Justia Criminal Law Opinion Summaries

Articles Posted in Iowa Supreme Court
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In the Supreme Court of Iowa, the State of Iowa appealed against the district court's dismissal of an extortion charge against Jerome Bailey Sr. Bailey had demanded $10,000 from his former property manager, threatening to expose her for allegedly sending a registered sex offender to his house, which he claimed was a childcare facility. The district court dismissed the charge, concluding that Bailey's threats were made with the reasonable belief that he had a right to make them under Iowa's extortion statute. However, the Supreme Court of Iowa reversed the district court's decision and remanded the case for further proceedings. The court reasoned that the statutory defense in the extortion statute, which allows threats made with a reasonable belief of a right to make them, does not apply automatically at the motion to dismiss stage if there are disputed facts. The court found that whether Bailey had a reasonable belief that he could demand $10,000 for the alleged misconduct was a question for a jury to decide, not a matter for dismissal. View "Iowa v. Bailey" on Justia Law

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This case was heard by the Supreme Court of Iowa and involved an appeal by a defendant, Demetrias Martin, who was challenging the mandatory minimum term imposed with his sentence for first-degree robbery. The main issue in the case was the use of a risk assessment tool that categorized Martin as a "high" risk for violent recidivism and a "moderate/high" risk for continuous victimization. Martin argued that the district court abused its discretion by relying on these conclusions without any information about how the tool actually arrived at them.In March 2019, Martin was sentenced to twenty-five years in prison with a requirement to serve at least 70% of his sentence under a statutory mandatory minimum. After a retroactive amendment to the robbery sentencing statute in June 2019, Martin was eligible for resentencing with a potential mandatory minimum as low as 50%. The amendment required the district court to consider certain factors when determining the mandatory minimum to impose, including a validated risk assessment.The Supreme Court of Iowa affirmed the decision of the lower courts, holding that the district court did not abuse its discretion in considering the results of the risk assessment tool. The court found that Martin had notice of the risk assessment and had the opportunity to challenge it but failed to do so. The court held that a district court does not abuse its discretion by considering risk assessment information in a presentence investigation report where a defendant has notice of the risk assessment and fails to present evidence exposing some actual unsoundness in it. Therefore, the court rejected Martin's argument and affirmed the sentence imposed by the lower court. View "State of Iowa v. Martin" on Justia Law

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In this case, the Supreme Court of Iowa addressed whether the district court erred in ordering the placement of a sexually violent predator in a transitional release program over the State’s objection. The State argued that the offender was ineligible for that program without a relapse prevention plan (RPP) accepted by his treatment provider at the Civil Commitment Unit for Sexual Offenders (CCUSO) as required by Iowa Code section 229A.8A(2)(d) (2022). The district court determined that the offender’s plan, approved by the offender’s expert, satisfied that statutory requirement. The State appealed, asserting that the court erred by substituting its judgment for that of CCUSO’s staff.The Supreme Court of Iowa held that a writ of certiorari is the proper form of appellate review, and granted the petition. On the merits, the court held that the district court erred by substituting its judgment for that of CCUSO’s staff. The court agreed with the State that the offender was ineligible for placement in the transitional release program because his treatment provider at CCUSO had not accepted his proposed RPP. The court also rejected the offender's substantive due process claims. Consequently, the court sustained the writ and vacated the district court’s ruling. View "In Re Detention of Schuman" on Justia Law

