Justia Criminal Law Opinion Summaries

In this case, the Supreme Court of Iowa was asked to determine who should bear the costs of a technology vendor hired to review a large volume of emails seized under a search warrant for potential attorney-client privileged communications. The emails belonged to a criminal defendant, Craig Juan Merrill, who was charged with multiple counts of ongoing criminal conduct, theft, assault, and misconduct in office. The search warrant stipulated that the seized materials would be reviewed by the district court to ensure no attorney-client privileged materials were inadvertently handed over to the prosecution.However, due to the large volume of emails and technical difficulties, the district court was unable to complete the review and decided to hire a technology vendor to assist. The question of who should bear the costs of this vendor became a point of contention. The district court initially ordered the prosecution to pay the costs, but left open the possibility that the costs could be taxed to the defendant at the conclusion of the case.The State of Iowa filed a petition for writ of certiorari with the Supreme Court of Iowa, arguing that the district court acted illegally in assessing the costs of the privilege review against the prosecution. The State contended that the judicial branch should bear the costs, as the vendor was effectively acting as a special master to assist the court.The Supreme Court of Iowa sustained the writ, ruling that the judicial branch should be responsible for the costs of the technology vendor. The court reasoned that the district court had voluntarily assumed the responsibility of conducting the initial privilege review and, when it was unable to do so, it was compelled to employ a third-party vendor. Under these unique circumstances, the court concluded that the judicial branch must bear the costs of the vendor it employed. View "State of Iowa v. Iowa District Court For Emmet County" on Justia Law

The case involves a defendant, Brandon Lee, who was convicted of two counts of first-degree robbery, willful injury causing serious injury, willful injury causing bodily injury, theft in the first degree, and impersonating a public official. The charges stemmed from an incident where Lee, posing as a law enforcement officer, assaulted a husband and wife in their home and stole $50,000 from their safe.The case was first heard in the Iowa District Court for Linn County, where Lee was found guilty of all six charges. He was sentenced to twenty-five years for each conviction of robbery in the first degree, ten years for willful injury causing serious injury, five years for willful injury causing bodily injury, ten years for theft in the first degree, and two years for impersonating a public official. The sentences for the two robbery convictions were ordered to be served consecutively, for a total of fifty years, with a minimum sentence of thirty years before being eligible for parole. The remaining sentences were ordered to be served concurrently to each other and consecutively to the robbery convictions.The case was then brought to the Supreme Court of Iowa on appeal. Lee argued that there was insufficient evidence to sustain a conviction for two counts of first-degree robbery, asserting that he did not intend to commit two separate and distinct thefts. The Supreme Court disagreed, finding that the evidence was sufficient to conclude that Lee intended to commit two separate and distinct thefts. Therefore, the Supreme Court affirmed both convictions and sentences for first-degree robbery. View "State of Iowa v. Lee" on Justia Law

The defendant, Christopher James Wilson, was charged with two counts of indecent exposure after he was seen masturbating in public by two women, E.H. and T.A., at a gas station. Wilson followed the women to another location where he continued his actions. He was subsequently arrested and charged. After a jury trial, he was convicted on both counts and sentenced to an enhanced sentence under Iowa Code section 901A.2(1) to an indeterminate prison term of two years for the first count and an indeterminate prison term of two years for the second count. The sentence for count one was ordered to run consecutively to the sentence for count two.Wilson appealed his conviction and sentence, arguing that the unit of prosecution for indecent exposure is per exposure, not per viewer. Therefore, he contended that there was insufficient evidence to convict him on two separate counts of indecent exposure. He also argued that the district court did not provide sufficient reasons for imposing a consecutive sentence under Iowa Rule of Criminal Procedure 2.23(3)(d).The Supreme Court of Iowa affirmed the lower court's decision. The court held that the unit of prosecution for indecent exposure is one count per viewer, not one count per exposure. Therefore, there was sufficient evidence to support a conviction on two counts of indecent exposure. The court also found that the district court provided sufficient reasoning for imposing a consecutive sentence. The court noted that the district court's reasoning for imposing consecutive sentences may be the same reasons the court relied on for the imposition of incarceration. The court concluded that the district court's statement that the only appropriate sentence was to send Wilson to prison for as long of a period of time as possible implied that the sentences should run consecutively. View "State v. Wilson" on Justia Law

