Justia Criminal Law Opinion Summaries

Articles Posted in Iowa Supreme Court
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The Supreme Court affirmed Defendant's conviction of a class C felony drug offense and prison sentence, holding that immigration status per se is not an appropriate sentencing consideration but that immigration status may be taken into account to the extent it affects an otherwise relevant sentencing factor. Defendant, a Mexican national, pled guilty to a felony drug offense and was placed on immigration hold for likely deportation. Defendant sought probation, but the district court imposed a prison sentence, expressing the view that it would not be feasible to order probation for a defendant who was going to be deported to Mexico. The Supreme Court affirmed, holding (1) a defendant's immigration status may not be the basis for a sentence, but to the extent it affects an otherwise relevant sentencing factor it may be taken into account; and (2) on the record, the district court properly determined that probation would not be appropriate for someone whose probation would need to be supervised in Mexico. View "State v. Valdez" on Justia Law

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The Supreme Court conditionally remanded this case involving Defendant's conviction for assault with attempt to commit sexual abuse; pattern, practice, or scheme to engage in sexual exploitation by a counselor or therapist; and child endangerment, holding that the trial court should have conducted a Iowa R. Evid. 5.412 hearing to determine whether one of the alleged victims made false accusations of sexual abuse against her parents. Defendant, the former owner of a school for troubled youth, was convicted of two offenses involving acts of sexual misconduct against a former female student and a third offense relating to the school's physical mistreatment of two former male students. The Supreme Court affirmed on condition and remanded with directions, holding (1) the evidence was sufficient to sustain Defendant's convictions; (2) the district court did not err in declining to consider ineffective assistance claims as part of motion for new trial proceedings; but (3) the district court erred by failing to conduct a rule 5.412 hearing before or during trial to determine whether the female student made false accusations of sexual abuse against her adoptive or foster parents. View "State v. Trane" on Justia Law

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The Supreme Court affirmed the district court's judgment convicting Defendant of first-degree murder, holding that Defendant's Sixth Amendment rights of confrontation or compulsory process were not violated when the district court refused to permit Defendant during trial to call a witness who intended to invoke his Fifth Amendment privilege against self-incrimination on all questions. In his retrial for murder, Defendant sought to call a witness so that the jury could him him "take the Fifth" and thus infer the witness's guilt. The district court refused to permit Defendant to call the witness because, pursuant to State v. Bedwell, 417 N.W.2d 66 (Iowa 1987), the jury is not entitled to draw inferences favorable to the defense from a witness's decision to exercise his constitutional privilege. The court of appeals reversed, distinguishing Bedwell on grounds that the witness had testified in Defendant's prior trial and the district court failed to ascertain the scope of his privilege question by question. The Supreme Court vacated the court of appeals' decision and affirmed the district court, holding (1) under the circumstances, Bedwell provides a categorical rule against compelling the witness to assert his Fifth Amendment privilege in front of the jury; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "State v. Heard" on Justia Law

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The Supreme Court reversed the magistrate's dismissal of three pending misdemeanor charges against Defendant based on the legal proposition that Iowa courts lack jurisdiction over crimes committed on the Meskwaki Settlement, holding that the State may assert jurisdiction involving crimes committed on tribal lands by non-Indians involving either victimless crimes or non-Indian victims. An officer of the Meskwaki Nation Police Department filed two cases in district court alleging that Defendant committed the misdemeanor crimes of trespass, possession of drug paraphernalia, and violation of a no-contact order while on the Meskwaki Settlement. The magistrate dismissed the charges, concluding that recent federal legislation removed state jurisdiction for crimes committed on the Settlement. The Supreme Court reversed the dismissal of the charges and vacated the remaining portions of the district court's order, holding that the recent legislation left undisturbed state court criminal jurisdiction involving criminal acts involving non-Indians. View "State v. Stanton" on Justia Law

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The Supreme Court vacated Defendant's sentence in connection with her Alford plea to four counts of child endangerment entered pursuant to a plea agreement, holding that the State breached the plea agreement with Defendant and that Defendant's original counsel was ineffective for failing to object. On appeal, Defendant argued that, pursuant to the plea agreement between the parties, the State was obligated to jointly recommend a deferred judgment. Instead, at the sentencing hearing, the State recommended, and the court imposed, a two-year suspended prison sentence without objection from defense counsel. The court of appeals affirmed Defendant's conviction and sentence. Thereafter, amendments to Iowa Code 814.6 and 814.7, enacted in Senate File 589, were signed into law and became effective. The State argued before the Supreme Court that Senate File 589 foreclosed relief in this appeal. The Supreme Court held (1) sections 814.6 and 814.7, as amended, do not apply to a direct appeal from a judgment and sentence entered before July 1, 2019; and (2) the State breached the plea agreement and Defendant's counsel was ineffective. The Supreme Court remanded the case for the State's specific performance of the plea agreement and resentencing by a different judge. View "State v. Macke" on Justia Law

