Justia Criminal Law Opinion Summaries

In a case before the Supreme Court of Iowa, the defendant, Robert Clark Geddes, was charged with trespass as a hate crime. The defendant had trespassed onto various properties, leaving behind anonymous notes that urged the residents to "Burn that gay flag." The homes targeted by the defendant were displaying LGBTQ+ flags or decals. Geddes appealed his conviction, arguing that the evidence was insufficient and that his convictions violated his rights to free speech and due process.The court rejected the defendant's arguments and affirmed his convictions. The court ruled that Geddes was not being punished for his speech, but rather for his conduct—trespassing onto properties with the intent to commit a hate crime. The court found that the statute under which Geddes was convicted does not criminalize speech, but rather conduct with a specific intent—namely, trespassing on property because of the property owner or possessor's association with persons of a certain sexual orientation. The court also found that there was sufficient evidence to support Geddes's conviction.The court held that the defendant's conduct of surreptitiously entering onto properties to post his harassing notes was not protected under the First Amendment rights. The court noted that hate crime laws are designed to punish conduct, not expression, and Geddes's motive or intent led to the more serious criminal consequence. The court also rejected the defendant's argument that the trespass law was vague or overbroad, finding that it provides sufficient guidance to those enforcing it and does not intrude on protected freedoms. View "State of Iowa v. Geddes" on Justia Law

In the case before the Supreme Court of Iowa, the court reviewed the trial and conviction of Robert Krogmann for attempted murder and willful injury causing serious injury. This was Krogmann's second trial after his initial conviction was overturned on appeal due to an improper asset freeze that interfered with his defense rights. In the second trial, Krogmann appealed his conviction on multiple grounds.The court held that the court of appeals erred in concluding that the trial court should have admitted a video recording of Krogmann's interview with law enforcement. Although the video was not hearsay and should have been admitted, the court held that the exclusion of the video did not affect Krogmann’s substantial rights and was therefore harmless error. The video would not have materially aided Krogmann's diminished capacity defense.The court further held that the trial court did not err in instructing the jury that assault, an element of the crimes charged against Krogmann, is a specific-intent crime, and that diminished responsibility can negate the intent element of assault.The court also upheld the trial court's decision to exclude evidence of a $1.5 million civil settlement between Krogmann and the victim, finding that the evidence was not relevant to the issues in the case.However, the court found that the trial court erred in allowing a witness to testify to the ultimate issue of intent, stating that it is the job of the court, not a paid expert, to explain criminal law to the jury.Lastly, the Supreme Court of Iowa agreed with Krogmann's contention that the court erred in awarding him to pay an expert witness’s fees and expenses in excess of the $150 per day cap in Iowa Code section 622.72.The Supreme Court of Iowa vacated the decision of the court of appeals, affirmed the district court judgment, granted and sustained in part the writ of certiorari, and remanded the case for redetermination of costs. View "Iowa v. Krogmann" on Justia Law

The Supreme Court affirmed Defendant's conviction for operating while intoxicated (OWI) and eluding, holding that the district court did not abuse its discretion in admitting evidence about a preliminary breath test (PBT) and that the evidence was sufficient to support the convictions.During the underlying jury trial, the district court admitted a portion of an officer body cam video showing Defendant agreeing to a PBT, after which the edited video jumped to Defendant's arrest for OWI. The Supreme Court held (1) this juxtaposition of the PBT and arrest violated Iowa R. Evid. 5.403 because it had minimal probative value while strongly implying that Defendant had failed the PBT, but the error was harmless; and (2) there was sufficient evidence to sustain Defendant's eluding conviction. View "State v. Amisi" on Justia Law

The Supreme Court held that the district court and court of appeals did not err in finding that Defendant was not seized before the law enforcement officer who eventually arrested him discovered his probable intoxication and that Defendant was lawfully detained on grounds of probable intoxication.In his motion to suppress, Defendant argued that he had been seized when the officers partially blocked him in while he was parked in a parking lot, trained a spotlight on him, and shined flashlights into his car from both sides. The trial court concluded that Defendant had not been "seized" before the police discovered his intoxication. The court of appeals affirmed, concluding that the officers' actions were not "sufficiently coercive" to constitute a seizure. The Supreme Court affirmed, holding that Defendant was lawfully detained because the officers did not seize him before his intoxication was observed. View "State v. Wittenberg" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the trial court denying Defendant's motion to suppress and convicting him of firearm violations, holding that the law enforcement officer who arrested Defendant did not unlawfully seize Defendant.After a woman called the police to report a suspicion car parked in front of her home an officer responded in a patrol car and pulled alongside the parked car. The officer walked over to talk to the driver, smelled a strong odor of burnt marijuana, and searched Defendant and the car. In his suppression motion, Defendant argued that the officer did not unlawfully seize him. The court of appeals concluded that the trial court did not err in denying the motion to suppress. The Supreme Court affirmed, holding that the officer's conduct in this case did not constitute a seizure, and once the officer detected the odor of burnt marijuana he had a lawful ground to detain and search Defendant and the car. View "State v. Cyrus" on Justia Law

