Justia Criminal Law Opinion Summaries

The Supreme Court reversed Defendant's conviction for wanton neglect of a resident of a health care facility, holding that the admission of a certain exhibit, when coupled with a certain instruction, posed a serious risk of misleading or confusing the jury.Defendant's conviction arose out of his alleged failure to properly ensure that a facility resident as ordered by the patient's physician. On appeal, Defendant argued that the trial court's admission of the standard of care in the nursing profession and the subsequent instructions related to the use of the standard of care in this case were improper. The Supreme Court agreed and reversed the conviction, holding that the professional standards should have been excluded under Iowa R. Evid. 5.403 and that the court's jury instructions did not mitigate the problem. View "State v. Buman" on Justia Law

The Supreme Court affirmed Defendant's convictions for attempting to obtain a prescription drug by deceit, as a habitual offender, and conspiracy to commit a nonforcible felony, holding that Defendant's constitutional challenge to Iowa Code 814.6A was unavailing.Specifically, the Supreme Court held (1) the district court did not abuse its broad discretion in admitting, over Defendant's objections, evidence regarding Defendant's residential address, which was offered to prove Defendant's knowledge, motive, and intent; and (2) section 814.6A, a newly-enacted law that prohibits a represented defendant from filing pro se documents, does not violate the constitutional separation-of-powers doctrine. The Court then denied Defendant's motion to accept his pro se supplemental brief. View "State v. Thompson" on Justia Law

The Supreme Court affirmed Defendant's sentence imposed following his pleas of guilty to possession of a firearm by a felon, interference with official acts while armed with a firearm, and carrying weapons, holding that there was no error.On appeal, Defendant argued that the prosecutor breached the parties' plea agreement by failing to recommend the bargained-for sentence and that the district court improperly considered his juvenile offense history as an aggravating factor. The Supreme Court affirmed, holding (1) Defendant failed to establish a breach of the plea agreement; and (2) the district court did not consider an improper sentencing factor in considering Defendant's juvenile adjudications and dispositions. View "State v. Boldon" on Justia Law

The Supreme Court affirmed Defendant's conviction for attempted burglary with intent to commit theft, holding that the State's evidence, and all reasonable inferences from that evidence, was sufficient to support Defendant's conviction.The court of appeals reversed Defendant's attempted burglary conviction, concluding that the circumstantial evidence was too speculative to support his conviction because it required a stacking of inferences. The Supreme Court vacated the court of appeals' decision after noting that this Court does not categorically prohibit stacking of inferences, holding that Defendant's conviction was supported by substantial evidence. View "State v. Ernst" on Justia Law

The Supreme Court vacated Defendant's sentence for domestic abuse assault while displaying a dangerous weapon, holding that the district court exceeded its statutory sentencing authority in this case.The district court sentenced Defendant to an indeterminate term of incarceration not to exceed two years, suspended all but six days of the sentence, and placed Defendant on probation for two years. On appeal, the court of appeals noted that the imposed sentence appeared to be an illegal split sentence but declined to resolve the issue. The Supreme Court exercised its discretion to correct the illegality in this case, holding that the district court imposed a statutorily unauthorized sentence by suspending a portion of Defendant's indeterminate sentence. View "State v. Wieneke" on Justia Law

The Supreme Court reversed the restitution order of the district court, holding that the State failed to prove the full amount of restitution was caused by the crime of conviction.Defendant pled guilty to ongoing criminal conduct and admitted that the victim bank's losses totaled $288,000. The bank obtained a civil deficiency judgment of $988,636. The district court ordered Defendant to pay restitution in the full amount of the bank's loss rather than the amount Defendant admitted converting. The Supreme Court vacated the restitution amount in excess of $288,000 and remanded the case for entry of an amended restitution award in that amount, holding that the district court's order was not supported by substantial evidence. View "State v. Waigand" on Justia Law

The Supreme Court affirmed the restitution order of the district court in this criminal matter, holding that this Court had jurisdiction to review the restitution order and that Defendant did not meet his burden to overturn the restitution order.Defendant pled guilty to possession of methamphetamine. He was sentenced to ten years in prison and ordered to pay a $1000 fine. The district court then ordered a "second category" of restitution apart from the fine totaling $593 for court costs and attorney fees. Defendant appealed, arguing that the second category of restitution was excessive. The Supreme Court affirmed, holding (1) this Court has jurisdiction to consider Defendant's appeal; and (2) the district court did not abuse its discretion in determining the amount of restitution Defendant had the ability to pay. View "State v. Hawk" on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's motion for a new trial, holding that the district court erred in applying too strict a standard in determining whether Defendant was entitled to a new trial under the circumstances of this case.Defendant, who was charged with sexual abuse of a child, requested the child's privileged mental health and counseling records. The district court denied the request. The court of appeals remanded the case, ruling that Defendant should have been granted access to the child's mental health and counseling records because they contained exculpatory information. On remand, the district court denied the motion for new trial after applying a weight of the evidence standard. The Supreme Court reversed, holding (1) the appropriate standard for a new trial determination after a district court fails to order production of exculpatory medical records is the material standard in Brady v. Maryland, 373 U.S. 83 (1963); and (2) because the district court applied the incorrect standard in denying the motion for new trial, the case must be remanded. View "State v. Barrett" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming one of Defendant's two convictions of sexual abuse in the third degree based on an aiding-and-abetting theory, holding that the contested count was supported by a factual basis.Defendant raped a woman, G.S., and then forced his companion, J.C., to have sex with the same woman against both of their wills. Defendant pled guilty to two counts of sexual abuse in the third degree. The victim in count I was identified as G.S., and the victim in count II was identified as J.C. On appeal, Defendant argued that there was no evidence that he committed a sex act against J.C. The court of appeals affirmed. The Supreme Court affirmed, holding that J.C. was a victim because Defendant forced him to commit a sex act against his will. View "State v. El-Amin" on Justia Law

In this appeal from a court of appeals decision affirming Defendant's resentencing without eliminating the jail fees relating to the count on which Defendant was acquitted on appeal, the Supreme Court reversed the assessment of $4935 in posttrial fees, holding that Defendant's reimbursement obligation must be reduced.Defendant was found guilty of two crimes, including a forcible felony. While Defendant was confined in the county jail until his sentencing, the sheriff filed a reimbursement claim for jail fees against Defendant. The court of appeals reversed Defendant's forcible felony conviction. On resentencing, the district court revised Defendant's prison sentence but left untouched the jail fees resulting from the dismissed conviction. The court of appeals affirmed. The Supreme Court reversed in part, holding that Defendant's reimbursement obligation under Iowa Code 356.7 must be reduced by $4935 because the costs for Defendant's confinement in the county jail were clearly attributed to the forcible felony charge on which Defendant ultimately received an acquittal. View "State v. Shackford" on Justia Law