Justia Criminal Law Opinion Summaries

The Supreme Court reversed the ruling of the district court denying Defendant's motion to dismiss the trial information filed against her, holding that the State violated the speedy indictment rule.On July 5, 2020, Defendant was issued citations in lieu of arrest for several misdemeanors. Defendant's initial appearance happened on September 21, and the State filed its trial information on October 6. Defendant subsequently filed her motion to dismiss, arguing that a citation in lieu of arrest triggers the speedy indictment rule, and the State failed timely to file the trial information within forty-five days of the citations issued against her or even within a sixty-day extended deadline under the Supreme Court's supervisory order. The district court denied the motion to dismiss. The Supreme Court reversed, holding (1) the district court should have counted the forty-five days from the date the citations issued rather than Defendant's initial appearance; (2) the district court erred by ruling that the COVID-19 pandemic provided good cause for the delay in indicting Defendant; and (3) Defendant was entitled to dismissal under Iowa R. Crim. P. 2.33(2)(a). View "State v. Watson" on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's motion to suppress evidence of methamphetamine found in his coat pocket during a traffic stop, holding that the search was unconstitutional, and therefore, the district court erred in denying Defendant's motion to suppress.Defendant was a backseat passenger in a car driven by his brother that was pulled over for a traffic violation. On appeal, Defendant argued that the officer who found methamphetamine in his coat pocket lacked probable cause to search him after a canine indicated drugs were present in the car. The Supreme Court agreed and reversed the denial of Defendant's motion to suppress and vacated his conviction, holding (1) the officers lacked probable cause to arrest Defendant before they searched his person; and (2) therefore, the district court erred by denying Defendant's motion to suppress the evidence found from the unconstitutional search. View "State v. Stevens" on Justia Law

The Supreme Court affirmed Defendant's conviction that arose from the search of her backpack after police officers encountered a stolen car parked with the engine running, holding that the district court did not err in denying Defendant's motion to suppress.Defendant was one of the three backseat passengers in the parked car at issue. The officers observed an open bottle of liquor on the driver's seat and another open container of liquor standing on the rear seat floorboard. When the passengers were directed to exit the vehicle Defendant took her backpack with her. An officer took the backpack, noticed a bag of marijuana, and discovered illicit drugs in a subsequent search. The district court denied Defendant's motion to suppress the results of the search of her backpack on the basis of the automobile exception. The Supreme Court affirmed, holding that the district court properly denied Defendant's motion to suppress. View "State v. Rincon" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of operating while intoxicated after a trial at which Defendant did not appear, holding that a court may conduct a criminal trial on a misdemeanor criminal charge without the defendant present for any portion of the trial.At the first day of Defendant's trial on a misdemeanor charge Defendant requested a continuance, claiming that he could not find a ride to court to attend his trial. The district court denied the motion to continue and, after a two-day trial held to give Defendant the opportunity to appear, found Defendant guilty. The Supreme Court affirmed, holding that the district court did not err in holding that Iowa R. Crim. P. 2.27 permitted trial to proceed without Defendant. View "State v. Hurlburt" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for sexual abuse in the third degree, holding that Defendant was not entitled to relief on his allegations of error.Defendant entered a guilty plea to sex abuse in the third degree. After the district court had imposed a sentence, Defendant filed a pro se motion stating that he wanted to enter an Alford plea instead of a guilty plea. The district court denied the motion. The Supreme Court affirmed, holding (1) the district court did not misinterpret Defendant's pro se postjudgment motion; and (2) there was no defect in Defendant's sentencing hearing. View "State v. Jackson-Douglass" on Justia Law

The Supreme Court affirmed Defendant's conviction for aiding and abetting a robbery, holding that the district court did not err in holding that Defendant failed to prove that his constitutional right to an impartial jury had been violated.On appeal, Defendant, an African-American, argued that his right to an impartial jury under both the United States and Iowa Constitutions was violated because his jury, and even the jury panel, did not contain any African-Americans. The Supreme Court remanded the case to allow Defendant to develop his impartial-jury claims, but the district court ultimately rejected Defendant's arguments. The Supreme Court affirmed, holding that the district court did not err in holding on remand that Defendant failed to prove that his right to an impartial jury had been violated in the proceedings below. View "State v. Lilly" on Justia Law

The Supreme Court affirmed Defendant's sentence to an indeterminate term of incarceration not to exceed five years imposed in connection with his plea of guilty to operating while intoxicated, holding that there was no error.While represented by counsel, Defendant filed a time pro se notice of appeal from his conviction and sentence. Thereafter, Defendant's appellate counsel filed an untimely notice of appeal. In his appeal, Defendant argued that the district court denied him the right of allocution at sentencing and requested remand for resentencing. The Supreme Court affirmed, holding (1) even assuming Iowa Code 814.6A prohibited Defendant from filing a pro se notice of appeal Defendant established good cause to appeal as a matter of right; and (2) Defendant was provided the right of allocution. View "State v. Davis" on Justia Law

The Supreme Court affirmed Defendant's conviction entered upon his Alford plea to the charges of intimidation with a dangerous weapon with intent to injure, willful injury resulting in bodily injury, assault with a dangerous weapon, and driving while barred, holding that the district court had jurisdiction to enter the judgment.In 1948, Congress gave the State criminal jurisdiction over offenses committed by or against "Indians" on the Meskwaki Settlement, and in 2018, Congress took back that jurisdiction. In the instant case, Defendant entered an Alford plea to several charges. After Defendant violated his probation, the Tama County Attorney filed an application for entry of judgment on the counts for which Defendant had previously received deferred judgments. Before the court granted Defendant deferred judgments but before the county attorney sought entry of judgment on those counts Congress repealed the 1948 Act. Defendant filed a motion to dismiss the application for entry of judgment for lack of jurisdiction. The district court denied the motion. The Supreme Court affirmed, holding that Congress's repeal of the state's jurisdiction did not affect criminal cases pending at the time of the repeal. View "State v. Cungtion" on Justia Law

The Supreme Court affirmed the judgment of the district court finding Defendant guilty of domestic abuse assault and criminal mischief in the fourth degree, holding that the district court had jurisdiction to enter the judgment.The conduct giving rise to the charges against Defendant occurred on the Meskwaki Settlement, and both Defendant and the victim were Indians for purposes of the relevant statutory schemes. In 2018, Congress took back the criminal jurisdiction it gave to the State of Iowa in 1948 over offenses committed by or against "Indians" on the Meskwaki Settlement. On appeal, Defendant argued that Congress's repeal of the 1948 Act divested the district court of jurisdiction to enter judgment. The Supreme Court affirmed, holding that Congress's repeal of the State's jurisdiction did not affect criminal cases pending at the time of the repeal. View "State v. Bear" on Justia Law

The Supreme Court affirmed Defendant's conviction for sexual abuse in the second degree arising out of the sexual abuse of his daughter, N.F., holding that the trial court erred in instructing the jury but that the error was not prejudicial.On appeal, Defendant argued that the district court erred in instructing the jury that there was "no requirement that the testimony of a complainant of sexual offenses be corroborated." Defendant argued that the instruction violated Iowa Code 709.6 and unduly emphasized N.F.'s testimony. The court of appeals affirmed, ruling that the instruction was erroneous but that the error was not prejudicial. The Supreme Court affirmed, holding (1) the instruction at issue unduly emphasized the complainant witness's testimony; but (2) Defendant's rights were not injuriously affected and that he had not suffered a miscarriage of justice, despite the erroneous noncorroboration instruction. View "State v. Kraai" on Justia Law