Justia Criminal Law Opinion Summaries

The Supreme Court reversed the order of the district court denying Defendant's motion to dismiss four additional arson charges as breach of his plea agreement with the State as to second-degree arson, holding that the State remained bound by its plea agreement under the circumstances of this case.The plea agreement provided that Defendant would plead guilty to second-degree arson, that Defendant would cooperate in an interview regarding other suspicious fires, and that the State would not bring charges regarding the other fires. Defendant pled guilty. Thereafter, the State decided not to hold the interview and advised Defendant that he would be charged with other arsons. The State gave Defendant an opportunity to withdraw from the plea agreement, but Defendant declined to withdraw. The State brought four additional arson charges, and Defendant moved to dismiss them as breach of the plea agreement. The district court denied the motion. The Supreme Court reversed, holding (1) the State could not unilaterally withdraw from the plea agreement by declining to conduct the interview; and (2) Defendant did not ratify the State's modification of the plea agreement by refusing the State's offer of rescission. View "State v. Beres" on Justia Law

The Supreme Court affirmed Defendant's conviction for assault on a peace officer with a dangerous weapon, a felony, and several misdemeanors, holding that Defendant did not receive ineffective assistance of counsel.After Defendant pleaded guilty, he absconded. He was later returned to custody. On appeal, Defendant argued that he received ineffective assistance of counsel because the plea bargain contained an unlawful term. Specifically, Defendant argued that the plea bargain's provision that he would be released from jail for a forty-eight-hour furlough after pleading guilty was illegal and that his trial counsel committed ineffective assistance in obtaining the illegal benefit for him. The Supreme Court affirmed, holding that where Defendant entered into the plea agreement with the illegally lenient sentence, he could not benefit from that sentence and then attack the plea bargain. View "State v. Gordon" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder after declining Defendant's invitation to change constitutional precedent to further limit the admissibility of eyewitness identifications following police photo arrays, holding that the double-blind procedures used in this case were not unduly suggestive and that Defendant received effective assistance of counsel.On appeal, Defendant argued (1) because the police used unduly suggestive photographic identification procedures the district court erred by failing to grant his motion to suppress the resulting identification; and (2) trial counsel was ineffective for failing to request jury instructions on eyewitness identifications that reflect modern scientific research. The court of appeals affirmed the conviction while preserving for possible postconviction relief action Defendant's ineffective assistance of counsel claim. The Supreme Court affirmed in part and vacated in part the court of appeals' decision, holding (1) the eyewitness identification was not unduly suggestive; and (2) contrary to the decision of the court of appeals, the record was adequate to decide the ineffective assistance of counsel claim challenging the jury instruction on eyewitness identification, and this claim is rejected on the merits. View "State v. Booth-Harris" on Justia Law

The Supreme Court vacated in part and affirmed in part the decision of the court of appeals declining relief on Defendant's claims that his trial counsel provided ineffective assistance for failing to object to the crime victim's first-time, in-court identification of Defendant, holding that Defendant's trial counsel did not provide constitutionally deficient representation for failing to object to the victim's trial testimony.The court of appeals affirmed Defendant's conviction, concluding that the record was inadequate to decide Defendant's ineffective-assistance-of-counsel claims but preserved those claims for post conviction proceedings. The Supreme Court vacated the judgment in part, holding (1) the record was adequate to decide Defendant's ineffective-assistance-of-counsel claim, but the claim is rejected because precedent permits first-time, in-court identifications; and (2) the court of appeals decision stands on the remaining issues. View "State v. Doolin" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder in the second degree, holding that Defendant's Fifth Amendment rights were invaded when the trial judge instructed the jury that Defendant was required to notify law enforcement of his use of deadly force, but the error was harmless.During trial, Defendant asserted the defense of justification in his shooting of the victim. At issue on appeal was whether the district court abused its discretion by giving a jury instruction incorporating the terms of Iowa Code 704.2B. The instruction included a statement that a person using deadly force is required to notify law enforcement about his use of deadly force. Defendant argued before the Supreme Court that both section 704.2B and the jury instruction incorporating that section violated his Fifth Amendment rights. The Supreme Court affirmed, holding (1) instructing the jury that a homicide defendant is required to notify a law enforcement agency of his use of deadly force violates the defendant's Fifth Amendment rights; but (2) any error in this case was harmless beyond a reasonable doubt. View "State v. Gibbs" on Justia Law

