Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's convictions for misdemeanor possession of of marijuana and felony eluding with marijuana, holding that the convictions do not merge.After convicting Defendant the district court imposed concurrent sentences. On appeal, Defendant argued that the possession convictions merged with the eluding charges. The State argued in response that the statutory scheme demonstrates that the legislature intended cumulative punishments for these offenses. The Supreme Court affirmed, holding (1) under the legal-elements test, it is impossible to commit felony eluding with marijuana without possessing it; but (2) the legislature prescribed cumulative punishments for the two offenses. View "State v. Johnson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the judgment of the district court ordering Defendant to register as a sex offender after he entered an Alford plea to child endangerment, holding that the evidence was insufficient to prove sexual motivation beyond a reasonable doubt under Iowa Code 692A.126 and that the proper remedy was to remand and give the State an opportunity to prove sexual motivation.The district court relied on Defendant's Alford plea and a victim impact statement from the child victim's mother to find that Defendant's underlying conduct was sexually motivated. The court ordered Defendant to register as a sex offender. The court of appeals remanded the cause, finding that victim statements do not provide sufficient evidence that the offense of conviction was sexually motivated beyond a reasonable doubt but that the minutes of testimony identified evidence to establish that the offense could have been sexually motivated. The Supreme Court affirmed the court of appeals, vacated the order requiring Defendant to register as a sexual offender, and remanded, holding that, under the circumstances, the State is allowed to introduce the facts from the minutes in an effort to support its request that Defendant be required to register as a sex offender. View "State v. Chapman" on Justia Law

The Supreme Court reversed the judgment of the district court convicting Defendant of violating Iowa Code 724.4C, which criminalizes carrying a dangerous weapon while intoxicated, holding that the jury instructions were erroneous because section 724.4C prohibits only carrying, which requires more than mere possession.On appeal, Defendant argued that the jury instructions improperly allowed the jury to convict him based on conduct not covered under the statute. Specifically, Defendant argued that the jury could have convicted him on a finding of possession alone, rather than carrying a dangerous weapon. The Supreme Court reversed and remanded the case for a new trial, holding (1) the jury instructions that allowed the jury to convict Defendant if he either carried or possessed a dangerous weapon misstated the law; and (2) the instructional error prejudiced Defendant and required reversal. View "State v. Shorter" on Justia Law

In this criminal action, the Supreme Court vacated the restitution awarded and clarified State v. Albright, 925 N.W.2d 144 (Iowa 2019), holding that defendants may seek appellate review of interim restitution orders in a direct appeal of right from the judgment of conviction.Appellant filed a direct appeal from his judgment of conviction, challenging only the restitution award, which was awarded without a determination of his reasonable ability to pay and without a final order of restitution. The State argued that under Albright, which held that "any temporary, permanent, or supplemental order regarding restitution is not appealable or enforceable until the court files its final order of restitution," the appeal must be dismissed. The Supreme Court vacated the restitution orders, holding (1) interim restitution orders are not enforceable until the district court determines the defendant's reasonable ability to pay all items of restitution and enters the final order of restitution; (2) there is no right of direct appeal from interim restitution orders preceding the court's final order of restitution, but defendants may seek appellate review of interim restitution orders in a direct appeal of right from the judgment of conviction; and (3) because the district court did not have the benefit of Albright, this case is remanded for further proceedings. View "State v. Davis" on Justia Law

The Supreme Court vacated the order of restitution in this criminal case for the reasons explained today in State v. Davis, __ N.W.2d __ (Iowa 2020), concluding that interim orders on components of restitution requiring a reasonable ability to pay are neither appealable nor enforceable, but because the district court did not have the benefit of State v. Albright, 925 N.W.2d 144 (Iowa 2019) in issuing the restitution order, the order is vacated and the case remanded for further proceedings.Defendant entered a guilty plea to sexual abuse in the third degree. The court placed Defendant on probation, ordered him to register as a sex offender, and ordered that Defendant pay $204 in court costs, stating that additional amounts could be assessed at a later date. Defendant filed this direct appeal from his judgment of sentence, arguing that the district court erred in ordering him to pay restitution when it did not know the total amount of those costs and had not conducted a reasonable-ability-to-pay determination. The State argued in response that Defendant's appeal was unripe because no final restitution order had been entered. The Supreme Court vacated the restitution order and remanded the matter for further proceedings because the district court did not have the benefit of Albright. View "State v. Staake" on Justia Law