The Supreme Court reversed the judgment of the district court granting Defendant's motion to suppress evidence obtained during a traffic stop, holding that because Defendant's license plate cover violated Iowa Code 321.37 it was reasonable for Iowa State Patrol troopers to stop his SUV, the stop was not unconstitutional, the exclusionary rule did not apply, and there were no grounds to suppress evidence from the stop.Because Defendant's rear license plate was shrouded with a tinted plastic cover troopers found it difficult to read the plate. The troopers stopped Defendant to warn him that the cover violated Iowa law and during the stop uncovered evidence leading to Defendant's charges for operating while intoxicated and child endangerment. The district court granted Defendant's motion to suppress, concluding that the traffic stop was unconstitutional. The Supreme Court reversed, holding (1) the traffic stop was constitutional because the license plate cover violated an Iowa traffic statute; and (2) therefore, the district court erred in suppressing evidence from the stop. View "State v. Griffin" on Justia Law

The Supreme Court affirmed Defendant's judgment of sentence and confirmed what it held in State v. Wilbourn, 974 N.W.2d 58 (Iowa 2022) and State v. Treptow, 960 N.W.2d 98 (Iowa 2021), that if good cause is lacking to bring a criminal appeal, an appellate court has no jurisdiction, and the appeal must be dismissed.Defendant pleaded guilty to second-degree theft and was sentenced to three consecutive five-year sentences of imprisonment. The court of appeals affirmed the sentence after finding good cause to address Defendant's challenge to his sentence under Iowa Code 814.6(1)(a)(3). The court declined to address Defendant's assertion that there was an inadequate factual basis to support his guilty plea to theft based on a lack of good cause. The Supreme Court affirmed in part and vacated the judgment in part, holding (1) because the court of appeals had jurisdiction over this appeal it should have also addressed Defendant's challenge to the factual basis supporting his guilty plea; and (2) even though this Court had jurisdiction over Defendant's appeal, it lacked the authority to resolve his factual basis challenge. View "State v. Rutherford" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant, following a jury trial, of murder in the second degree, obstructing prosecution, and abusing a corpse, holding that the district court did not abuse its discretion by giving a verdict-urging instruction in this case.On appeal, Defendant argued that the district court coerced the jury's verdict by giving a verdict-urging instruction after the court was informed that the jury was divided 11-1 and that one juror was not following the judge's instructions. The court of appeals vacated Defendant's convictions, concluding that the jury's verdict was coerced. The Supreme Court vacated the court of appeals' opinion and affirmed Defendant's convictions, holding that the court of appeals erred in its coercion analysis and that the jury's verdict was not coerced under the circumstances. View "State v. Church" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of first-degree robbery and willful injury causing serious injury, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued, among other things, that the district court imposed an illegal and unconstitutional sentence by failing to merge his two convictions. The Supreme Court affirmed, holding (1) there was sufficient evidence to convict Defendant of willful injury causing serious injury; and (2) the district court did not err by not merging the willful injury causing serious injury conviction with the first-degree robbery conviction because there are additional elements of willful injury causing serious injury that are not encompassed within the elements of first-degree robbery under the dangerous weapon alternative. View "State v. Cook" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions for first-degree robbery and willful injury causing serious injury, holding that Defendant was not entitled to relief on his allegations of error.Defendant's convictions stemmed from his role in the baseball bat attack of a man outside his apartment complex, and a surveillance camera captured some of the altercation. The Supreme Court held (1) there was sufficient evidence to convict Defendant of first-degree robbery based on the victim's testimony and the corroborating surveillance video evidence of the attack; (2) the district court's failure to merge the convictions was not erroneous; and (3) Defendant was not prejudiced by the district court's decision to continue the trial for nine days due primarily to juror illness. View "State v. Brown" on Justia Law