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This case from the Supreme Court of Iowa involves a juvenile, I.S., who was charged with sexual exploitation of a minor and possession of child pornography. The juvenile court initially waived its jurisdiction over the case, allowing it to be tried in the district court. However, the juvenile court later vacated its waiver and reclaimed jurisdiction over the case. The State sought a review of the juvenile court's decision to vacate its earlier order, arguing that the juvenile court no longer had jurisdiction or authority to modify or vacate the waiver order once it had been issued.The Supreme Court of Iowa held that the juvenile court did not have the authority to reclaim jurisdiction over the case after it had waived it to the district court. The court found that there was no provision in Iowa law for such a "revocation of waiver." The court reasoned that once a case has been transferred or waived to another court, the transferring court loses jurisdiction over the parties. The court also noted that allowing a juvenile court to reclaim jurisdiction could lead to disruption of proceedings and friction between the district and juvenile courts.Therefore, the court sustained the State's writ, vacated the juvenile court's revocation of its waiver of jurisdiction, and remanded the case, with the expectation that any further proceedings would occur in the district court. View "State of Iowa v. Iowa Juvenile Court for Plymouth County" on Justia Law

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In this case from the Supreme Court of Iowa, the appellant, David Gordon, a minor at the time of committing his crimes, was charged with theft in the first degree and willful injury resulting in bodily injury. He pleaded guilty and was sentenced to ten years in prison for the theft conviction and five years for the assault conviction, with the sentences to run concurrently. Gordon appealed the sentence and also filed a motion requesting reconsideration of the sentence under Iowa Code § 902.4. The district court reconsidered the sentence and placed Gordon on probation for up to five years. Gordon then filed a petition for writ of certiorari challenging his resentencing, arguing that the district court had abused its discretion by not granting him a deferred judgment in its initial sentencing, and then by wrongly concluding that it lacked the authority to do so under § 902.4 when resentencing him.The Supreme Court of Iowa affirmed the district court's decisions. The court held that the district court did not abuse its discretion in the initial sentencing. It found that the district court had considered and weighed the arguments for and against a deferred judgment, and had thoroughly explained its reasoning for the sentence imposed. As for Gordon's argument about the district court's power to defer judgment when reconsidering a sentence under § 902.4, the Supreme Court held that a deferred judgment involved more than a sentence. It involved the deferring of a judgment adjudicating guilt as well as a sentence. The court concluded that the district court correctly interpreted its authority under § 902.4 when it determined that it could not defer judgment when reconsidering Gordon's sentence. Therefore, the court affirmed Gordon's conviction and sentence and annulled the writ of certiorari. View "State of Iowa v. Gordon" on Justia Law

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In this case from the Supreme Court of Iowa, the defendant, Stephen Arrieta, a truck driver, was pulled over at a weigh station after his vehicle failed a "PrePass" check. During the stop, an Iowa Department of Transportation officer requested a K-9 unit to conduct a free air sniff of the truck and trailer. The drug dog alerted to the presence of drugs in the sleeper compartment of the cab, and Arrieta admitted to having marijuana inside. Arrieta was subsequently charged with possession of a controlled substance.Arrieta appealed the denial of his motion to suppress the marijuana. His main argument was that the officer unlawfully extended the time of his stop, known as a Level 3 inspection, to allow the K-9 handler to arrive and search his truck. Arrieta cited Rodriguez v. United States, a Supreme Court case that ruled such extensions of traffic stops without reasonable suspicion of criminal activity are unconstitutional.The Supreme Court of Iowa agreed with Arrieta, finding that he was detained longer than necessary to complete the Level 3 inspection, in violation of the Fourth Amendment. The court concluded that the officer had effectively completed his tasks before the arrival of the K-9 unit and that the 25-minute delay until the K-9 unit's arrival was unjustified. As such, Arrieta was improperly detained when the free air sniff occurred, and any evidence obtained as a result of the search should have been suppressed.The court vacated the decision of the Court of Appeals and reversed and remanded the judgment of the district court. View "State of Iowa v. Arrieta" on Justia Law

