Justia Criminal Law Opinion Summaries

Articles Posted in Iowa Supreme Court
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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

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The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court convicting Defendant of making a false report alleging the occurrence of the criminal act of carrying weapons, holding that the district court did not err in denying Defendant's request for an instruction on the exceptions to the underlying criminal act of carrying weapons. On appeal, the Supreme Court addressed only whether the definitional instructions to the criminal act of carrying weapons required inclusion of the statutory exceptions. Based on its review of the entire record, the Supreme Court affirmed, holding that the district court's refusal to give Defendant's requested instruction was not erroneous because substantial evidence did not support Defendant's requested instruction on his hypothetical affirmative defense. View "State v. Bynum" on Justia Law

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The Supreme Court affirmed Defendant's sentence imposed in connection with his guilty plea to second-degree murder, holding that where Defendant received an individualized sentencing hearing that addressed the Miller/Lyle/Roby factors Defendant's challenge to his sentence did not constitute a proper motion to correct an illegal sentence. Defendant was sixteen years old when he fatally shot his father. After an individualized sentencing hearing the district court imposed a fifty-year prison sentence with a twenty-year mandatory minimum before parole eligibility and recited its consideration of the sentencing factors. Defendant later filed a motion to correct an illegal sentence and for appointment of counsel, alleging that the district court failed properly to apply the factors set forth in Miller v. Alabama, 567 U.S. 460 (2012), State v. Lyle, 854 N.W.2d 378 (Iowa 2014), and State v. Roby, 897 N.W.2d 127 (Iowa 2017). The district court denied the motion. The Supreme Court affirmed, holding (1) a motion claiming the district court misapplied the Miller/Lyle/Roby factors does not constitute a challenge to an illegal sentence with a concomitant statutory right to counsel; (2) Defendant's challenge to his sentence did not constitute an attack on an illegal sentence; and (3) the district court acted within its authority in sentencing Defendant to the twenty-year mandatory minimum. View "Goodwin v. Iowa District Court for Davis County" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court convicting Defendant of driving while intoxicated, holding that Defendant was not seized for purposes of the Fourth Amendment or Iowa Const. art. I, 8 when the officer approached Defendant on foot the evening of her arrest. An officer watched a vehicle driving suspiciously for several minutes in a residential neighborhood at night. When the vehicle entered a one-lane alley and did not emerge from the alley, the officer approached the stopped vehicle without activating flashers. The officer walked up to Defendant, the driver, to engage in a conversation, which resulted in the officer learning that Defendant was under the influence of alcohol. Defendant was convicted of driving while intoxicated. Defendant appealed, arguing that she was seized in violation of her rights under the Fourth Amendment and article I, section 8. The court of appeals affirmed, concluding that Defendant was not subjected to a seizure in the constitutional sense. The Supreme Court affirmed, holding that no seizure occurred under either the state or federal constitution. View "State v. Fogg" on Justia Law

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The Supreme Court vacated Defendant's sentence and remanded this case for resentencing, holding that where the sentencing court indicated that it lacked "wiggle room" regarding whether to reduce Defendant's sentence, the court failed to exercise its discretion under Iowa Code 901.10(1), which expressly provided the court with discretion to reduce Defendant's sentence. Defendant was convicted of intimidation with a dangerous weapon (count one) and reckless use of a firearm. The court sentenced Defendant to a term of incarceration of up to ten years with a mandatory minimum of five years on count one. The Supreme Court vacated the sentence, holding that the district court was unaware that it had discretion under section 901.10 to reduce the five-year minimum term, and therefore, the court failed to exercise its discretion. View "State v. Moore" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals affirming the judgment of the district court convicting Defendant of willful injury resulting in serious injury, in violation of Iowa Code 708.4(1), holding that this Court had jurisdiction to hear the appeal. After the court of appeals affirmed Defendant's conviction Defendant asked the Supreme Court for further review, which the Court granted on June 18, 2019. On July 1, 2019, an amendment to Iowa Code 814.6(1) became effective. The amendment denies a defendant the right of appeal from a guilty plea, except for a guilty plea to a class "A" felony or in a case where a defendant establishes good cause. At issue in this appeal was whether this Court had jurisdiction of the appeal regarding Defendant's guilty plea or the district court's denial of Defendant's motion in arrest of judgment under the amendment. The Supreme Court affirmed, holding (1) this Court has jurisdiction of this appeal; and (2) the court of appeals decision stands as the final decision as to Defendant's claims on appeal. View "State v. Draine" on Justia Law

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The Supreme Court affirmed Defendant's conviction for carrying a firearm on the grounds of a school, holding that a school district-owned athletic complex that is not contiguous to a classroom building does not qualify as grounds of a school under Iowa Code 724.4B and that the district court did not err in giving the jury an instruction defining "grounds of a school." Specifically, the Supreme Court held (1) the "grounds of a school" as used in Iowa Code 724.4B can include school district-owned athletic facilities that are not contiguous to the classroom building, and there was substantial evidence that the parking lot where Defendant was carrying a firearm qualified as grounds of a school; and (2) the district court properly instructed the jury that the grounds of a school may include recreational and cultural facilities. View "State v. Mathias" on Justia Law

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In this postconviction relief case, the Supreme Court affirmed the judgment of the district court dismissing Appellant's claim without an evidentiary hearing that he was actually innocent of robbery in the first degree and that his conviction should be vacated, holding that Appellant was not innocent in any sense of the word. Appellant pleaded guilty to robbery in the first degree, in violation of Iowa Code 711.21. This case arose out of Appellant's second application for postconviction relief. Appellant argued in his application that he was actually innocent of robbery in the first degree because a BB gun is not a dangerous weapon. The district court summarily denied application. The Supreme Court affirmed, holding (1) actual innocence requires proof of factual innocence with respect to the challenged conviction, including any lesser included offenses; and (2) Appellant did not establish a claim of actual innocence upon clear and convincing evidence that he was factually innocent of the offense of conviction. View "Dewberry v. State" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction for sexual abuse in the second degree and lascivious acts with a child, holding that there was no error in the trial court's evidentiary rulings. Specifically, the Supreme Court held (1) the district court did not abuse its discretion in excluding certain evidence proffered by Defendant; (2) the district court did not err in admitting certain hearsay testimony under the medical diagnosis or treatment exception to the general rule; and (3) even if defense counsel breached an essential duty in failing to object to certain hearsay testimony the admission of the testimony did not amount to constitutional prejudice. View "State v. Walker" on Justia Law

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The Supreme Court affirmed in part and vacated in part the decision of the court of appeals reversing Defendant's conviction and remanding the case for a new trial, holding that trial counsel was not ineffective for failing to object to a jury instruction on the outdated version of the "stand your ground" justification and that the district court did not abuse its discretion in excluding character evidence of the victim. A jury found Defendant guilty of murder. During trial, Defendant asserted the justification of self-defense and defense of others. On appeal, the court of appeals held (1) the district court did not abuse its discretion in excluding certain character evidence of the victim, (2) there was sufficient evidence to support the conviction, but (3) the outdated justification instruction was prejudicial. The Supreme Court vacated the court of appeals' decision in part and affirmed the judgment of the district court, holding (1) trial counsel was not ineffective for not objecting to the instruction because engaging in an illegal activity disqualified Defendant from asserting stand-your-ground justification; and (2) the character evidence at issue was properly excluded because Defendant was unaware of the victim's specific conduct. View "State v. Baltazar" on Justia Law