Justia Criminal Law Opinion Summaries

Articles Posted in Iowa Supreme Court
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In this criminal case in which Defendant was charged with sexually abusing his fourteen-year-old daughter, S.V., the Supreme Court reversed the district court's preliminary ruling that a video recording of a forensic interview of S.V. was not admissible under the residual exception to the hearsay rule, holding that the district court committed two overarching error in its analysis of the preliminary question. After the district court granted Defendant's motion to exclude the forensic interview the State sought a definitive ruling on four of the findings requisite for evidence to be admitted under the residual exception - trustworthiness, materiality, notice, and service of the interests of justice. The district court concluded that the video was not admissible under the residual hearsay exception. The Supreme Court reversed, holding that the district court erred in concluding that it had discretion regarding the admission of the videotape and that the district court's analysis of the preliminary question was contaminated with extraneous considerations relating to confrontation clause jurisprudence. View "State v. Veverka" on Justia Law

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The Supreme Court affirmed Defendant's conviction of boating while intoxicated in violation of Iowa Code 462A.14(1), holding that Iowa Department of Natural Resources (DNR) officers had probable cause to stop Defendant's vessel. Two DNR officers were patrolling Lake Panorama, a recreational lake that was created by damming the Middle Raccoon River, when they stopped Defendant's pontoon boat for displaying blue lights in violation of Iowa Code 462A.12(4). The stop revealed that Defendant, the operator of the boat, appeared to be intoxicated. Defendant was charged with boating while intoxicated. Defendant filed a motion to suppress, arguing section 462A.12(4) did not apply because Lake Panorama was not "waters of this state under the jurisdiction of the conservation commission" and there was no probable cause for the stop. The district court denied the motion to suppress. The Supreme Court affirmed, holding that the officers had probable cause to stop the boat because Lake Panorama belongs to the people of Iowa and is not a privately owned lake as defined in section 462A.2(31). View "State v. Meyers" on Justia Law

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The Supreme Court conditionally affirmed Defendant's convictions but remanded the case for an in camera inspection of the victim's mental health records, holding that the district court erred by failing to conduct the in camera inspection. Defendant was convicted of sexually abusing his granddaughter. During trial, the granddaughter lied about certain facts, and thus the granddaughter's credibility was a key issue. In her deposition, the granddaughter testified that she had disclosed the defendant's abuse to her therapist, a mandatory reporter. Noting that the therapist had not reported the alleged abuse, Defendant filed a motion for the court's in camera inspection arguing that the records likely contained exculpatory impeachment evidence. The district court denied the motion and Defendant's request for an ex parte hearing. The Supreme Court remanded the case, holding that the district court did not err in denying Defendant's motion for an ex parte hearing but erred by failing to conduct the in camera inspection of the granddaughter's mental health records. View "State v. Leedom" on Justia Law

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The Supreme Court affirmed the decision of the district court dismissing Appellant's application for postconviction relief (PCR) claiming a violation of his constitutional right to an impartial jury drawn from a fair cross section of the community, basing his claim on State v. Plain, 898 N.W.2d 801 (Iowa 2017), holding that the holding in Plain does not apply retroactively to cases on collateral review. In 1984, Appellant was convicted of first-degree murder. In 2017, the Supreme Court decided Plain, which addressed the Duren three-part test for evaluating Sixth Amendment fair-cross-section claims and overruled precedent adopting the absolute-disparity method as the exclusive indicator of representativeness under the second prong of Duren. In 2018, Appellant filed the instant PCR application, alleging that he was denied his rights to due process, equal protection, and a fair and impartial trial under the state and federal constitutions. Appellant based his claim on Plain. The district court granted the State's motion to dismiss, concluding that Plain is not retroactive. The Supreme Court affirmed, holding (1) Appellant's Plain claim is time-barred by Iowa Code 822.3; and (2) because Plain's holding is not a watershed rule of criminal procedure, it does not apply retroactively to cases on collateral review. View "Thongvanh v. State" on Justia Law

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The Supreme Court affirmed the decision of the postconviction relief (PCR) court dismissing Appellant's fourth PCR application, holding that under this Court's holding today in Thongvanh v. State, __ N.W.2d __ (Iowa 2020), Defendant's claims based on State v. Plain, 898 N.W.2d 801 (Iowa 2017), failed because Plain is not retroactive. In his PCR application Appellant alleged violations of his rights to equal protection and due process and his right to an impartial jury drawn from a fair cross section of the community. Appellant based his claims on Plain. The trial court granted the State's motion to dismiss, concluding that Plain does not apply retroactively. The Supreme Court affirmed, holding (1) the trial court improperly dismissed Appellant's application based upon a ground neither party raised; and (2) because the new law of criminal procedure announced in Plain does not apply retroactively to cases on collateral review Appellant's PCR application was properly dismissed. View "Jones v. State" on Justia Law

