Justia Criminal Law Opinion Summaries

In June 2020, fourteen-year-old K.S. reported to the Sioux City Police Department that Taylor Smith, then twenty-three, had sexually assaulted her, resulting in her pregnancy. A DNA test confirmed Smith as the father. Smith was charged with third-degree sexual abuse, a class “C” felony, under Iowa Code section 709.4(1)(b)(3)(d). After a bench trial, Smith was found guilty. At sentencing, the district court imposed a $1,370 fine, which coincided with the increased minimum fine effective after the offense, and issued a notice of firearm prohibition.The Iowa District Court for Woodbury County sentenced Smith to an indeterminate term not exceeding ten years, imposed a $1,370 fine (suspended), a 15% crime services surcharge (suspended), and a $90 sexual abuse surcharge. The court also issued a notice of firearm prohibition based on Smith’s felony conviction. Smith appealed, arguing that the district court abused its discretion by imposing a fine based on an incorrect statutory range and challenged the firearm prohibition notice as unconstitutional.The Iowa Supreme Court reviewed the case. The court found that the district court misunderstood the applicable fine range, which should have been $1,000 to $10,000, not the increased range effective after the offense. This misunderstanding constituted an abuse of discretion. Consequently, the court vacated the fine portion of Smith’s sentence and remanded for resentencing. Regarding the firearm prohibition notice, the court determined it was not reviewable on direct appeal as it was not a term of Smith’s sentence but rather a collateral consequence of his felony conviction. Thus, the court did not address the constitutional challenges to the firearm prohibition. View "State of Iowa v. Smith" on Justia Law

Gerry Greenland was convicted of attempted murder, assault on a peace officer with intent to cause serious injury while using a dangerous weapon, and simple assault. The incident occurred on May 23, 2019, when Greenland, after a series of confrontations with family members on a farm, used a tractor equipped with bale spears to attack Sheriff Ben Boswell's vehicle. Greenland's actions included ramming the sheriff's car, causing significant damage and endangering the sheriff's life.The Iowa District Court for Decatur County found Greenland guilty of all charges and sentenced him to concurrent terms of incarceration, totaling a maximum of twenty-five years. Greenland appealed, arguing insufficient evidence for his convictions and that the assault conviction should merge with the attempted murder conviction. The Iowa Court of Appeals affirmed the convictions, holding that there was sufficient evidence to support the convictions and that the convictions did not merge because they were based on separate and distinct actions.The Iowa Supreme Court reviewed the case, focusing on whether the convictions for assault on a peace officer and attempted murder should merge under Iowa Code section 701.9. The court held that the convictions did not merge because the assault involved alternative theories, including the use or display of a dangerous weapon, which was not an element of attempted murder. The court disavowed a previous statement in State v. Braggs that suggested it is impossible to commit attempted murder without also committing an assault, clarifying that assault is not always a lesser included offense of attempted murder. The court affirmed the decisions of the Court of Appeals and the District Court. View "State of Iowa v. Greenland" on Justia Law

Benjamin Trane established a private therapeutic boarding school for troubled youth, which was shut down after a police raid. Trane was charged with sexual abuse of a minor, sexual exploitation by a counselor or therapist, and child endangerment. The first two charges involved an underage female victim, while the third charge involved two boys placed in isolation rooms. A jury found Trane guilty on all counts. On direct appeal, the Iowa Supreme Court conditionally affirmed his convictions but remanded for a hearing on a rape shield issue, preserving his ineffective-assistance-of-counsel claims for postconviction relief (PCR) proceedings.In the Iowa District Court for Lee (South) County, Trane alleged ineffective assistance of trial counsel for failing to move to sever the child endangerment count and for not objecting to the marshaling instruction on that count. The district court rejected the severance claim, finding Trane made an informed decision to forego a motion for severance to avoid delay. However, the court ordered a new trial on the child endangerment charge, finding that the marshaling instruction allowed a nonunanimous verdict, thereby prejudicing Trane.The Iowa Supreme Court reviewed the case de novo. The court affirmed the district court's finding that Trane chose to forego a motion to sever the child endangerment count. However, the court reversed the district court's order for a new trial on the child endangerment charge. The court agreed that the marshaling instruction was erroneous but found no prejudice because both child victims were similarly situated, and there was no reasonable probability that jurors did not find Trane guilty of endangering both children. Thus, the court affirmed the denial of relief on the severance claim and reversed the order for a new trial on the child endangerment charge. View "Trane v. State of Iowa" on Justia Law

