Articles Posted in Iowa Supreme Court

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The Supreme Court reversed the judgment of the trial court convicting Defendant of operating while intoxicated (OWI), holding that the stop of the van in which Defendant was a passenger violated Iowa Const. art. I, section 8. After responding to a dispatch report of a vehicle in a roadside ditch, officers saw a van pass by on the road. Discovering that the van’s license plate was registered to another member of the same household that the vehicle in the ditch had been registered to, the officers followed the van and pulled it over. The driver of the car that had gone into the ditch was riding as a passenger in the van. That person, Defendant, was convicted of OWI. Defendant appealed the denial of his motion to suppress, arguing that the stop of the van was not permissible under the community caretaking doctrine. The Supreme Court agreed and reversed Defendant’s conviction and sentence, holding that the community caretaking exception did not apply under article I, section 8. View "State v. Smith" on Justia Law

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At issue was whether the three-year statute of limitations in Iowa Code 822.3 applies where a postconviction relief (PCR) petitioner files an untimely second petition for PCR alleging that counsel for his timely filed first petition for PCR was ineffective. The district court concluded that the second petition’s allegations of ineffective assistance of postconviction counsel were not grounds to avoid the three-year statutory bar. The court of appeals affirmed, citing the Supreme Court’s decision in Dible v. State, 557 N.W.2d 881, 883, 886 (Iowa 1996). The Supreme Court qualified Dible and held that where a PCR petition alleging ineffective assistance of trial counsel has been timely filed per section 822.3 and there is a successive PCR petition alleging that postconvcition counsel was ineffective in presenting the ineffective-assistance-of-trial-counsel claim, the timing of the filing of the second PCR petition relates back to the timing of the filing of the original PCR petition for purposes of Iowa Code section 822.3 if the successive PCR petition is filed promptly after the conclusion of the first PCR petition. The Court therefore vacated the court of appeals and reversed the decision of the district court and remanded the case. View "Allison v. State" on Justia Law

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The Supreme Court adopted a tighter legal framework for warrantless inventory searches and seizures of automobiles under Iowa Const. art. I, 8 than provided under the recent precedents of the United States Supreme Court. In his challenge to the search and seizure provision of article I, section 8 of the Iowa Constitution Defendant noted that a number of state courts have rejected the approach of the United States Supreme Court - which generally provides that warrantless inventory searches of automobiles are permissible if they are conducted pursuant to law enforcement policies that govern the decision to impound the vehicle and the nature and scope of any subsequent search - in favor of a more restrictive approach that sharply limits warrantless searches and seizures of automobiles. The Supreme Court ultimately held (1) the police should advise the owner or operator of the vehicle of the options to impoundment, and when impoundment is necessary, personal items may be retrieved from the vehicle, and if the vehicle is impounded, containers found within the vehicle will not be opened but stored for safekeeping as a unit unless the owner or operator directs otherwise; and (2) the impoundment and search in this case was outside the bounds of any constitutionally permissible local impoundment and inventory policy. View "State v. Ingram" on Justia Law

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The Supreme Court declined to hold that the felony-murder rule violates due process under the Iowa or United States Constitution when it is applied to juvenile offenders pursuant to a theory of aiding and abetting. Defendant was a juvenile and unarmed when he participated in a marijuana robbery. A coparticipant, who had brought a gun to the crime, killed the robbery victim. Defendant was convicted of first-degree murder and sentenced to life imprisonment with immediate parole eligibility. The Supreme Court affirmed the conviction and sentence, holding (1) applying the felony-murder rule to juvenile offenders based on a theory of aiding and abetting is constitutional; (2) Defendant’s sentence did not constitute cruel and unusual punishment, either categorically or as applied to Defendant; (3) the trial court provided the jury with proper instructions regarding the types of assault required to establish the forcible felony robbery element of felony murder; and (4) the record was inadequate for the Court to address some of Defendant’s claims of ineffective assistance of counsel, and the remainder of Defendant’s ineffective assistance of counsel claims were without merit. View "State v. Harrison" on Justia Law

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Under the Iowa Constitution, a community caretaking seizure of a vehicle must be undertaken for genuine community caretaking purposes. In this case, a law enforcement officer was justified under the “community caretaking function” exception to the warrant requirement of the Fourth Amendment and Iowa Const. art. I, 8 when he pulled behind a vehicle stopped by the side of a highway after 1 a.m. with its brake lights engaged and activated his emergency lights. Defendant was charged with operating while intoxicated, first offense. Defendant moved to suppress the evidence obtained as a result of the stop of his vehicle, arguing that the stop of his vehicle and person was unconstitutional. The trial court denied the motion. The Supreme Court affirmed, holding that the conduct of the deputy in this case was not unconstitutional because the officer acted out of a genuine community caretaking motivation. View "State v. Coffman" on Justia Law