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In a case before the Supreme Court of Iowa, the defendant, Robert Clark Geddes, was charged with trespass as a hate crime. The defendant had trespassed onto various properties, leaving behind anonymous notes that urged the residents to "Burn that gay flag." The homes targeted by the defendant were displaying LGBTQ+ flags or decals. Geddes appealed his conviction, arguing that the evidence was insufficient and that his convictions violated his rights to free speech and due process.The court rejected the defendant's arguments and affirmed his convictions. The court ruled that Geddes was not being punished for his speech, but rather for his conduct—trespassing onto properties with the intent to commit a hate crime. The court found that the statute under which Geddes was convicted does not criminalize speech, but rather conduct with a specific intent—namely, trespassing on property because of the property owner or possessor's association with persons of a certain sexual orientation. The court also found that there was sufficient evidence to support Geddes's conviction.The court held that the defendant's conduct of surreptitiously entering onto properties to post his harassing notes was not protected under the First Amendment rights. The court noted that hate crime laws are designed to punish conduct, not expression, and Geddes's motive or intent led to the more serious criminal consequence. The court also rejected the defendant's argument that the trespass law was vague or overbroad, finding that it provides sufficient guidance to those enforcing it and does not intrude on protected freedoms. View "State of Iowa v. Geddes" on Justia Law

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In the case before the Supreme Court of Iowa, the court reviewed the trial and conviction of Robert Krogmann for attempted murder and willful injury causing serious injury. This was Krogmann's second trial after his initial conviction was overturned on appeal due to an improper asset freeze that interfered with his defense rights. In the second trial, Krogmann appealed his conviction on multiple grounds.The court held that the court of appeals erred in concluding that the trial court should have admitted a video recording of Krogmann's interview with law enforcement. Although the video was not hearsay and should have been admitted, the court held that the exclusion of the video did not affect Krogmann’s substantial rights and was therefore harmless error. The video would not have materially aided Krogmann's diminished capacity defense.The court further held that the trial court did not err in instructing the jury that assault, an element of the crimes charged against Krogmann, is a specific-intent crime, and that diminished responsibility can negate the intent element of assault.The court also upheld the trial court's decision to exclude evidence of a $1.5 million civil settlement between Krogmann and the victim, finding that the evidence was not relevant to the issues in the case.However, the court found that the trial court erred in allowing a witness to testify to the ultimate issue of intent, stating that it is the job of the court, not a paid expert, to explain criminal law to the jury.Lastly, the Supreme Court of Iowa agreed with Krogmann's contention that the court erred in awarding him to pay an expert witness’s fees and expenses in excess of the $150 per day cap in Iowa Code section 622.72.The Supreme Court of Iowa vacated the decision of the court of appeals, affirmed the district court judgment, granted and sustained in part the writ of certiorari, and remanded the case for redetermination of costs. View "Iowa v. Krogmann" on Justia Law

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The Supreme Court affirmed Defendant's conviction for operating while intoxicated (OWI) and eluding, holding that the district court did not abuse its discretion in admitting evidence about a preliminary breath test (PBT) and that the evidence was sufficient to support the convictions.During the underlying jury trial, the district court admitted a portion of an officer body cam video showing Defendant agreeing to a PBT, after which the edited video jumped to Defendant's arrest for OWI. The Supreme Court held (1) this juxtaposition of the PBT and arrest violated Iowa R. Evid. 5.403 because it had minimal probative value while strongly implying that Defendant had failed the PBT, but the error was harmless; and (2) there was sufficient evidence to sustain Defendant's eluding conviction. View "State v. Amisi" on Justia Law

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The Supreme Court held that the district court and court of appeals did not err in finding that Defendant was not seized before the law enforcement officer who eventually arrested him discovered his probable intoxication and that Defendant was lawfully detained on grounds of probable intoxication.In his motion to suppress, Defendant argued that he had been seized when the officers partially blocked him in while he was parked in a parking lot, trained a spotlight on him, and shined flashlights into his car from both sides. The trial court concluded that Defendant had not been "seized" before the police discovered his intoxication. The court of appeals affirmed, concluding that the officers' actions were not "sufficiently coercive" to constitute a seizure. The Supreme Court affirmed, holding that Defendant was lawfully detained because the officers did not seize him before his intoxication was observed. View "State v. Wittenberg" on Justia Law