Justia Criminal Law Opinion Summaries

The Supreme Court reversed the judgment of the trial court convicting Defendant of two counts of suborning perjury and two counts of obstructing prosecution, holding that a defendant cannot violate Iowa Code 719.3 and "induce" a witness to fail to testify by unsuccessfully offering or attempting to produce the witness's unavailability.While being detained on a parole violation and pending charges Defendant told his former girlfriend that she should not go to "church" and that she would not be in trouble if she did not go to church. The girlfriend understood Defendant to be making a coded request that she should not attend a subpoenaed deposition in which she was expected to give testimony incriminating Defendant. Although the girlfriend attended the deposition and gave testimony incriminating Defendant. Based on his coded requests, Defendant was charged with suborning perjury and obstructing prosecution. The jury found Defendant guilty. The Supreme Court reversed, holding that there was insufficient evidence to support Defendant's convictions. View "State v. Hall" on Justia Law

The Supreme Court affirmed Defendant's conviction of harassment in the first degree, holding that the district court did not err on remand in denying Defendant's motion challenging the representativeness of the jury pool under the fair-cross-section requirements under the Sixth Amendment.On appeal from his conviction, Defendant, an African-American, argued that his constitutional right to an impartial jury had been violated because his jury panel contained only one Africa-American out of forty-nine potential jurors that appeared at the courthouse for trial. The Supreme Court remanded the matter to give Defendant an opportunity to develop his impartial jury arguments, but the district court rejected Defendant's more developed claims on remand. The Supreme Court affirmed, holding that the district court did not err in holding on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury. View "State v. Plain" on Justia Law

The Supreme Court reversed Defendant's conviction for possession of cocaine and affirmed her conviction of interference with official acts, holding that the warrantless entry into Defendant's apartment to arrest her was unlawful.After Defendant was charged, she filed a motion to suppress, alleging that law enforcement officers made an illegal entry into her home and then used the information obtained from the legal entry to secure a search warrant. The motion to suppress was denied, and the trial court found Defendant guilty of the interference charge and possession of cocaine charge. The Supreme Court reversed in part, holding (1) evidence related to Defendant's conviction of possession of cocaine obtained from the unlawful warrantless entry into her apartment must be suppressed; and (2) Defendant's conviction of interference with official acts was sufficiently attenuated from the officers' unlawful entry to permit admission of Defendant's own illegal conduct under the "new crime exception" to the exclusionary rule. View "State v. Wilson" on Justia Law

The Supreme Court affirmed Defendant's conviction of harassment in the first degree, holding that the conviction was supported by substantial evidence and that the district court did not abuse its discretion in its evidentiary rulings or in imposing sentence.Specifically, the Supreme Court held (1) Defendant's harassment conviction was a final judgment appealable as a matter of right; (2) there was sufficient evidence to support the conviction; (2) the district court did not abuse its discretion in excluding a series of certain text messages the victim had sent to her and in disallowing Defendant from testifying about her knowledge of the cycle of domestic abuse; and (3) the district court did not abuse its sentencing discretion. View "State v. Lacey" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court denying Defendant's application for postconviction relief, holding that there was no error.Defendant pleaded guilty to child endangerment resulting in death. The court imposed an indeterminate sentence of up to fifty years with immediate parole eligibility. Defendant later filed the instant application for postconviction relief, alleging that counsel provided ineffective assistance in giving parole advice and in failing to object to an in-chambers proceeding. The district court denied the application. The Supreme Court affirmed, holding that Defendant failed to show that her plea counsel breached an essential duty or that she was prejudiced by the in-chambers proceeding. View "Sothman v. State" on Justia Law

The Supreme Court vacated the decision of the court of appeals reversing Defendant's convictions of possession of methamphetamine with intent to deliver and possession of marijuana, holding that the court of appeals made three legal errors in reviewing the jury's verdict.After the jury considered the evidence and arguments at trial it found Defendant guilty of all charges. The court of appeals reversed, concluding that the conviction was not supported by substantial evidence. The Supreme Court vacated the court of appeals' decision, holding that the court (1) misstated the law of possession; (2) relied upon a long-rejected distinction between direct-evidence and circumstantial-evidence cases in concluding that there was insufficient evidence to establish Defendant was in constructive possession of controlled substances; and (3) improperly reasoned that the convictions were the result of an impermissible stacking of inferences. View "State v. Jones" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Petitioners' applications for postconviction relief, holding that Petitioners' challenges to the State's allocation of its resources in the prison system were without merit.Petitioners were several male inmates serving time for sex-related offenses. Due to limits on resources, inmates were eligible for the sex offender treatment program, the completion of which was a requirement to be considered meaningfully for parole, only as the inmate neared his tentative discharge date. Petitioners brought applications for postconviction relief, arguing that this circumstance violated their constitutional due process rights. The district court denied relief. The Supreme Court affirmed, holding that the existing waiting list prioritizing admission to treatment based on tenantive discharge date, was a reasonable way to decide when an offender gets admitted to treatment and that the district court did not err in denying Petitioners' applications for postconviction relief. View "Bomgaars v. State" on Justia Law

The Supreme Court reversed Defendant's conviction of sexual abuse of a child, his granddaughter, holding that the district court erred by excluding evidence that another person, a teenager who testified for the State, sexually abused the victim.On appeal, Defendant argued (1) the Supreme Court should overrule State v. Pearson, 514 N.W.2d 452 (Iowa 1994), which would result in the reversal of his conviction; and (2) the district court erred in applying the "constitutional rights" exception to the rape shield law, Iowa R. Evid. 5.412(b)(1)(C). The Supreme Court reversed, holding (1) this Court declines to overrule Pearson; and (2) excluding Defendant's cross-examination of his granddaughter and the teenager about their relationship violated Defendant's rights under the Confrontation and Due Process Clauses and the constitutional rights exception to the rape shield law. View "State v. Montgomery" on Justia Law

The Supreme Court affirmed in part and vacated in part the decision of the court of appeals affirming Defendant's conviction and sentence, holding that the district court erred in allowing the State to amend the trial information one week prior to the day of trial.The State charged Defendant with, among other offenses, assault causing bodily injury. One week prior to trial, the State moved to amend the trial information to charge Defendant with willful injury causing bodily injury. The district court allowed the amendment, concluding that the elements were substantially similar and the underlying facts remained the same. Defendant was subsequently found guilty. The court of appeals affirmed. The Supreme Court reversed in part and remanded the case for further proceedings, holding the court of appeals erred in relying on State v. Brisco, 816 N.W.2d 415 (Iowa Ct. App. 2012), to conclude that the charge of willful injury causing bodily injury was not wholly new and different from assault causing bodily injury. View "State v. Vandermark" on Justia Law

The Supreme Court vacated Defendant's conviction of assault while using or displaying a dangerous weapon, holding that the district court erred in allowing the State to amend the trial information on the day of trial.The State filed a trial information charging Defendant with assault causing bodily injury. On the first day of trial, the State moved to amend the charge of assault causing bodily injury to assault while using or displaying a dangerous weapon. The district court allowed the amendment, and a jury found Defendant guilty of the amended charge. The Supreme Court reversed, holding that the amended trial information charged a wholly new and different offense within the meaning of Iowa R. Crim. P. 2.4(8)(a), and the district court erred in allowing the amendment. View "State v. Allen" on Justia Law