Jesse McCollaugh was found guilty of child exploitation after his wife discovered videos on his phone of her 15-year-old sister using the bathroom, which McCollaugh had secretly recorded. The videos showed the minor partially nude, unaware she was being filmed. McCollaugh admitted to recording the videos and having a sexual problem. He was charged with one count of sexual exploitation of a minor, to which he pleaded not guilty. After a bench trial, the district court found McCollaugh guilty and sentenced him to a prison term not exceeding two years, and required him to register as a sex offender.Before the Supreme Court of Iowa, McCollaugh appealed his conviction, arguing that the evidence was insufficient to support his conviction because it failed to establish that the minor had the purpose of engaging in nudity to arouse or satisfy the sexual desires of a person who may view the visual depiction. The Supreme Court disagreed with McCollaugh's interpretation of the statute, stating that the relevant "purpose" that the State must prove is identified after the word "purpose" in the definition, not before. The court held that the State must prove the purpose of purchasing or possessing a visual depiction of the nude minor—not the minor’s purpose in being nude. The court found sufficient evidence to prove McCollaugh’s purpose for taking the videos was for his sexual gratification and affirmed his conviction. McCollaugh also argued that the district court relied on an improper factor in its sentencing order, but the Supreme Court found no evidence that the district court relied on the improper factor and affirmed the sentence. View "State v. McCollaugh" on Justia Law

The case involves Clayton Curtis Brown, who was convicted of possession of a firearm as a felon, aggravated eluding, and driving while barred. The charges stemmed from an incident where Brown eluded a police officer's attempt to initiate a traffic stop. The officer later found the car abandoned and discovered a loaded handgun under the driver's seat and ammunition in the center console and under the front passenger seat. Brown's personal items were also found in the car.The Iowa Court of Appeals reversed Brown's convictions for possession of a firearm as a felon and aggravated eluding, concluding there was insufficient evidence to show that Brown knowingly possessed the handgun. Brown also contested the sufficiency of the evidence to support his convictions, arguing that the State failed to prove his identity as the driver of the car that eluded the officer.The Supreme Court of Iowa disagreed with the lower court's decision. The court held that the State's evidence, including the officer's testimony, the location of the firearm, and the presence of Brown's personal effects in the car, was sufficient to support the jury's conclusion that Brown had constructive possession of the firearm. The court also found that there was sufficient evidence to support the jury's determination that Brown was driving the car when it eluded the officer. Therefore, the Supreme Court of Iowa vacated the portion of the court of appeals decision reversing those convictions and affirmed the district court judgment in full. View "State of Iowa v. Brown" on Justia Law

The Supreme Court of Iowa ruled in a case involving an individual, Faron Alan Starr, who was arrested and denied his request to call a family member to get an attorney. Starr was suspected of an assault and stealing two firearms. After his arrest, he was taken to a police station where he initially equivocated about speaking to the police without an attorney. However, he later requested to call his father to obtain a lawyer, which was refused by the police officer. The officer proceeded to question Starr about his actions and whereabouts of the stolen firearms.Starr was charged with multiple offenses, and he subsequently filed a motion to suppress his statements and any evidence derived from them, asserting violations of his constitutional and statutory rights. The district court granted the motion, finding a violation of Starr's rights under Iowa Code section 804.20, which mandates that an arrested person be allowed to call and consult a family member or an attorney without unnecessary delay upon arrival at the place of detention.The Supreme Court of Iowa affirmed the lower court's decision, holding that while public safety concerns could potentially justify a delay in honoring an arrested person's rights under Iowa Code section 804.20, the circumstances of this case did not warrant such a delay. The court noted that the police did not address the issue of the missing firearms until nearly two hours after Starr was taken into custody for questioning at the police station. Therefore, the delay in permitting Starr to call a family member was deemed unnecessary. View "State of Iowa v. Starr" on Justia Law

