Justia Criminal Law Opinion Summaries

In 1994, Dorsey shot and killed a woman when he was 18 years and five days old. He was found guilty of murder in the first degree and was sentenced to a mandatory term of life in prison without the possibility of parole.In Dorsey’s fifth attempt to obtain post-conviction relief, the Iowa Supreme Court affirmed his sentence, rejecting Dorsey’s argument that the sentence violates his state constitutional right to be free from “cruel and unusual punishment.” He argued the state constitution prohibits imposing a mandatory punishment on a young adult offender and instead requires the district court to hold an individualized sentencing hearing before imposing any sentence and that his life sentence without the possibility of parole is grossly disproportionate to the crime. Considerations of efficiency and certainty require a bright line separating adults from juveniles. There is nothing unique about the facts of this case that raise an inference of gross disproportionality. Dorsey’s willful, deliberate, and premeditated murder of an unarmed woman in her own home justifies the most severe sentence allowed under our law. View "Dorsey v. State of Iowa" on Justia Law

The Supreme Court affirmed Defendant's conviction of possession of a controlled substance under Iowa Code 124.401(5), holding that there was no error in the proceedings below.When Defendant was pulled over by an Iowa trooper for speeding she provided the trooper with a current Patient Medical Marijuana Registry Identification Card issued by the Arizona Department of Health Services, which allowed her to legally purchase and possess a limited amount of marijuana for medical use in Arizona. The registry card required a written certification completed by a licensed Arizona physician, but the certification was not provided to the trooper. On appeal from her convictions, Defendant challenged the district court's determination that the registry card and written certification were not a valid prescription or order and barring their admissions during trial. The Supreme Court affirmed, holding (1) the district court properly excluded from evidence the registry card and written certification because they were not a valid prescription or order; and (2) Defendant was not entitled to relief on her remaining allegations of error. View "State v. Middlekauff" on Justia Law

The Supreme Court affirmed the decision of the court of appeals and the district court judgment convicting Defendant of murder in the first degree, holding that a verdict-urging instruction did not improperly coerce the jury verdict.Specifically, the Supreme Court held (1) a jury instruction that explains reasonable doubt in terms of "hesitate to act" is legally adequate, but because the inclusion of "hesitate to act" language was not legally required in this case the district court did not abuse its discretion by refusing to add the discretionary instruction; and (2) the verdict-urging instruction given in this case lacked content that this Court had previously disapproved of, but the jury was not improperly coerced by the court's verdict-urging instruction. View "State v. Davis" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the order of the district court granting Defendant's motion to suppress evidence of drugs seized following a pat-down, holding that law enforcement's conclusion that Defendant possessed drugs met the bar to establish probable cause.The district court concluded that the officer's inability to discern the type of the drugs in the packaging before removing them from Defendant's pocket required suppression of the evidence. The court of appeals reversed, determining that the evidence was sufficient under the plain-feel exception to the warrant requirement that Defendant believed the package contained heroin, powder cocaine, or crack cocaine, despite not knowing which one. The Supreme Court affirmed, holding that the evidence established probable cause for the officer to have arrested Defendant for drug possession. View "State v. Hunt" on Justia Law

The Supreme Court reversed Defendant's conviction and sentence for ongoing criminal conduct and Defendant's conviction for robbery in the first degree, holding that Defendant's conduct did not satisfy the requirements for ongoing criminal conduct.Defendant was indicted for his participation in a three-week crime spree that involved using a torch to cut into an ATM, robbing a bank, and using the proceeds to buy and subsequently sell marijuana. Defendant was convicted of first-degree robbery and ongoing criminal conduct and sentenced to twenty-five years on each. The Supreme Court vacated the convictions at issue, holding (1) the State presented insufficient evidence to establish the continuing basis element of the ongoing criminal conduct charge; and (2) Defendant's conviction for robbery in the first degree is vacated and the case remanded for entry of judgment and sentencing for robbery in the second degree. View "State v. Crawford" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting and sentencing Defendant but remanded for entry of a nun pro tune order to correct the fine suspended in the written sentencing order to the amount orally pronounced at the sentencing hearing.Pursuant to a plea agreement, Defendant pleaded guilty to several drug offenses. The district court imposed a thirty-year prison sentence with the mandatory minimum reduced by Defendant's guilty plea. On appeal, Defendant argued that the district court failed to consider its discretion for a lower mandatory minimum sentence under Iowa Code 124.413(3) and that there was a discrepancy between the fine stated orally at sentencing and in the written order. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion by imposing the agreed-upon prison sentence; and (2) the fine should be reset through a nunc pro tunc order on remand. View "State v. Wilbourn" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court granting Defendant a new trial at which a key witness associated with missing records would be barred from testifying, holding that the unavailability of the records did not entitle Defendant to a retrial.Defendant was convicted of solicitation to commit murder. At issue on appeal was whether the district court erred in denying Defendant's requests to obtain the privileged counseling records of two of the State's key witnesses on the grounds that the records might contain critical exculpatory information. The court of appeals reversed and remanded with instructions for the district court to review the counseling records. On remand, the two federal agencies believed to have the records refused to turn them over. The district court presumed the records contained exculpatory information and granted Defendant a new trial. The court of appeals reversed and remanded the case. The Supreme Court affirmed, holding that the trial court erred in allocating the discovery burden and ordering a new trial without requiring Defendant to show that he’d exhausted every available avenue to lawfully obtain the medical records for the court to review. View "State v. Retterath" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress and convicting him of possession of methamphetamine, second offense, holding that law enforcement acted reasonably under the Fourth Amendment and Iowa Const. art. I, 8 by ordering Defendant out of the vehicle.Defendant was the passenger in a vehicle that was stopped for speeding. Officers asked Defendant to exit the vehicle in order to facilitate the lawful arrest of the back-seat passenger. Officers then asked if they could check Defendant for weapons. The officer's pat-down revealed a methamphetamine pipe and a baggie containing methamphetamine. Defendant moved to suppress the evidence obtained after the exit order, which the district court denied. The Supreme Court affirmed, holding (1) Defendant's consent was voluntary based on the totality of the circumstances; and (2) the Iowa Constitution does no require that subjects of a search must be informed of their right to decline the search in order for their consent to be voluntary. View "State v. Hauge" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court denying Defendant's motion to suppress and convicting him of being a felon in possession of a firearm, holding that there was no error in the denial of the motion to suppress.Defendant was a passenger in a Lyft vehicle that was stopped for traffic violations. The officers recognized Defendant from past eluding incidents and ordered him out of the vehicle to conduct a pat-down for weapons. Defendant moved to suppress the evidence, arguing that the officer lacked reasonable and articulable facts to justify ordering him out of the vehicle and patting him down. The district court denied the motion to suppress, and the court of appeals affirmed. The Supreme Court affirmed, holding that the officer had reasonable suspicion to justify ordering Defendant out of the vehicle and subsequently patting him down for weapons. View "State v. Williams" on Justia Law

In this criminal action, the Supreme Court affirmed the ruling of the district court on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury, holding that Defendant's conviction of second-degree murder stands.On appeal, Defendant, an African-American, argued that his right to an impartial jury under the United States Constitution had been violated because his jury pool contained only two African-Americans, one of whom was later excused. The Supreme Court made refinements to how a defendant must prove a fair-cross-section constitutional violation and remanded the case to give Defendant an opportunity to develop his impartial-jury arguments. On remand, the district court rejected Defendant's further-developed claims. The Supreme Court affirmed, holding that the district court did not err in ruling on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury. View "State v. Williams" on Justia Law