Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's convictions for assault with a dangerous weapon and third degree criminal mischief, holding that Iowa R. Evid. 5.701 and 5.702 did not require certain testimony concerning historical cell site data to be presented by an expert.Investigating officers used Defendant's cell phone records to place him in the general vicinity at the time of the incident giving rise to Defendant's convictions. On appeal, Defendant argued that his counsel provided ineffective assistance by not challenging the phone records as inadmissible hearsay and by not challenging the testimony provided by an officer as an unqualified expert. The Supreme Court affirmed, holding (1) the testimony at issue was not based on specialized knowledge and thus did not require an expert; and (2) therefore, Defendant's counsel was not ineffective for failing to challenge the phone records or the officer's testimony. View "State v. Boothby" on Justia Law

The Supreme Court reversed the judgment of the district court convicting Defendant of second-degree murder, holding that the exclusion of evidence regarding the victim's mental health records and the limitation of testimony on those records was not harmless error.On appeal, Defendant argued that the district court erred when it excluded his mental health records at trial and limited review of those records and erred in forbidding lay testimony on the victim's suicidal behavior. The court of appeals reversed on the evidentiary rulings regarding Defendant's medical records. The Supreme Court affirmed, holding (1) evidence of a person's suicidal disposition is not properly analyzed as character evidence under the Iowa Rules of Evidence in cases where the defendant alleges suicide; (2) the temporal proximity of the medical records was not too remote to be relevant to Defendant's defense that the victim committed suicide; and (3) the exclusion of the victim's medical records and limitation of related admissible testimony was not harmless error. View "State v. Buelow" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for operating while intoxicated first offense, holding that a peace officer does not violate a duty under Iowa Code 321J.11(2) by agreeing to a detainee's request for a retest on the machine that has already tested the detainee's blood alcohol level without also informing the detainee of the statutory right to an independent test at the detainee's expense.Specifically, the Supreme Court held (1) an officer must inform the detainee of the right to an independent test only in circumstances when the detainee has reasonably asked about that right or when a failure to disclose that right could be misleading; and (2) because neither of those circumstances were present in this case, the district court did not err in denying Defendant's motion to suppress. View "State v. Casper" on Justia Law

The Supreme Court affirmed Defendant's convictions and sentences for eluding while speeding and several unrelated offenses, holding that trial counsel was not ineffective for failing to challenge Defendant's eluding charge on double jeopardy grounds based on his guilty plea to speeding in the same incident.At age seventeen, Defendant pled guilty to a speeding citation without pleading guilty to the accompanying charge of eluding. When Defendant turned eighteen, the State charged him by trial information with eluding while speeding. Defendant pled guilty to the eluding charge. The court of appeals affirmed. The Supreme Court affirmed, holding (1) speeding is a lesser included offense that at trial would merge into a conviction for eluding while speeding, but under the circumstances of this case, Defendant cannot use double jeopardy principles as a sword to defeat his conviction for eluding; and (2) therefore, Defendant's ineffective assistance of counsel claims fail. View "State v. Roby" on Justia Law

The Supreme Court reversed the judgment of the district court convicting Defendant of first-degree murder, holding that a new trial was required because the marshaling instruction for that charge failed to cross-reference Defendant's insanity defense.On appeal, Defendant argued that his trial counsel provided ineffective representation by failing to object to the instruction at issue. The Supreme Court agreed, holding (1) the jury instructions were materially misleading without the cross-reference to the insanity defense in the marshaling instruction for first-degree murder and that trial counsel breached an essential duty by failing to object; and (2) this significant error in that marshaling instruction for the main offense undermines this Court's confidence in the verdict, requiring a new trial. View "State v. Davis" on Justia Law

The Supreme Court reversed the order of the district court revoking Defendant's deferred judgment, holding that the district court failed to include sufficient factual findings to support revocation.Defendant pled guilty to child endangerment. The district court ordered the judgment deferred and Defendant to pay a civil penalty, court costs, and attorney fees. Thereafter, the State filed an application to revoke deferred judgment and pronounce sentence, alleging that Defendant had not paid the balance due. The court found that Defendant had violated the terms of her probation and revoked the deferred judgment. The Supreme Court reversed, holding (1) the holding in State v. Damme, 944 N.W. 2d 98 (Iowa 2020), that a defendant who is not challenging her guilty plea or conviction has good cause to appeal an alleged sentencing error when the sentence was neither mandatory nor agreed to in the plea bargain extends to appeals from orders revoking deferred judgments; and (2) the district court's factual findings were insufficient. The Court remanded the case to the district court for a new hearing on the State's application to revoke Defendant's deferred judgment. View "State v. Thompson" on Justia Law

The Supreme Court affirmed Defendant's conviction of homicide by intoxicated operation of a vehicle, holding that the district court did not err by denying his requested instruction for homicide by reckless driving as a lesser included offense and by excluding certain evidence.Defendant drove his pickup through a stop sign and broadsided a minivan. One of the passengers in the minivan, a six-month-old infant who wasn't secured in a child restraint system, died from injuries suffered in the crash. Defendant was convicted of homicide by intoxicated operation, and the trial court denied his motion for a new trial. The Supreme Court affirmed, holding (1) the district court did not err in refusing to give to the jury Defendant's requested homicide by reckless driving instruction because it was not a lesser included offense; and (2) the district court did not err in preventing Defendant from offering evidence that the infant wasn't secured in a child restraint seat. View "State v. Johnson" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court denying Defendant's motion for new trial based on a claim of newly discovered evidence, holding that the district court did not abuse its broad discretion in denying Defendant's motion for new trial.In 2014, Defendant registered as a sex offender in Iowa. In 2016, Defendant failed to appear at the sheriff's office to verify his registration information. Defendant was subsequently convicted of failure to comply with the sex offender registry. Thereafter, Defendant filed a motion for new trial based on newly discovered evidence. The district court denied the motion, finding that the newly discovered evidence was not material and would not have changed the jury's verdict. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying the motion for new trial. View "State v. Uranga" on Justia Law

The Supreme Court affirmed Defendant's convictions for misdemeanor possession of of marijuana and felony eluding with marijuana, holding that the convictions do not merge.After convicting Defendant the district court imposed concurrent sentences. On appeal, Defendant argued that the possession convictions merged with the eluding charges. The State argued in response that the statutory scheme demonstrates that the legislature intended cumulative punishments for these offenses. The Supreme Court affirmed, holding (1) under the legal-elements test, it is impossible to commit felony eluding with marijuana without possessing it; but (2) the legislature prescribed cumulative punishments for the two offenses. View "State v. Johnson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the judgment of the district court ordering Defendant to register as a sex offender after he entered an Alford plea to child endangerment, holding that the evidence was insufficient to prove sexual motivation beyond a reasonable doubt under Iowa Code 692A.126 and that the proper remedy was to remand and give the State an opportunity to prove sexual motivation.The district court relied on Defendant's Alford plea and a victim impact statement from the child victim's mother to find that Defendant's underlying conduct was sexually motivated. The court ordered Defendant to register as a sex offender. The court of appeals remanded the cause, finding that victim statements do not provide sufficient evidence that the offense of conviction was sexually motivated beyond a reasonable doubt but that the minutes of testimony identified evidence to establish that the offense could have been sexually motivated. The Supreme Court affirmed the court of appeals, vacated the order requiring Defendant to register as a sexual offender, and remanded, holding that, under the circumstances, the State is allowed to introduce the facts from the minutes in an effort to support its request that Defendant be required to register as a sex offender. View "State v. Chapman" on Justia Law