The Supreme Court of Iowa upheld the decision of the Iowa Court of Appeals and the district court that sentenced a recidivist drug offender, Jacob Lee Goble, to an indeterminate prison sentence of up to five years. Goble, who had pleaded guilty to a class "D" felony, appealed on the grounds that the sentencing court improperly considered parole as a factor in determining his sentence. The court mentioned parole once in the context of Goble's need for a structured setting for his rehabilitation and protection of the community.The Supreme Court of Iowa, however, found that the mention of parole in this context was not inappropriate. The court stated that the district court did nothing to circumvent the parole board’s discretion in determining the release date, and its reference to parole is authorized by statute. Goble’s sentence was therefore affirmed, and his claim that the sentencing court relied on an improper factor by mentioning parole was rejected.The court also differentiated this case from precedent where it was held impermissible for the district court to impose a longer prison sentence for the purpose of delaying the defendant’s release on parole. In this case, the district court’s choice was limited to imposing a five-year indeterminate sentence with immediate parole eligibility or suspending that sentence and placing Goble on probation. The court concluded that the district court did not impose a longer sentence to circumvent the parole board’s discretion. View "State of Iowa v. Goble" on Justia Law

The case at hand arose from the appeal by Scott Randolph Luke, who was convicted of domestic abuse assault while on probation for two previous domestic abuse assaults. The district court sentenced him to two years in prison for the latter offense, revoked his probation, and ordered his sentences to be served consecutively. Luke challenged the sentence, contending that the district court abused its discretion and failed to provide reasons for the consecutive sentences.The Court of Appeals affirmed the decision. It concluded that the district court did not abuse its discretion in imposing a prison term for the latest offense. It also determined, though narrowly, that the district court's explanation for the consecutive sentences was sufficient.Upon further review, the Supreme Court of Iowa also affirmed the decisions of the lower courts. The Supreme Court held that the district court had given a detailed and personalized explanation for why it was sending Luke to prison. Although the district court did not explicitly discuss reasons for running that sentence consecutively to the sentence imposed on the probation revocation, it addressed that omission in the written sentencing order. The Supreme Court found no error in Luke's sentence. View "State of Iowa v. Luke" on Justia Law

The appellant, Lawrence George Canady III, had been charged with voluntary manslaughter, willful injury causing bodily injury, and assault causing bodily injury due to his involvement in a fatal nighttime shooting incident. He was not the shooter, but the State alleged that he was beating the victim while another person shot the victim. The appellant challenged the admission of a cell phone video recorded prior to the shooting where he and the shooter were seen singing a rap song containing lyrics that seemed to reference the victim. The district court allowed the video, but the court of appeals reversed the decision, remanding for a new trial.Upon further review by the Supreme Court of Iowa, the court found that the district court did not abuse its discretion in admitting the video. It was relevant to the case as it showed the appellant and the shooter jointly voicing a threat, which could counter the appellant's claim that he was unaware of the shooter's intention. The court also found no error in the admission of a Snapchat photo, as it was relevant to showing that the appellant may have been aware that the shooter had a gun and was willing to use it. The court further held that the evidence was sufficient to support the appellant's voluntary manslaughter conviction.The appellant's argument that his sentences for voluntary manslaughter and willful injury causing bodily injury should be merged was rejected as the offenses did not overlap in elements. Moreover, the court found no error in the sentencing court's consideration of the minutes of testimony or in its imposition of consecutive sentences. The Supreme Court of Iowa vacated the decision of the court of appeals and affirmed the appellant's convictions and sentence. View "State of Iowa v. Canady" on Justia Law

In the Supreme Court of Iowa, the case involved David Jackson, who was involved in a car accident that resulted in the death of another motorist. Jackson was convicted of vehicular homicide by operating while intoxicated, reckless driving, leaving the scene of an accident resulting in death, and operating a motor vehicle without the owner’s consent. Jackson appealed on the basis that the court allowed rebuttal evidence of his medical condition, which he claimed caused him to black out and lose control of the vehicle, over his objections that the evidence was hearsay.The Court concluded that the district court had erred in admitting the testimony of an employee of a healthcare vendor who had reviewed some of Jackson’s post-accident medical records. The court found that the testimony was hearsay and did not fall into the business records exception to the hearsay rule because the testimony was about the records, not the records themselves.The Court affirmed Jackson’s conviction for operating a motor vehicle without the owner’s consent, but vacated his convictions for vehicular homicide (OWI), reckless driving, and leaving the scene of an accident resulting in death, and remanded the case for further proceedings. View "State of Iowa v. Jackson" on Justia Law