Justia Criminal Law Opinion Summaries

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

The Supreme Court reversed Defendant's conviction of sexually abusing his seven-year-old daughter, K.W., holding that the trial court erred by admitting videos of two forensic interviews in which K.W. described the abuse and the admission was not harmless error.Defendant was convicted of sexual abuse in the second degree, enticing a minor, and indecent exposure. On appeal, Defendant argued that the forensic interview videos involving K.W. and played for the jury were inadmissible hearsay and did not fall within any exception to the hearsay rule. The Supreme Court agreed and remanded the case for a new trial, holding that neither interview was admissible under the Court's hearsay rules and that the error was not harmless. View "State v. Skahill" on Justia Law

The Supreme Court conditionally affirmed Defendant's convictions of three misdemeanor drug offenses and remanded this case for further proceedings, holding that remand was required for the district court to apply the standard set forth in State v. Wright, 961 N.W.2d 396 (Iowa 2021).Last term, in Wright, the Supreme Court held that law enforcement officers conducted an unconstitutional seizure and search when they seized and searched garbage bags left out for collection without first obtaining a warrant. In the instant case, Defendant argued that a sheriff's deputy violated his constitutional rights by seizing and searching his trash without first obtaining a warrant. The Supreme Court conditionally affirmed Defendant's convictions and remanded the case for the district court to hold a hearing on Defendant's motion to suppress evidence without consideration of the evidence obtained during the trash pull. View "State v. Kuuttila" on Justia Law

The Supreme Court affirmed the judgment of the district court and the decision of the court of appeals rejecting a sex offender's challenge to two aspects of his lifetime special parole sentence, holding that there was no error.Defendant pled guilty to one count each of sexual abuse in the third degree, lascivious acts with a child, and indecent contact with a child. Following the revocation of his parole, Defendant returned to prison and filed this application for post conviction relief claiming that his plea counsel his ineffectively for failing adequately to inform him of the rules and requirements of his special sentence. The district court denied the application. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Defendant's plea counsel was not constitutionally ineffective; and (2) Defendant's claim that the parole and ex-offender-treatment-program rules were unconstitutional as applied to him was unavailing. View "Doss v. State" on Justia Law