Justia Criminal Law Opinion Summaries

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

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