An officer on patrol stopped a vehicle for a traffic infraction after receiving information that the vehicle’s occupants might have been involved in a drug sale. After initially interacting with the driver, the officer waited for backup before removing the occupants and conducting a search with a drug-sniffing dog, which led to the discovery of a gun. The passenger, Tyre Brown, admitted ownership of the gun and was charged with unlawful possession of a firearm. Brown argued that the officer unlawfully prolonged the stop beyond the time necessary to address the traffic infraction, violating his constitutional rights.The Iowa District Court for Polk County denied Brown’s motion to suppress the evidence obtained from the search. Brown was found guilty after stipulating to a trial on the minutes of testimony. Brown appealed the denial of his motion to suppress, and the Iowa Court of Appeals affirmed the district court’s ruling. The court of appeals concluded that the extension of the stop was permissible under the shared-knowledge doctrine and that the officer had smelled marijuana, justifying further investigation.The Iowa Supreme Court reviewed the case and affirmed the lower courts' decisions. The court held that the shared-knowledge doctrine allowed the officer to act on information provided by another officer who had observed a potential drug transaction, thus justifying the extension of the stop. The court found that the extension of the stop to investigate for drugs did not violate Brown’s constitutional rights. Consequently, the district court’s ruling denying Brown’s motion to suppress was affirmed. View "State of Iowa v. Brown" on Justia Law

Isaiah Duffield was required to register as a sex offender due to a juvenile adjudication for sexual abuse. In April 2022, he was charged with sexual abuse in the third degree, second or subsequent offense, and failure to comply with the sex offender registry. After the charges were severed and amended, Duffield entered a guilty plea to the lesser offense of failure to register, an aggravated misdemeanor. The district court sentenced him to a term of incarceration not to exceed two years and a fine of $1,025, which was suspended. The court ordered the sentence to be served consecutively to a sentence in a separate sexual abuse case.Duffield appealed to the Iowa Court of Appeals, arguing that the district court abused its discretion in imposing the $1,025 fine and failed to state its reasons for imposing consecutive sentences. The court of appeals upheld the fine, reasoning it was within the statutory range and Duffield did not establish any irregularity. However, the court agreed that the district court erred in failing to state reasons for consecutive sentences and remanded the case to a different judge to decide whether the sentences should be served concurrently or consecutively.The Iowa Supreme Court reviewed the case and focused on the consecutive sentencing issue. The court held that the district court erred in failing to state its reasons for imposing consecutive sentences. The court vacated Duffield’s sentence and remanded the case for a plenary resentencing hearing, emphasizing that the resentencing should not be limited to the consecutive sentencing issue alone. The court also concluded that resentencing before a different judge was not required, as there was no taint in the sentencing process. The decision of the court of appeals was vacated, the conviction was affirmed, the sentence was vacated, and the case was remanded for resentencing. View "State of Iowa v. Duffield" on Justia Law

Lukouxs Brown was charged with first-degree murder after allegedly killing a coworker. Before his arraignment, his counsel observed signs of mental illness, including hearing voices and a history of schizophrenia. The district court found probable cause to believe Brown was not competent to stand trial and ordered a psychiatric evaluation. Dr. Arnold Andersen diagnosed Brown with a schizophrenia-like disorder and substance abuse disorders, concluding he was not competent but could potentially be restored to competency. Brown was committed to the Iowa Medical and Classification Center (IMCC) for treatment.After eight months of treatment, Dr. Andersen reported that Brown remained incompetent and unlikely to be restored to competency within a reasonable time. The district court, however, allowed the State to obtain a separate psychiatric evaluation, which concluded that Brown was competent. The district court found Brown competent to stand trial and reinstated the criminal proceedings. Brown filed an interlocutory appeal, arguing the district court erred in its competency determination and in allowing the State to obtain a separate evaluation.The Iowa Court of Appeals reviewed the case de novo, found Brown was not competent, and remanded the case for further treatment. The State sought further review, challenging the standard of review and the district court's decision to allow a separate evaluation. The Iowa Supreme Court reaffirmed the de novo standard of review for competency determinations, emphasizing the protection of constitutional rights. The court also held that Iowa Code does not permit separate psychiatric evaluations at the dispositional phase of competency proceedings. The court vacated the Court of Appeals decision, reversed the district court order, and remanded the case for further proceedings consistent with its opinion. View "State of Iowa v. Brown" on Justia Law

Alison Dorsey ran an in-home daycare in Cass County, Iowa. In 2019, an eleven-week-old baby at her daycare died, leading to Dorsey being charged with first-degree murder and child endangerment resulting in death. Her first trial in Cass County ended in a hung jury. The State then requested a change of venue, which the district court granted, moving the second trial to Pottawattamie County. Dorsey was subsequently convicted of second-degree murder and child endangerment resulting in death.The Iowa District Court for Cass County initially handled the case, where the first trial ended in a mistrial due to a hung jury. Following this, the State filed a motion to change the venue, citing concerns about pretrial publicity and the difficulty of seating an impartial jury in Cass County. The district court granted the motion, and the second trial was held in Pottawattamie County, where Dorsey was convicted. Dorsey appealed the decision, challenging the change of venue among other issues.The Iowa Supreme Court reviewed the case and concluded that the district court abused its discretion by granting the State's motion for a change of venue without attempting to seat a second jury in Cass County. The court emphasized that the district court should have used the voir dire process to assess potential juror bias before deciding to move the trial. The court found that the pretrial publicity was not sufficiently pervasive or inflammatory to justify the venue change without this step. Consequently, the Iowa Supreme Court reversed Dorsey's conviction and remanded the case for a new trial in Cass County. View "State of Iowa v. Dorsey" on Justia Law

