Justia Criminal Law Opinion Summaries

In this wrongful death action the Supreme Court affirmed the order of the district court entering judgment for Defendant, holding that Plaintiffs did not preserve any issues for appellate review.A jury determined that Defendant was not liable for wrongful death and awarded no damages. The district court subsequently entered judgment for Defendant. Plaintiff filed a posttrial combined motion for new trial and change of venue, alleging a violation of a granted motion in limine, undue influence of Defendant over the jury, and other trial court errors. The district court denied the post trial motion. Plaintiff appealed. The Supreme Court affirmed, holding that Plaintiff was deemed to have waived and abandoned her posttrial motion, and therefore, Plaintiff did not preserve any issues for appellate review. View "Freer v. DAC, Inc." on Justia Law

The Supreme Court reversed the judgment of the district court summary judgment for the State on Appellant's application for postconviction relief (PCR) after denying Appellant's request to appoint an expert, holding that the district court abused its discretion in denying the expert and that the summary disposition was erroneous.After a jury trial, Appellant was found guilty of first-degree murder. Appellant was sentenced to life imprisonment. In her petition for postconviction relief Appellant asserted, among other claims, that her trial counsel was ineffective for failing to raise battered woman syndrome (BWS) in her trial and for not adducing BWS evidence. To prove her claim, Appellant sought a court-appointed BWS expert. The district court denied Appellant's request to appoint an expert and, simultaneously, cited Appellant's failure to provide an expert in granting summary judgment. The Supreme Court reversed, holding that the summary disposition was erroneous where the court, among other errors, concluded that the record did not show facts to support Appellant's claim that BWS should have been raised at her trial. View "Linn v. State" on Justia Law

The Supreme Court vacated the decision of the court of appeals reversing Defendant's conviction of second-degree murder, holding that Defendant was not entitled to a new trial on any of his allegations of error.After trial, Defendant filed a motion for a new trial alleging, among other things, that the trial court erred in refusing to disqualify a juror who allegedly made out-of-court statements regarding Defendant's guilt and misconduct and bias related to extraneous information reaching the jury about a possible riot if a certain verdict was not returned. The district court denied the motions for a new trial and entered judgment. The court of appeals reversed, concluding that juror misconduct and bias warranted a new trial. The Supreme Court vacated the decision of the court of appeals and affirmed the district court judgment, holding that Defendant was not entitled to a new trial under the facts of this case. View "State v. Christensen" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming in part and reversed in part the judgment and sentence of the district court convicting Defendant of operating while intoxicated (OWI) second offense, holding that the clause of the OWI statutes that makes it unlawful for a person to operate a motor vehicle with any amount of a controlled substance in his or her person does not violate the Due Process Clause of either the United States or Iowa Constitution as applied to the facts of this case.The court of appeals found Iowa Code 321J.2(a)(c), which makes it unlawful for a person to operate a motor vehicle "[w]hile any amount of a controlled substance is present in the person," does not violate due process guarantees but reversed the judgment and sentence after concluding that the district court failed to engage in a proper colloquy before accepting a stipulation relating to the prior conviction for OWI. The Supreme Court only addressed the due process claim and affirmed the court of appeals as to the remaining issues, holding that section 321J.2(1)(c) does not violate the requirements of due process under the federal or state Constitutions as applied to this case. View "State v. Newton" on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's application for postconviction relief, holding that a factual basis did not exist for the element of confinement to support Defendant's guilty plea to the crime of kidnapping in the second degree.In her postconviction relief application Defendant asserted that her trial counsel was ineffective for permitting her to plead guilty to kidnapping because no facts were presented to show that she impeded the victim's movement by pointing a handgun at the victim for a period of time before shooting and killing him. The district court denied Defendant's application, finding that a factual basis for confinement existed to support the plea of guilty. The Supreme Court reversed, holding that the record did not contain a factual basis to demonstrate that Defendant confined the victim in a manner to support an independent kidnapping charge. View "Sauser v. State" on Justia Law

