Justia Criminal Law Opinion Summaries

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

The Supreme Court conditionally affirmed Defendant's drug-related convictions, second offense, holding that, consistent with this Court's opinion in State v. Wright, __ N.W.2d __ (Iowa 2021), filed today, law enforcement officers conducted an unreasonable seizure and search when they seized and searched garbage bags left out for collection without first obtaining a warrant.On appeal, Defendant argued that two sheriff's deputies violated his federal and state constitutional rights to be free from unreasonable searches and seizures when they seized and searched a trash bag outside Defendant's residence without first obtaining a warrant. The Supreme Court agreed, holding that remand was required in order for the district court to hold a hearing on Defendant's motion to suppress evidence without consideration of the evidence and information obtained during a trash pull used to support their warrant application. View "State v. Hahn" on Justia Law

The Supreme Court denied Appellant's delayed appeal of the postconviction court's summary judgment denial of his third application for postconviction relief, holding that this Court lacked jurisdiction over the matter.Appellant was convicted of first-degree burglary and first-degree robbery and sentenced to two twenty-five-year sentences to run concurrently. Later, Appellant filed a third application for postconviction relief. The postconviction court granted the State's motion for summary judgment, ruling that the claims were barred by the statute of limitations. The Supreme Court affirmed, holding that Appellant failed to present the Court with a basis to grant a delayed appeal six months after the deadline. View "Anderson v. State" on Justia Law

The Supreme Court rejected Defendant's constitutional challenge to Iowa Code 321J.16 and joining the majority of courts holding that it is not an unconstitutional penalty to admit into evidence Defendant's refusal to submit to a breath test, holding that the best course is to overrule State v. Pettijohn, 899 N.W.2d 1, 38-39 (Iowa 2017).After denying Defendant's motion in liming to exclude evidence of her refusal to submit to a breathalyzer test Defendant was convicted of driving while intoxicated. On appeal, Defendant challenged the constitutionality of section 321J.16, which allows into evidence a defendant's test refusal. Specifically, Defendant argued that Pettijohn, which held that a search warrant was required for a breathalyzer test of an intoxicated boater, should be extended to drunken driving cases. The Supreme Court (1) overruled Pettijohn and held that search warrants are not required for breathalyzer tests of either boaters or drivers when law enforcement has probable cause to believe that intoxicated boating or driving has occurred; and (2) it is not an unconstitutional penalty to admit into evidence a defendant's refusal to submit to a breath test. View "State v. Kilby" on Justia Law

The Supreme Court conditionally affirmed Defendant's convictions and remanded for the district court to hold a hearing on Defendant's motion to suppress evidence, holding that the peace officer in this case conducted an unreasonable search and seizure by taking a citizen's opaque trash bags left outside for collection, opening the trash bags, and rummaging through the papers and effects contained therein.Despite an ordinance making it unlawful for any person to take solid waste placed out for collection, Officer Brandon Heinz, without probable cause or warrant, took Defendant's garbage bags and searched through them during the dark of night. Heinz subsequently applied for and was granted a search warrant based on the evidence obtained from the warrantless seizure and search of Defendant's trash bags. Defendant was subsequently charged with several drug-related counts. The district court denied Defendant's motion to suppress, and Defendant was found guilty. The court of appeals affirmed. The Supreme Court held that Heinz conducted an unreasonable search and seizure in violation of Iowa Const. art. I, 8 and that remand was required for a suppression hearing without consideration of the evidence obtained during the trash pulls used to support the warrant application. View "State v. Wright" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for operating while intoxicated on two alternative theories, holding that neither Iowa law nor the Iowa Constitution guarantee a suspected drunk driver the right to a private phone consultation with counsel before deciding whether to take a blood alcohol test.On appeal, Defendant challenged the denial of his motion to suppress, arguing that the officials at the jail where he was detained impermissibly refused to allow him a private, unrecorded conversation with his attorney. The Supreme Court affirmed, holding (1) Iowa Code 804.20 does not provide the detainee a right to a private and confidential telephone consultation; and (2) the Iowa Constitution does not provide a detainee with a right to a confidential telephone conversation. View "State v. Sewell" on Justia Law

The Supreme Court dismissed Defendant's appeal challenging the factual basis supporting his guilty plea to a drug offense, holding that Defendant failed to establish good cause to pursue a direct appeal as a matter of right.Defendant pled guilty to three drug-related offenses and was sentenced to an indeterminate term of incarceration. On appeal, Defendant argued (1) there was not a factual basis supporting one of his convictions; (2) his counsel provided constitutionally ineffective assistance; and (3) Iowa Code section 814.6 and 814.7 are unconstitutional. The Supreme Court dismissed the appeal, holding (1) section 814.6(1)(a)(3) is constitutional and governs this appeal; and (2) Defendant did not establish good cause to pursue this appeal as a matter of right. View "State v. Treptow" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Appellant's cause of action for unjust enrichment against the State, holding that the district court correctly dismissed the matter as an unlawful collateral attack on Appellant's criminal conviction.Appellant pleaded guilty to speeding in a construction zone. Appellant later filed a lawsuit challenging the authority of Iowa Department of Transportation (IDOT) officers to issue traffic citations and contesting the payments the State collected from fines resulting from convictions on unauthorized IDOT-issued citations. The district court held (1) the IDOT officers, at the time, lacked authority to stop Defendant's vehicle; and (2) Appellant's unjust enrichment claim was an improper collateral attack on his conviction, warranting dismissal. The Supreme Court affirmed, holding that the district court correctly concluded that Appellant's unjust enrichment claim was an improper collateral attack on his speeding ticket conviction. View "Rilea v. State" on Justia Law