Justia Criminal Law Opinion Summaries

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

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 two counts of murder in the first degree and one count of attempted 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, although his jury pool contained five African-Americans, the jury that decided his case contained no African-Americans. 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. Veal" on Justia Law

The Supreme Court affirmed the judgment of the district court imposing a six-day jail sentence and ordering Defendant to pay restitution costs for operating a motor vehicle while her license was barred as a habitual offender, holding that there was no error.On appeal, Defendant challenged the district court's discretion to sentence her to jail and the constitutionality of the sentence, arguing that the court (1) improperly considered her financial situation in imposing the jail sentence over Defendant's requested sentence of a fine or probation, and (2) erred by ordering restitution for court costs and court-appointed attorney fees under recent legislation codified in Iowa Code chapter 910. The Supreme Court affirmed, holding (1) the district court properly evaluated all of the facts before imposing jail time instead of a fine or probation; and (2) Defendant waived any challenges to the court's finding that she had a reasonable ability to pay court costs and court-appointed attorney fees. View "State v. McCalley" on Justia Law

The Supreme Court affirmed Defendant's conviction, rendered after a second jury trial, of second-degree murder, holding that Defendant was not entitled to relief on her allegations of error.Over twenty-five years after the murder in this case, a woman told a cold-case investigator about a murder confession she witnessed as a girl from Defendant. Defendant was ultimately charged with and convicted of murder. The Supreme Court affirmed, holding (1) as to Defendant's argument that the prosecution failed to timely disclose that certain evidence had been determined unsuitable for standard DNA testing, Defendant could have sought DNA testing prior to trial but chose not to do so, and Defendant may still pursue specialized DNA testing in a postconviction proceeding; (2) the twenty-six year delay in prosecution did not prejudice Defendant's ability to make her case, and there was no bad faith on the part of the prosecution; (3) the district court did not err in allowing the jury to scrutinize the credibility of witnesses; and (4) there was sufficient evidence for the jury to find Defendant guilty of second-degree murder. View "State v. Cahill" on Justia Law