In this criminal case arising from Appellant's act of writing checks without authorization from a bank account that was not hers the Supreme Court reversed the judgment of the district court denying Appellant's motion for acquittal, holding that the State failed to present sufficient evidence supporting a conviction under Iowa Code 714.1(6).Appellant was convicted under section 714.1(6), which forbids knowingly presenting a check that will not be paid when presented. The checks the State charged Appellant with writing were paid when presented. On appeal, Appellant argued that presenting a check without authorization was different than providing a check one knows will not be paid when presented. The Supreme Court agreed and reversed, holding that the State failed to present sufficient evidence that Appellant knew the checks would not be paid when presented, and therefore, there was insufficient evidence to support Appellant's conviction under section 714.1(6). View "State v. Schiebout" on Justia Law

The Supreme Court affirmed Defendant's sentence for theft after Defendant pleaded guilty, holding that "good cause" under the newly amended Iowa Code 814.6 means a "legally sufficient reason," and the good cause requirement is satisfied when the defendant appeals a sentence that was neither mandatory nor agreed to in the plea bargain.Defendant pleaded guilty to two separate charges of theft in the third degree. The court sentenced Defendant to an indeterminate term of two years of incarceration for each case to run concurrently. Defendant appealed, arguing that the sentencing court abused its discretion by considering improper factors when imposing her sentence. The State responded that the Supreme Court lacked jurisdiction over Defendant's appeal without a showing of good cause under the newly amended Iowa Code 814.6. The Supreme Court affirmed, holding (1) Defendant satisfied the good-cause requirement to proceed with her appellate challenge to the sentence; and (2) on the merits, Defendant's challenge to her sentence failed. View "State v. Damme" on Justia Law

The Supreme Court affirmed Defendant's sentence for indecent contact with a child, holding that Defendant satisfied the good-cause requirement to challenge his sentence as an abuse of discretion but that, on the merits, his challenge failed.Defendant pleaded guilty to indecent contact with a child. The court sentenced Defendant to two years in prison and to ten years' special parole after completion of his prison term. The court further ordered Defendant to register as a sex offender for ten years and complete the sex offender treatment program. Defendant appealed. The State filed a motion to dismiss the appeal, arguing that entering an Alford plea is not good cause to appeal. The Supreme Court held that Defendant had shown good cause but failed to establish that any alleged errors warranted resentencing. View "State v. Henderson" on Justia Law

The Supreme Court granted Jane Doe's petition for writ of certiorari, sustained the writ, and vacated the order of the district court denying Doe's application to expunge her criminal record as to three separate cases pursuant to Iowa Code 901C.2, holding that the court erred in denying the application on the ground that Doe had court-ordered financial obligations in other cases.In the three separate cases at issue the charges were all dismissed. Doe later filed an application for expungement of the record in each of the cases. The district court denied the application on the ground that Doe had "[m]onies owed in other matters." The Supreme Court vacated the district court's order denying expungement, holding (1) pursuant to State v. Doe, __ N.W.2d __ (Iowa 2020), filed today, the requisite condition for expungement requires that the defendant establish only that he satisfied all of the court-ordered financial obligations in the criminal case for which expungement was sought; and (2) in the instant case, the district court erred in concluding that Iowa Code 901C.2(1)(a)(2) required Defendant to establish that she also satisfied all court-ordered financial obligations in other cases. View "Doe v. State" on Justia Law

The Supreme Court granted John Doe's petition for writ of certiorari, sustained the writ, and vacated the order of the district court denying Doe's application to expunge his criminal record as to a particular case pursuant to Iowa Code 901C.2, holding that the court erred in denying the application on the ground that Doe had court-ordered financial obligations in other cases.In 2000, Doe was charged with escape. The charge was later dismissed. In 2019, Doe filed an application for expungement of the record. The district court denied the application on the ground that Doe had court-ordered financial obligations in other cases. The Supreme Court vacated the district court's order denying expungement, holding (1) pursuant to State v. Doe, __ N.W.2d __ (Iowa 2020), filed today, the requisite condition for expungement requires that the defendant establish only that he satisfied all of the court-ordered financial obligations in the criminal case for which expungement was sought; and (2) in the instant case, the district court erred in concluding that section 901C.2(1)(a)(2) required Defendant to establish that he also satisfied all court-ordered financial obligations in other cases. View "Doe v. State" on Justia Law