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The Supreme Court affirmed in part and vacated in part the decision of the court of appeals affirming Defendant's conviction and sentence for child endangerment resulting in serious injury, holding that the part of the sentencing order regarding restitution must be remanded for the district court to impose restitution consistent with the Court's decision in State v. Albright, 925 N.W.2d 144 (Iowa 2019). On appeal, Defendant argued that his counsel provided ineffective assistance and that the district court erred in ordering him to pay restitution without first determining his reasonable ability to pay. The court of appeals affirmed. The Supreme Court held (1) the court of appeals' decision stands as this Court's final decision regarding Defendant's ineffective assistance of counsel claims; and (2) because the district court did not have the benefit of the procedures outlined in Albright when it entered its order regarding restitution the sentencing order must be remanded. View "State v. Moore" on Justia Law

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The Supreme Court affirmed the judgment of the district court ruling in favor of the Iowa Parole Board (Board) as to Petitioner's action challenging the manner in which the Board considers whether persons convicted of offenses while a juvenile should be granted parole, holding that the district court did not err. Petitioner was sixteen years old when he committed the crime of kidnapping. In his petition for judicial review brought pursuant to the Iowa Code 17A.19, Petitioner sought a declaratory judgment that a variety of substantive and procedural rights are required when a juvenile offender is considered for parole. The district court denied the Board's motion to dismiss and then proceeded to rule in favor of the Board on the merits. The Supreme Court affirmed, holding (1) dismissal was not appropriate without analyzing the merits of the underlying constitutional claims; (2) the statute and rules governing the parole process can be applied in a constitutional manner through the required Graham-Miller lens; (3) a juvenile offender has a liberty interest in the proper application of Graham-Miller principles under the Due Process Clause; and (4) Petitioner failed to establish any constitutional violations. View "Bonilla v. Iowa Board of Parole" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence discovered by law enforcement after a stop of Defendant's automobile that resulted in her arrest for driving while barred, holding that the district court did not err in denying Defendant's motion to suppress. Specifically, the Court held (1) Defendant was not subject to an impermissible pretextual seizure because the subjective motivations of an individual officer in making a traffic stop are irrelevant as long as the officer has objectively reasonable cause to believe the motorist violated a traffic law; (2) Defendant's stop was supported by reasonable suspicion; and (3) Defendant's claim that her trial court provided ineffective assistance for declining to challenge whether the vehicle's license plate was malfunctioning failed on the merits. View "State v. Haas" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress all evidence obtained after a stop of his vehicle, holding that the subjective motivations of an individual officer for making a traffic stop are irrelevant as long as the officer has objectively reasonable cause to believe the motorist violated a traffic law. A police officer observed Defendant making an improper turn and, after following Defendant, noticed Defendant's vehicle had an improperly functioning license plate light. The vehicle information for the registered owner - who was not Defendant - revealed the registered owner's affiliation to gang activity. The officer pulled Defendant over and discovered Defendant's open beer container in the center cupholder. Defendant filed a motion to suppress, arguing that the stop was unconstitutional because the officer's reasons for the stop were not the traffic violations themselves. The Supreme Court affirmed, holding that traffic stops for traffic violations are reasonable regardless of the officer's subjective motivation. View "State v. Brown" on Justia Law

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In this wrongful death action the Supreme Court affirmed the order of the district court entering judgment for Defendant, holding that Plaintiffs did not preserve any issues for appellate review. A jury determined that Defendant was not liable for wrongful death and awarded no damages. The district court subsequently entered judgment for Defendant. Plaintiff filed a posttrial combined motion for new trial and change of venue, alleging a violation of a granted motion in limine, undue influence of Defendant over the jury, and other trial court errors. The district court denied the post trial motion. Plaintiff appealed. The Supreme Court affirmed, holding that Plaintiff was deemed to have waived and abandoned her posttrial motion, and therefore, Plaintiff did not preserve any issues for appellate review. View "Freer v. DAC, Inc." on Justia Law