The Supreme Court affirmed Defendant's conviction of voluntary manslaughter and assault with intent to cause serious injury, holding that Defendant was not entitled to a pretrial evidentiary hearing and that Defendants remaining challenges were without merit.Defendant was charged with one count of murder and two counts of attempted murder. Following a jury trial, Defendant was convicted of the lesser included offenses of one count of voluntary manslaughter and two counts of assault with intent to cause serious injury. On appeal Defendant argued, among other things, that the district court should have held a pretrial hearing pursuant to section 704.13 to determine his immunity from prosecution before trial. The Supreme Court affirmed, holding (1) the district court did not err in refusing to conduct a pretrial hearing on Defendant's justification defense; (2) the trial evidence was sufficient to prove lack of justification; and (3) Defendant's remaining allegations of error were without merit. View "State v. Wilson" on Justia Law

The Supreme Court vacated Defendant's guilty plea to possessing a tool with the intent to use it in the unlawful removal of a theft detection device under Iowa Code 714.7B(3), holding that there was no factual basis to support Defendant's guilty plea to this charge.Defendant's conviction arose from his act of using bolt cutters to cut the padlock off of a steel cable wrapped around a riding lawn mower on display outside of a Mills Fleet Farm. Defendant pled guilty violating section 714.7B(3). On appeal, Defendant argued that the padlock-steel cable combination device he cut with bolt cutters was not a "theft detective device" under section 714.7B, and therefore, his trial counsel was ineffective for allowing him to plead guilty to this charge.The Supreme Court agreed and vacated Defendant's guilty plea, holding (1) the padlock-steel cable combination did not constitute a "theft detective device" under the statute, and therefore, there was no factual basis to support Defendant's guilty plea; and (2) Defendant's counsel was ineffective for allowing Defendant to plead guilty. View "State v. Ross" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of child endangerment, holding that the evidence was sufficient to support Defendant's conviction.During trial, the State was required to prove Defendant had custody of her child and that she knowingly acted in a manner that created a substantial risk to her child's health or safety. The district court concluded that the State met its burden of production and persuasion. The Supreme Court affirmed, holding that Defendant's failure to remove her child from a physical environment that caused a risk of fire was sufficient to establish that Defendant had knowledge she had created or allowed her child to remain in a physical environment that posed a substantial risk to her child's physical health and safety. View "State v. Folkers" on Justia Law

The Supreme Court annulled the writ of certiorari sought by Defendant after the district court denied his motion to correct an illegal sentence, holding that Iowa Code 124.413 and 901.12 serve to reduce the minimum period of confinement for specific criminal drug offenses and that Defendant's minimum period of confinement was not eligible for the one-half reduction.Defendant pled guilty to possession of methamphetamine with intent to deliver and to possession or control of a firearm. Defendant's guilty plea to the firearm charge enhanced the drug charge by doubling his maximum sentence to fifty years. The legislature later amended section 124.413 and created section 901.12, which amended Iowa law by retroactively reducing particular mandatory sentences by one-half. Defendant filed a motion to correct an illegal sentence arguing that section 901.12 reduced his minimum period of confinement by one-half. The district court denied the motion. The Supreme Court granted certiorari review but then annulled the writ, holding that Defendant's firearm-enhanced sentence was not eligible for the one-half reduction. View "Campuzano v. Iowa District Court for Polk County" on Justia Law

The Supreme Court dismissed Appellant's appeal from an order of the district court directing Appellant to pay room and board reimbursement for the seventy-eight days Appellant spent in the Mills County jail, holding that this Court lacked jurisdiction to consider matters raised in the restitution order or any other subsequent order of the court.On September 24, 2018 Appellant entered guilty pleas in two sex abuse cases. On October 5, after Appellant was sentenced, the sheriff a room and board reimbursement claim seeking a total of $4680 for the time Appellant spent in jail. The district court approved the claim and ordered Appellant to pay the amount. Appellant appealed, seeking relief from the district court's September 24 order. However, Appellant's entire argument was a challenge to the October 5 order. The Supreme Court dismissed the appeal, holding that it lacked jurisdiction to consider matters raised in the October 5 restitution order. View "State v. Boyer" on Justia Law