Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's prison sentence, holding that Defendant forfeited any rights to enforce the plea agreement in this case when he breached it.The plea agreement provided that Defendant would plead guilty to third-degree burglary, be released with supervision until sentencing, and be free to argue for probation at sentencing. Defendant, however, absconded after the plea hearing and failed to appear for the sentencing hearing. Defendant was arrested approximately seven months later. Defendant's counsel sought a suspended sentence and probation, and the State advocated for a term of imprisonment. The district court sentenced Defendant to an indeterminate term of imprisonment not to exceed five years. The Supreme Court affirmed, holding that the State did not breach the plea agreement in this case. View "State v. Jordan" on Justia Law

The Supreme Court reversed Defendant's conviction of operating while intoxicated (OWI), holding that Mitchell v. Wisconsin, 588 U.S. __, __, 139 S. Ct. 2525 (2019) (plurality opinion), applies to cases of suspected driving while under the influence of controlled substances, in addition to alcohol-related cases.Defendant caused an accident while driving recklessly. Defendant, who was injured, was taken to the hospital strongly smelling of marijuana. A police officer dispatched to the hospital performed a blood test of Defendant, who was sedated, after a medical professional certified that Defendant was unable to consent or refuse blood testing. Defendant filed a motion to suppress the testing, but the motion was overruled. Defendant appealed, arguing that the warrantless blood draw violated Iowa Code 321J.7, the Fourth Amendment to the federal Constitution, and Iowa Const. art. I, 8. The Supreme Court reversed, holding (1) the State complied with section 321J.7; (2) because the parties did not have an opportunity to make a record under the Mitchell standard, the case must be remanded; and (3) article I, section 8 does not provide greater protection from warrantless blood draws than the Mitchell standard. View "State v. McGee" on Justia Law

The Supreme Court dismissed Defendant's appeal challenging his guilty plea to theft in the second degree, holding that Defendant's challenge to the constitutionality of new legislation limiting his ability to appeal was unavailing.The legislation at issue limits the ability of a defendant to appeal as a matter of right from a conviction following a guilty plea and directs that ineffective assistance of counsel claims be presented and resolved in the first instance in postconviction relief proceedings. On appeal from his conviction of theft in the second degree Defendant argued that the new legislation violated his right to equal protection of then laws and the separation of powers doctrine. The Supreme Court affirmed, holding that Defendant's constitutional challenges failed. View "State v. Tucker" on Justia Law

The Supreme Court vacated the judgment of the district court sentencing Defendant to consecutive sentences of incarceration in connection with his plea of guilty to possession of a controlled substance, third or subsequent offense, and driving while barred, holding that the district court improperly speculated that Defendant was working under the influence.The district court accepted Defendant's guilty pleas and proceeded to a sentencing hearing. The district court sentenced Defendant to consecutive sentences of incarceration not to exceed two years for both charges after noting that it was not safe for Defendant to be working in a day care center if he was under the influence. The court of appeals affirmed. The Supreme Court vacated the sentence, holding that the district court's speculation about Defendant working under the influence was improper based on the information it had before it. View "State v. Fetner" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the determination of the district court that evidence of approximately twenty instances of Defendant's cell phone use while in a vehicle over an approximately three-year period was inadmissible as habit evidence.Plaintiff was riding his bicycle when he was struck with the vehicle driven by Defendant. Plaintiff filed a negligence petition against Defendant. Before trial, Defendant filed a motion in liming asking the district court to prevent Plaintiff from making any argument that she had a habit of driving while distracted. The district court refused to admit evidence of Defendant's cell phone use while driving to prove a habit. The jury returned a verdict for Defendant. The court of appeals affirmed. The Supreme Court affirmed, holding that proffered specific instances of Defendant's cell phone use while driving were not numerous enough to constitute habit evidence. View "Holmes v. Pomeroy" on Justia Law

The Supreme Court affirmed Defendant's convictions but reversed the illegal portion of Defendant's sentence, holding that Defendant's sentence was illegal because it specified a duration for sex offender registry obligations. Defendant was convicted of first-degree burglary, third-degree sexual abuse, domestic abuse assault causing bodily injury, and operating a vehicle without its owner's consent. The court of appeals affirmed the convictions but held that a portion of his sentence was illegal. The Supreme Court affirmed, holding (1) the district court did not err in admitting any prior act evidence; (2) Defendant's conviction of first-degree burglary and third-degree sexual abuse do not merge; and (3) Defendant's sentence was illegal because it specified a duration for sex offender registry obligations. View "State v. Goodson" on Justia Law

The Supreme Court dismissed this appeal from a 2019 order that declined to modify Defendant's court-ordered restitution in a criminal case, holding that Senate File 457 (S.F. 457) required dismissal of this appeal.Defendant was serving a life sentence for kidnapping when he requested a restitution hearing, alleging that the state had failed to comply with a prior court order finding that Defendant lacked a reasonable ability to pay attorney fees. The district court denied relief. The Supreme Court dismissed Defendant's appeal, holding that Defendant's remedies in district court had not been exhausted and that, under section 80 of S.F. 457, this Court was precluded from hearing this appeal. View "State v. Holmes" on Justia Law

The Supreme Court affirmed Defendant's conviction for assault "us[ing] any object to penetrate the genitalia or anus of another person" in violation of Iowa Code 708.2(5), holding that there was sufficient evidence to support the conviction and that Defendant's remaining claims of error were unavailing.Defendant's conviction stemmed from his act of penetrating the victim's vagina with his finger while the victim was unconscious. On appeal, Defendant argued that his finger did not constitute an "object" under section 708.2(5). The Supreme Court affirmed, holding (1) the evidence was sufficient to prove that Defendant committed assault by penetration with an object; and (2) the district court did not err in restricting Defendant from impeaching the complaining witness with otherwise inadmissible evidence. View "State v. Zacarias" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction and sentence for two counts of indecent contact with a child, holding the trial court did not err by allowing the jury to see a video recording of a child's forensic interview where the child discussed Defendant's sexual abuse of her.Long before the time the child reported the abuse and long before criminal charges were brought, the video interview at issue was recorded. During trial, the State filed a notice of intent to present the video interview. The video was shown the the jury after defense counsel cross-examined the child victim and suggested that she had fabricated her criminal trial testimony. After showing the jury the video the district court instructed the jury that the video could only be used as a tool to assess the child's credibility. Defendant appealed, arguing that the court's admission of the interview was in error. The Supreme Court affirmed, holding that the video was admissible as a prior consistent statement. View "State v. Fontenot" on Justia Law

The Supreme Court affirmed Defendant's conviction for child endangerment and remanded the case to the district court for resentencing, holding that the court of appeals properly vacated the restitution portion of the sentencing order due to the court's failure to make a proper reasonable-ability-to-pay determination regarding Defendant's restitution costs.The court of appeals affirmed Defendant's conviction but vacated the restitution portion of Defendant's sentence. The Supreme Court affirmed, holding (1) certain challenged statements fell under the excited utterance exception to the rule against hearsay; (2) Defendant's argument that her Confrontation Clause rights were violated by the admission of certain evidence was not preserved; and (3) the proper resolution of Defendant's appeal of the restitution order was to remand the case to the district court with instructions to allow Defendant to follow the procedures required by Iowa Code 910.2A and then to hold a hearing under section 910.7 on the remaining restitution issues in this case. View "State v. Dessinger" on Justia Law