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The Supreme Court vacated the decision of the court of appeals reversing Defendant's conviction on the basis that the district court inadequately instructed the jury on Defendant's justification defense, holding that the court's failure to include "lack of justification" in the marshaling instruction was not prejudicial for ineffective assistance purposes. On appeal, Defendant argued that his trial counsel provided ineffective assistance for failing to object to the marshaling instruction, which did not mention that the State needed to prove the act was done without justification. The Supreme Court disagreed, holding that, in light of the evidence and the instructions as a whole, there was not a reasonable probability of a different outcome if justification had been covered in the marshaling instruction along with the other instructions. View "State v. Kuhse" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court convicting Defendant of making a false report alleging the occurrence of the criminal act of carrying weapons, holding that the district court did not err in denying Defendant's request for an instruction on the exceptions to the underlying criminal act of carrying weapons. On appeal, the Supreme Court addressed only whether the definitional instructions to the criminal act of carrying weapons required inclusion of the statutory exceptions. Based on its review of the entire record, the Supreme Court affirmed, holding that the district court's refusal to give Defendant's requested instruction was not erroneous because substantial evidence did not support Defendant's requested instruction on his hypothetical affirmative defense. View "State v. Bynum" on Justia Law

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The Supreme Court affirmed Defendant's sentence imposed in connection with his guilty plea to second-degree murder, holding that where Defendant received an individualized sentencing hearing that addressed the Miller/Lyle/Roby factors Defendant's challenge to his sentence did not constitute a proper motion to correct an illegal sentence. Defendant was sixteen years old when he fatally shot his father. After an individualized sentencing hearing the district court imposed a fifty-year prison sentence with a twenty-year mandatory minimum before parole eligibility and recited its consideration of the sentencing factors. Defendant later filed a motion to correct an illegal sentence and for appointment of counsel, alleging that the district court failed properly to apply the factors set forth in Miller v. Alabama, 567 U.S. 460 (2012), State v. Lyle, 854 N.W.2d 378 (Iowa 2014), and State v. Roby, 897 N.W.2d 127 (Iowa 2017). The district court denied the motion. The Supreme Court affirmed, holding (1) a motion claiming the district court misapplied the Miller/Lyle/Roby factors does not constitute a challenge to an illegal sentence with a concomitant statutory right to counsel; (2) Defendant's challenge to his sentence did not constitute an attack on an illegal sentence; and (3) the district court acted within its authority in sentencing Defendant to the twenty-year mandatory minimum. View "Goodwin v. Iowa District Court for Davis County" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court convicting Defendant of driving while intoxicated, holding that Defendant was not seized for purposes of the Fourth Amendment or Iowa Const. art. I, 8 when the officer approached Defendant on foot the evening of her arrest. An officer watched a vehicle driving suspiciously for several minutes in a residential neighborhood at night. When the vehicle entered a one-lane alley and did not emerge from the alley, the officer approached the stopped vehicle without activating flashers. The officer walked up to Defendant, the driver, to engage in a conversation, which resulted in the officer learning that Defendant was under the influence of alcohol. Defendant was convicted of driving while intoxicated. Defendant appealed, arguing that she was seized in violation of her rights under the Fourth Amendment and article I, section 8. The court of appeals affirmed, concluding that Defendant was not subjected to a seizure in the constitutional sense. The Supreme Court affirmed, holding that no seizure occurred under either the state or federal constitution. View "State v. Fogg" on Justia Law

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The Supreme Court vacated Defendant's sentence and remanded this case for resentencing, holding that where the sentencing court indicated that it lacked "wiggle room" regarding whether to reduce Defendant's sentence, the court failed to exercise its discretion under Iowa Code 901.10(1), which expressly provided the court with discretion to reduce Defendant's sentence. Defendant was convicted of intimidation with a dangerous weapon (count one) and reckless use of a firearm. The court sentenced Defendant to a term of incarceration of up to ten years with a mandatory minimum of five years on count one. The Supreme Court vacated the sentence, holding that the district court was unaware that it had discretion under section 901.10 to reduce the five-year minimum term, and therefore, the court failed to exercise its discretion. View "State v. Moore" on Justia Law