Artell Young, a federal supervised releasee, was subject to a search condition allowing federal probation officers to search his person, vehicle, or home upon reasonable suspicion of contraband or release condition violations. After receiving information that Young was dealing drugs and possessing a firearm, federal probation officers searched his home, finding small amounts of crack cocaine, powdered cocaine, and marijuana. The federal authorities turned the case over to Iowa authorities, leading to Young's conviction on several drug offenses.In the Iowa District Court for Polk County, Young moved to suppress the evidence from the search, arguing it violated the Fourth Amendment and article I, section 8 of the Iowa Constitution. The district court upheld the search, citing the "special needs" exception under both the Fourth Amendment and article I, section 8. The court also noted that the search was conducted by federal officers under federal standards, thus not subject to Iowa constitutional standards. Young was convicted by a jury of three counts of possession of a controlled substance and sentenced to six years in prison.The Iowa Supreme Court reviewed the case, focusing on whether the search violated article I, section 8 of the Iowa Constitution. The court held that the constitutionality of the search should be evaluated by the law of the sovereign that conducted the search—in this case, federal law. The court affirmed the district court's decision, concluding that the search was lawful under federal standards and that the evidence obtained was admissible in the state prosecution. The court rejected Young's claim of an illegal search and affirmed his convictions. View "State of Iowa v. Young" on Justia Law

On the night of October 9, 2021, Wichang Chawech was at a bar in Des Moines with friends. After altercations between his friends and other patrons, Chawech pulled out a 9 mm pistol and fired a shot, grazing a man's jaw and fatally wounding a woman. Chawech was charged with first-degree murder, attempted murder, willful injury causing serious injury, and intimidation with a dangerous weapon. He pleaded not guilty and raised defenses of justification, self-defense, and defense of others. The jury found him guilty of lesser included offenses for the first two counts and the charged offenses for the latter two counts. They also found that he was in possession of a dangerous weapon during the offenses.The Iowa District Court for Polk County sentenced Chawech to consecutive terms for counts I, III, and IV, totaling twenty-two years, with a mandatory minimum of ten years due to the dangerous weapon enhancement under Iowa Code section 902.7. The court ordered the sentence for count II to run concurrently. Chawech appealed, arguing insufficient evidence, improper merger of counts II and III, and an illegal mandatory minimum sentence due to the enhancement not being charged in the trial information.The Iowa Court of Appeals affirmed the convictions and sentences, except for agreeing that counts II and III should merge. They vacated the sentence for count II and remanded for an appropriate order. Chawech sought further review, focusing on the sufficiency of evidence and the mandatory minimum sentence.The Iowa Supreme Court reviewed the case, focusing on the mandatory minimum sentence. They concluded that the challenge to the sentencing enhancement was an illegal-sentence challenge, not subject to error preservation principles. However, they found that the trial information and jury instructions met the requirements of Iowa Rule of Criminal Procedure 2.6(6) and the U.S. Constitution. Thus, the mandatory minimum sentence was upheld. The court affirmed the decision of the Court of Appeals in part, vacated in part, and remanded the case for further proceedings consistent with their opinion. View "State of Iowa v. Chawech" on Justia Law

John Feller was charged in 2011 with lascivious acts with a child and third-degree sexual abuse after his stepdaughter reported abuse. He pleaded guilty to two counts of lascivious acts with a child and was sentenced to concurrent five-year prison terms, a ten-year special sentence, and required to register as a sex offender. Initially, he was informed he needed to register for ten years, but later was told he had to register for life due to a procedural error resulting in two separate case numbers.The Iowa District Court for Dubuque County denied Feller's application to modify his sex offender registration requirements, citing his decision to testify by affidavit, his courtroom demeanor, and letters he sent to his daughter. The Iowa Court of Appeals affirmed this decision.The Iowa Supreme Court reviewed the case and found that the district court abused its discretion by considering improper factors, such as Feller's choice to testify by affidavit and his demeanor. The court noted that Feller had completed sex offender treatment, had no criminal charges since his release, and was evaluated as a low risk to reoffend. The court also found that the letters Feller sent to his daughter, which were sent with permission, did not indicate a risk of reoffense.The Iowa Supreme Court vacated the decision of the Court of Appeals, reversed the district court's judgment, and remanded the case for an order granting Feller's application to end his lifetime registration. The court emphasized that Feller's successful adjustment to the community and low risk of reoffense did not justify the continuation of his registration requirements. View "Feller v. State" on Justia Law