Justia Criminal Law Opinion Summaries

In this interlocutory appeal, the Supreme Court affirmed the order of the district court prohibiting Defendant from filing any additional pro se supplemental documents in a postconviction relief proceeding, holding that the district court did not err.Under Iowa Code 822.3A, postconviction relief applicants are prohibited from filing "any pro se document, including an application, brief, reply brief, or motion, in any Iowa court." At issue was the constitutionality of the law, which was passed in the spring of 2019 and effective July 1, 2019, to pending postconviction relief proceedings and postconviction relief appeals. Defendant in this case argued that section 822.3A violated his constitutional rights. The Supreme Court rejected the argument, holding that there is no constitutional right to file pro se supplemental documents in postconviction relief proceedings and postconviction appeals. View "Hrbek v. State" on Justia Law

The Supreme Court reversed the decision of the district court denying Appellant's application to modify his sex offender registry requirements, holding that the district court erred in penalizing Defendant for his years of successful adjustment to sex offender registration.In 2000, Defendant pled guilty to two counts of sexual abuse in the third degree, making him subject to lifetime as a sex offender. Defendant was released in 2009 and, since then, had been on the registry without any violation of the registration requirements. In 2019, Defendant filed an application for modification of his sex offender registry requirements pursuant to Iowa Code 692A.128. The district court denied the application. The Supreme Court reversed, holding that the district court abused its discretion by not putting Defendant's STATIC-99R score into proper context and improperly relied on the absence of a stipulation with the Iowa Department of Correctional Services approving of a modification of the registration requirement. View "Becher v. State" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing the trial information in this case, holding that the State's delay in arresting and formally charging Defendant did not amount to a due process violation.By late 2017, law enforcement had focused on Defendant as the suspected perpetrator of a robbery. However, the police did not file a criminal complaint against Defendant until August 2018 and did not serve an arrest warrant until September 2019. In October 2019, after it was finally filed, the district court dismissed the trial information, concluding that Defendant's due process rights under the Fifth Amendment were violated. The Supreme Court reversed, holding that the State's delay in arresting and charging Defendant did not violate the speedy indictment rule or violate due process where Defendant failed to show actual prejudice. View "State v. Smith" on Justia Law

The Supreme Court vacated the order of the district court denying Defendant's application under Iowa Code 692A.128 to modify the requirement that he register as a sex offender, holding that because the district court did not have the benefit of the guidance provided in this opinion, the case must be remanded.Defendant was convicted of three counts of lascivious acts with a child. As a result of his convictions, Defendant was a tier III sex offender and subject to lifetime registration as a sex offender. Defendant filed an application for modification of his sex offender registration requirements, but the district court denied the application, concluding that Defendant did not present a compelling reason for release from the registry. The Supreme Court vacated the decision and remanded for further proceedings, holding that the district court improperly considered a number of factors in the modification proceeding. View "Fortune v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of sexual abuse in the third degree, holding that there was no trial error and that there was sufficient evidence to support the conviction.Specifically, the Supreme Court held (1) the district court did not abuse its discretion when it prohibited Defendant from cross-examining the victim about a prior sexual incident between Defendant and the victim; (2) the district court did not err when it submitted Instruction No. 20 to the jury; and (3) Defendant's claim that the evidence offered by the victim was too vague and insufficient to constitute substantial evidence to support the jury's verdict was without merit. View "State v. Donahue" on Justia Law

The Supreme Court reversed the judgment of the district court granting Defendant's motion to suppress physical evidence and statements based on a police officer's alleged promise of leniency, holding that there was no improper promise of leniency.The officer at issue initiated a Terry stop on a public stop after observing Defendant make a possible drug buy. The officer told Defendant if he cooperated he would not be arrested that day but may be arrested later. Three months after Defendant handed over crack cocaine and marijuana the officer charged him with possession. The trial court granted Defendant's motion to suppress, concluding that the evidence obtained after the officer promised leniency was fruit of the poisonous tree. The Supreme Court reversed, holding that the officer did not improperly promise leniency. View "State v. Hillery" on Justia Law

The Supreme Court affirmed the judgment of the district court determining that Jason Carter was civilly liable for the death of his mother, Shirley Carter, holding that the district court did not abuse its discretion.Jason was civilly accused by his father and brother of intentionally shooting his mother. After a jury determined that Jason was civilly liable the State charged Jason with first degree murder. As a result of discovery from that criminal proceeding, Jason was acquitted murder. Jason later filed a second petition to vacate the judgment based on newly discovered evidence. The district court dismissed the petition. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion in denying Jason’s motion for continuance, judgment notwithstanding the verdict, first petition to vacate the judgment, and motion for recusal; (2) properly denied Jason's motion to quash a subpoena to the Iowa Department of Criminal Investigations; and (3) lacked jurisdiction to hear this second petition to vacate the judgment because it was untimely. View "Carter v. Carter" on Justia Law

The Supreme Court affirmed Defendant's conviction of driving while intoxicated (OWI), holding that defense counsel was not ineffective in declining to seek suppression of certain evidence on the basis that Defendant was subjected to an unconstitutional seizure.An officer observed Defendant illegally park her vehicle and stopped her to enforce the parking violation. Upon smelling marijuana and observing signs of Defendant's intoxication the officer inquired about her intoxication. The officer asked Defendant for her registration and insurance and discovered that her driver's license was revoked. Defendant was convicted of second-offense OWI and driving while license was revoked. The Supreme Court affirmed, holding (1) there was sufficient evidence to support Defendant's OWI conviction; and (2) Defendant's counsel was not ineffective in failing to seek suppression of the evidence because the officer had probable cause to seize Defendant based upon his observation of her traffic violation. View "State v. Warren" on Justia Law

The Supreme Court affirmed the decision of the court of appeals and the judgment of the district court convicting Defendant of attempted murder and related crimes, holding that any error that occurred in the proceedings below was harmless.Specifically, the Supreme Court held (1) whether Defendant's counsel breached an essential duty in failing to object to certain questions, any error was harmless; and (2) the district court did not abuse its discretion in admitting into evidence a policy body-cam video taken immediately after the shooting, a recorded call, or a recording of a police interview with the victim taken five days after the shooting. View "State v. Swift" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress, holding that observations of a driver holding a phone in front of his face and actively manipulating the screen for at least ten seconds justified stopping the driver to resolve any ambiguity about whether the driver was violating Iowa Code 321.276.Section 321.276 allows drivers to use cell phones for some limited purposes while prohibiting most others. Defendant was stopped when officers believed he might be violating the statute. In his motion to suppress, Defendant argued that the officers lacked reasonable suspicion that Defendant was committing a traffic violation. The district court denied the motion. The Supreme Court affirmed, holding that the officers had reasonable suspicion Defendant was violating section 321.276 to support an investigatory stop. View "State v. Struve" on Justia Law