensic interview the State sought a definitive ruling on four of the findings requisite for evidence to be admitted under the residual exception - trustworthiness, materiality, notice, and service of the interests of justice. The district court concluded that the video was not admissible under the residual hearsay exception. The Supreme Court reversed, holding that the district court erred in concluding that it had discretion regarding the admission of the videotape and that the district court's analysis of the preliminary question was contaminated with extraneous considerations relating to confrontation clause jurisprudence. View "State v. Veverka" on Justia Law

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The Supreme Court affirmed Defendant's conviction of boating while intoxicated in violation of Iowa Code 462A.14(1), holding that Iowa Department of Natural Resources (DNR) officers had probable cause to stop Defendant's vessel. Two DNR officers were patrolling Lake Panorama, a recreational lake that was created by damming the Middle Raccoon River, when they stopped Defendant's pontoon boat for displaying blue lights in violation of Iowa Code 462A.12(4). The stop revealed that Defendant, the operator of the boat, appeared to be intoxicated. Defendant was charged with boating while intoxicated. Defendant filed a motion to suppress, arguing section 462A.12(4) did not apply because Lake Panorama was not "waters of this state under the jurisdiction of the conservation commission" and there was no probable cause for the stop. The district court denied the motion to suppress. The Supreme Court affirmed, holding that the officers had probable cause to stop the boat because Lake Panorama belongs to the people of Iowa and is not a privately owned lake as defined in section 462A.2(31). View "State v. Meyers" on Justia Law

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The Supreme Court conditionally affirmed Defendant's convictions but remanded the case for an in camera inspection of the victim's mental health records, holding that the district court erred by failing to conduct the in camera inspection. Defendant was convicted of sexually abusing his granddaughter. During trial, the granddaughter lied about certain facts, and thus the granddaughter's credibility was a key issue. In her deposition, the granddaughter testified that she had disclosed the defendant's abuse to her therapist, a mandatory reporter. Noting that the therapist had not reported the alleged abuse, Defendant filed a motion for the court's in camera inspection arguing that the records likely contained exculpatory impeachment evidence. The district court denied the motion and Defendant's request for an ex parte hearing. The Supreme Court remanded the case, holding that the district court did not err in denying Defendant's motion for an ex parte hearing but erred by failing to conduct the in camera inspection of the granddaughter's mental health records. View "State v. Leedom" on Justia Law

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The Supreme Court affirmed the decision of the district court dismissing Appellant's application for postconviction relief (PCR) claiming a violation of his constitutional right to an impartial jury drawn from a fair cross section of the community, basing his claim on State v. Plain, 898 N.W.2d 801 (Iowa 2017), holding that the holding in Plain does not apply retroactively to cases on collateral review. In 1984, Appellant was convicted of first-degree murder. In 2017, the Supreme Court decided Plain, which addressed the Duren three-part test for evaluating Sixth Amendment fair-cross-section claims and overruled precedent adopting the absolute-disparity method as the exclusive indicator of representativeness under the second prong of Duren. In 2018, Appellant filed the instant PCR application, alleging that he was denied his rights to due process, equal protection, and a fair and impartial trial under the state and federal constitutions. Appellant based his claim on Plain. The district court granted the State's motion to dismiss, concluding that Plain is not retroactive. The Supreme Court affirmed, holding (1) Appellant's Plain claim is time-barred by Iowa Code 822.3; and (2) because Plain's holding is not a watershed rule of criminal procedure, it does not apply retroactively to cases on collateral review. View "Thongvanh v. State" on Justia Law

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The Supreme Court affirmed the decision of the postconviction relief (PCR) court dismissing Appellant's fourth PCR application, holding that under this Court's holding today in Thongvanh v. State, __ N.W.2d __ (Iowa 2020), Defendant's claims based on State v. Plain, 898 N.W.2d 801 (Iowa 2017), failed because Plain is not retroactive. In his PCR application Appellant alleged violations of his rights to equal protection and due process and his right to an impartial jury drawn from a fair cross section of the community. Appellant based his claims on Plain. The trial court granted the State's motion to dismiss, concluding that Plain does not apply retroactively. The Supreme Court affirmed, holding (1) the trial court improperly dismissed Appellant's application based upon a ground neither party raised; and (2) because the new law of criminal procedure announced in Plain does not apply retroactively to cases on collateral review Appellant's PCR application was properly dismissed. View "Jones v. State" on Justia Law

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The Supreme Court vacated the decision of the court of appeals reversing Defendant's conviction on the basis that the district court inadequately instructed the jury on Defendant's justification defense, holding that the court's failure to include "lack of justification" in the marshaling instruction was not prejudicial for ineffective assistance purposes. On appeal, Defendant argued that his trial counsel provided ineffective assistance for failing to object to the marshaling instruction, which did not mention that the State needed to prove the act was done without justification. The Supreme Court disagreed, holding that, in light of the evidence and the instructions as a whole, there was not a reasonable probability of a different outcome if justification had been covered in the marshaling instruction along with the other instructions. View "State v. Kuhse" on Justia Law