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Defendant was entitled to a new trial after the State limited his access to his personal funds by freezing his assets prior to trial. Defendant was convicted of attempted murder and willful injury causing serious injury. Before trial, the trial court granted the State’s application for an order freezing all of Defendant’s assets. The order granting the freeze did not cite any authority or legal basis for the asset freeze. After Defendant’s convictions were affirmed on appeal he filed a postconviction relief (PCR) application arguing that the order freezing his assets was illegal and imposed for an improper purpose. Defendant also argued that the asset freeze adversely impacted his ability to defend himself by, among other things, inhibiting his ability to select his counsel of choice. The PCR court denied relief, and the court of appeals affirmed. The Supreme Court reversed and remanded for a new trial, holding (1) the asset freeze was unlawful; (2) defense counsel’s failure to properly challenge the freeze breached an essential duty; and (3) the consequences of the asset freeze violated Defendant’s constitutional right to be master of his defense, a structural error. View "Krogmann v. State" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals finding substantial evidence that the juvenile in this case committed a sex offense by force and that the sex offender registry requirements imposed upon the juvenile by law did not violate the prohibition against cruel and unusual punishment under either the state or federal Constitutions. The juvenile court found the juvenile committed a sex offense by force and required him to register as a sex offender under Iowa Code 692A.103(4), the mandatory sex offender registry statute. The court of appeals affirmed. The Supreme Court affirmed, holding that automatic, mandatory registration for certain juvenile sex offenders is punishment but that such registration does not amount to cruel and unusual punishment. View "In re T.H." on Justia Law

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The Supreme Court reversed the district court’s decision granting postconviction relief to Defendant on his claim that he had received ineffective assistance of counsel from an immigration attorney when he tried to get a driver’s license, holding that no right to counsel had attached when Defendant went to the driver’s license station. Defendant’s visit to the driver’s license station triggered a criminal investigation and ultimately a conviction for a previously committed fraudulent practice. The district court set aside Defendant’s guilty plea and sentence, holding that Defendant’s counsel, who was representing Defendant in a pending federal immigration case, breached his essential duty to provide necessary advice to Defendant. The Supreme Court reversed, holding that neither the right to counsel under Iowa Const. art. I, 10, nor the United States Constitution Sixth Amendment right to counsel had attached at the time Defendant’s attorney advised Defendant regarding getting a driver’s license, as this was before any investigation or criminal proceedings had begun. View "Hernandez-Ruiz v. State" on Justia Law

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The Supreme Court reversed the rulings of the district court in this appeal from the denial of Defendant’s application for postconviction relief and remanded for further proceedings. As part of his application, Defendant alleged that between the time of his convictions for two counts of sexual abuse and his sentencing, the police department was investigating claims of sexual abuse that his victim was making against local gang members. Defendant further alleged that the ongoing investigation was concealed from his trial counsel and that, prior to sentencing, the police determined that the claims made against the gang members were false. The district court denied disclosure of the investigative reports to Defendant and ruled that all evidence and testimony related to the alleged false claims of the victim would be excluded from the postconviction-relief trial. The Supreme Court reversed and ordered the disclosure of these investigative reports, holding that the reports were relevant, and Defendant advanced a good-faith factual basis demonstrating how the information was reasonably calculated to lead to admissible evidence germane to an element or fact of the claim or defense. View "Powers v. State" on Justia Law

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The Supreme Court reversed the ruling of the district court denying Defendant’s motion for credit for time served based on the time he spent in the Bridges of Iowa (Bridges) program, holding that Bridges qualified as a community correctional residential treatment facility, and therefore, Iowa Code 907.3(3) mandated that Defendant be given credit for time served in the facility. Defendant pled guilty to third-degree burglary and was placed on supervised probation for two years. The conditions of Defendant's probation required that he complete the treatment program at Bridges. Defendant participated in the Bridges program for 126 days. Defendant's probation was later revoked, and Defendant pled guilty to second-degree theft. In sentencing Defendant, the district court did not provide credit for the 126 days Defendant was at Bridges, concluding that Bridges was not a correctional or mental health facility under Iowa Code 903A.5(1), nor an alternate jail facility or a community correctional residential treatment facility under section 907.3(3). The Supreme Court reversed for the reasons set forth above. View "State v. Hensley" on Justia Law