Justia Criminal Law Opinion Summaries

The Supreme Court vacated Defendant's convictions for three counts of sexual abuse in the second degree, holding that an erroneous jury instruction prejudiced Defendant's rights.At issue was the district court's instruction to the jury that "[t]here is no requirement that the testimony of an alleged victim of sexual offenses be corroborated." The Supreme Court vacated Defendant's convictions, holding (1) substantial evidence supported the jury's verdict that Defendant committed sexual abuse against B.T. and L.S., and Defendant's remaining attacks on the sufficiency of the evidence were unavailing; but (2) the district court committed reversible error when it gave the jury instruction at issue, and the remaining instructions did not cure the error. View "State v. Mathis" on Justia Law

The Supreme Court affirmed Defendant's convictions but vacated his sentence and remanded the case for resentencing by a different judge, holding that the prosecutor breached the parties' plea agreement by failing to recommend a suspended sentence in the manner required by precedent.Defendant pleaded guilty pursuant to an Alford plea to lascivious acts with a child and indecent contact with a child. The court, without mentioning the plea agreement or the State's recommendation, sentenced Defendant to a combined seven-year prison sentence that was not suspended. Defendant appealed, but the court of appeals dismissed the appeal. The Supreme Court affirmed Defendant's convictions and vacated his sentence, holding (1) the court of appeals erred by dismissing Defendant's appeal for lack of jurisdiction; and (2) the prosecutor breached the plea agreement by not actually recommending that the district court suspend the sentences. View "State v. Davis" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court convicting Defendant of failure to affix a drug tax stamp, interference with official acts causing bodily injury, and possession of heroin following a jury trial, holding that the appellate court did not err in reviewing the sufficiency of the evidence supporting Defendant's conviction.On direct appeal, Defendant challenged the sufficiency of the evidence supporting his conviction for failure to affix a drug tax stamp. Defendant acknowledged that he failed to file a motion for judgment of acquittal to preserve error but contended that the court of appeals could nonetheless review the sufficiency of the evidence. The court of appeals disagreed and affirmed. The Supreme Court affirmed, holding (1) a defendant can challenge the sufficiency of the evidence on direct appeal without first filing a motion for judgment of acquittal; and (2) substantial evidence supported the jury's verdict. View "State v. Crawford" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court convicting Defendant of various drug-related crimes and sentencing him to a total of forty-two years in prison, holding that the district court did not err in denying Defendant's motion to suppress.At issue on appeal was whether the grant of a search warrant to search Defendant's residence and vehicles for evidence of drug dealing had a substantial basis under the totality of the circumstances, as disclosed in the warrant application. The Supreme Court held that the magistrate's determination that the information was sufficient to justify a search warrant for the house had a substantial basis, and therefore, the district court did not err in denying Defendant's motion to suppress. View "State v. Bracy" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court convicting Defendant, following a guilty plea, of lascivious acts with a child, holding that Defendant was not entitled to relief.On appeal, Defendant argued (1) his plea counsel provided ineffective assistance in allowing him to plead guilty without first requesting a competency hearing; and (2) the district court erred by failing, sua sponte, to order a competency hearing. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Defendant's claim of ineffective assistance of counsel was not a legally sufficient reason that could serve as "good cause" to establish a statutory right to appeal; and (2) the district court did not err by failing, sua sponte, to order a competency hearing. View "State v. Newman" on Justia Law

The Supreme Court affirmed Defendant's plea-based conviction for a drug offense, a class "C" felony, holding that Defendant's challenges to the validity of his plea were unavailing.At issue was this Court's supervisory orders promulgated in response to the COVID-19 global pandemic temporarily allowing written pleas. On appeal, Defendant argued that the rules of criminal procedure, precedent, and due process required an in-person plea colloquy in open court and that the supervisory orders violated due process and separation of powers principles. The Supreme Court affirmed, holding (1) Defendant met the good cause requirement by presenting questions of first impression as the the validity of this Court's supervisory orders and Defendant's written guilty plea to a felony; but (2) this Court's supervisory orders are lawful exercises of this Court's constitutional and inherent authority during the pandemic. View "State v. Basquin" on Justia Law

The Supreme Court reversed Defendant's conviction for sexually abusing a client during a Reiki treatment session, holding that the district court erred in allowing evidence about the investigation by the Iowa Board of Massage Therapy into allegations that Defendant had inappropriately touched other clients, and Defendant was entitled to a new trial.On appeal, Defendant argued that the district court erred by introducing evidence about the Board's investigation that ultimately led to the loss of his massage license and by allowing testimony from his complaining former clients. The Supreme Court reversed, holding that the district court properly admitted some evidence from Defendant's former massage clients about their experiences but improperly failed to identify which issues that were truly disputed, leading to the admission of more testimony from the former clients than was permissible. Because the errors were not harmless, the district court remanded the case for a new trial. View "State v. Thoren" on Justia Law

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