Articles Posted in Iowa Supreme Court

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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

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One person’s consent to engage in a sexual encounter with another, obtained through the other actor’s fraudulent misrepresentations that he is someone else, does not constitute a valid consent to engage in the sexual encounter. Defendant was convicted of burglary in the third degree after the trial court concluded that Defendant entered S.G.’s residence with the specific intent to commit sexual abuse. At issue was whether S.G. consented to have sex with Defendant when she agreed to have a sexual encounter with Defendant, who was posing as another person. The lower courts concluded that Defendant’s deception did not establish consent to engage in a sexual encounter. The Supreme Court affirmed, holding that because Defendant’s actions denied S.G. the freedom of choice to engage in the sexual encounter, there was substantial evidence to support the finding that Defendant entered S.G.’s home with the intent to commit sexual abuse. View "State v. Kelso-Christy" on Justia Law

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Practicing massage therapy without a license is not a serious misdemeanor, and therefore, the district court properly dismissed the forfeiture action in this case and ordered the cash returned to the claimants. Responding to complaints by neighbors suspecting prostitution, police raided a spa advertising massage services and seized cash, cell phones, and other property. Thereafter, the State filed a civil in rem forfeiture action alleging that the cash was the proceeds of an unlicensed massage business or prostitution. The district court ruled (1) the State failed to meet its burden to prove prostitution, and (2) practicing massage therapy without a license was not a crime and therefore could not support forfeiture. The district court then dismissed the in rem forfeiture action and ordered the cash returned to the claimants. The Supreme Court affirmed, holding (1) practicing massage therapy without a license is not a serious misdemeanor; and (2) the district court did not err in finding that the State failed to meet its burden of proving the seized funds were the proceeds of prostitution. View "In re Property Seized From Bo Li, Na Tian, And Wei Tian" on Justia Law

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At issue was whether the district court erred in not ordering a competency examination and in excluding evidence when Defendant’s lawyer moved midtrial for the examination of Defendant, who, among other things, stated that she wanted to stab her lawyer in the neck and wanted to kill him. Defendant was charged with willful injury causing bodily injury. During trial, the district court excluded evidence relating to the victim’s prior threatening behavior and her convictions for two assaults and an escape as more prejudicial than probative. Also during trial, Defendant’s attorney moved for a competency examination of Defendant, stating that Defendant was incapable of aiding him in her defense due to Defendant’s paranoid schizophrenia. The district court denied the motion, and Defendant was convicted. The Supreme Court reversed, holding (1) the district court was presented with sufficient reason to order a competency evaluation under Iowa Code 812.3; and (2) the district court properly excluded the challenged evidence about the victim as being substantially more prejudicial than probative. View "State v. Einfeldt" on Justia Law

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The Supreme Court remanded this case involving the resentencing of Defendant, who was convicted of a murder he committed as a juvenile in 1976, holding that the resentencing failed to meet the standards established in State v. Roby, 897 N.W.2d 127 (Iowa 2017). When Defendant was convicted, he was sentenced to lifetime imprisonment without the possibility of parole. In 2016, when he was fifty-four years old and had been in prison for thirty-seven years, Defendant was resentenced under new procedures and sentencing options not available to him in 1976. After a hearing, the district court sentenced Defendant to life imprisonment with eligibility for parole after forty-two years, which meant eligibility for parole at age fifty-nine. The Supreme Court reversed the decision of the district court, holding that the case must be remanded for resentencing in light of Roby, which was decided after the sentencing hearing in district court. View "State v. Mulder" on Justia Law

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In this appeal, Appellant, who at age thirteen shot and killed his mother, raised challenges to Iowa’s youthful offender laws. Specifically, he argued (1) Iowa Code 232.45(7)(a) does not provide statutory authority to try a thirteen-year-old as a youthful offender, (2) Iowa Code 232.45(7) and Iowa Code 907.3A constitute unconstitutional cruel and unusual punishment, and (3) the sentencing court abused its discretion by incarcerating him. The Supreme Court affirmed Appellant’s conviction as a youthful offender and his fifty-year indeterminate sentence with immediate parole eligibility, holding that the district court did not abuse its discretion in sentencing Appellant to a prison term rather than releasing him on probation or placing him in a transitional facility based on an individualized assessment of Defendant under a constitutional statutory scheme. View "State v. Crooks" on Justia Law

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The Supreme Court affirmed the judgment of the district court summarily dismissing Appellant’s application for postconviction relief, holding that the statute of limitations did not bar Appellant’s claims but that Appellant failed to establish a Brady violation or demonstrate a viable newly-discovered-evidence claim. Appellant was found guilty of first-degree murder. This appeal concerned Appellant’s amended second pro se application for postconviction relief, in which he argued, inter alia, that newly discovered evidence required vacation of his original sentence and judgment and that the State committed a Brady violation during trial. The district court granted the State’s motion for summary dismissal, concluding that Appellant’s application was untimely by applying the newly-discovered-evidence test rather than the ground-of-fact test. The Supreme Court affirmed, holding (1) Appellant’s claims were not time barred; but (2) Appellant failed to establish that he was entitled to relief on his claims. View "Moon v. State" on Justia Law

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The Supreme Court reversed the decision of the district court denying Appellant’s motion to dismiss the State’s petition for his civil commitment as a sexually violent predator (SVP) under Iowa Code Ch. 229A, holding that Appellant was not “presently confined” under section 229A.4(1) by virtue of being subject to a chapter 903B special sentence. At the time the State initiated the civil commitment proceedings, Appellant had discharged his sentence for his underlying sexual offense but was serving a special sentence under Iowa Code chapter 903B.2. The State later successfully pursued revocation of Appellant’s release under section 903B.2. Before Appellant was discharged from his incarceration under section 903B.2, the State filed a petition seeking his civil commitment as an SVP under chapter 229A. Appellant filed a motion to dismiss, arguing that he was not “presently confined” under section 229A.4 because he was being confined because of a violation of his special sentence under chapter 903B and that there was no recent overt act that might otherwise support a section 229A.4(2) proceeding. The district court overruled the motion and granted the State’s SVP petition. The Supreme Court reversed, holding (1) Appellant was not “presently confined” under section 229A.4(1); and (2) there was insufficient evidence to find an overt act under section 229A.4(2). View "In re Detention of Ronald Tripp" on Justia Law

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The Supreme Court reversed the decision of the district court denying Appellant’s motion to dismiss the State’s petition for his civil commitment as a sexually violent predator (SVP) under Iowa Code Ch. 229A, holding that Appellant was not “presently confined” under section 229A.4(1), and therefore, the State could not commence an SVP proceeding in the absence of a recent overt act. At the time the State initiated the civil commitment proceedings, Appellant had discharged his sentence for his underlying offense of assault with intent to commit sexual abuse but was residing at the Curt Forbes Residential Facility while serving a special sentence under Iowa Code chapter 903B. Appellant filed a motion to dismiss because he was no longer “presently confined” under section 229A.4(1) and the State had not alleged a recent overt act that might otherwise support a section 229A.4(2) proceeding. The district court denied the motion. The Supreme Court reversed, holding (1) Defendant was not “presently confined” for the purposes of section 229A.4(1); and (2) therefore, the State could not commence an SVP proceeding in the absence of a recent overt act, as required under section 229A.4(2). View "In re Detention of Nicholas Wygle" on Justia Law