The Supreme Court conditionally affirmed Defendant's conviction and sentence for first-degree murder but remanded for further proceedings consistent with decisions it also filed today in State v. Lilly, __ N.W.2d __ (Iowa 2019), and State v. Veal, __ N.W.2d __ (Iowa 2019), and this opinion, holding that further consideration of Defendant's claim that his jury was not drawn from a fair cross section of the community, in violation of the Sixth Amendment to the United States Constitution and article I, section 10 of the Iowa Constitution, was warranted.Defendant, an African-American, was charged with first-degree murder in a county that was approximately 2.3 percent African-American in population. The jury pool of unexcused jurors, however, contained only one African-American. The Supreme Court held (1) as in Lilly and Veal, the appropriate course of action is to remand the case to offer Defendant a further opportunity to develop his arguments that his Sixth Amendment right to an impartial jury was violated; and (2) Defendant's remaining claims of error did not warrant a new trial. View "State v. Williams" on Justia Law

The Supreme Court conditionally affirmed Defendant's conviction for aiding and abetting a bank robbery and remanded for further consideration of Defendant's claim that his jury was not drawn from a fair cross section of the community, in violation of the Sixth Amendment to the United States Constitution and article I, section 10 of the Iowa Constitution, holding that further consideration of this claim was warranted.Defendant, an African-American, was convicted following a trial by a jury that contained no African-Americans. Further, there were no African-Americans in the jury venire that reported that day. On appeal, Defendant argued that the racial composition of the jury pool violated his rights to an impartial jury under both the federal and the state constitution. The Supreme Court held that the typical jury management practices can support a systematic exclusion claim under the framework established in State v. Plain, 898 N.W.2d 801 (Iowa 2017), and Duren v. Missouri, 439 U.S. 357 (1979), where the evidence shows one or more of those practices have produced underrepresentation of a minority group, and this case will be remanded to give Defendant a further opportunity to develop his fair-cross-section claim. View "State v. Lilly" on Justia Law

The Supreme Court conditionally affirmed Defendant's conviction of two counts of first-degree murder while remanding the case for further proceedings consistent with State v. Lilly, __ N.W.2d __ (Iowa 2019), also decided today, holding that further consideration of Defendant's claim of violation of his right to an impartial jury drawn from a fair cross section of the community was warranted.Defendant was an African-American. Although the jury venire contained five African-Americans, no African-American was seated on the jury that heard Defendant's case. On appeal, Defendant asserted a number of trial-related issues, including the claim that his jury was not drawn from a fair cross section of the community in violation of the Sixth Amendment. The Supreme Court held (1) as in Lilly, the appropriate course of action is to remand the case to offer Defendant a further opportunity to develop his arguments that his Sixth Amendment right to an impartial jury was violated; and (2) Defendant's remaining claims did not warrant reversal. View "State v. Veal" on Justia Law

The Supreme Court affirmed the ruling of the district court denying Jane Doe's motion to expunge her record, holding that the condition in Iowa Code 901C.2, the expungement statute, that an individual pay all court-imposed costs and fees does not violate the Equal Protection Clauses of the United States or Iowa Constitutions.Section 901C.2 creates a statutory right to expungement subject to several conditions. Doe was an indigent defendant who was denied expungement for failure to pay off her court-appointed attorney fees. On appeal, Defendant argued that the condition that she pay her court-appointed attorney fees violated her equal protection rights. The district court denied Doe's constitutional challenge and denied her motion to expunge her record. The Supreme Court affirmed, holding that the requirement to pay court costs, including court-appointed attorney fees, is rationally related to the government interest in collecting court debt. View "State v. Doe" on Justia Law

The Supreme Court vacated in part Defendant's sentence, holding that because the district court did not have the benefit of the procedures outlined in State v. Albright, __ N.W.2d __ (Iowa 2019), when it entered its order regarding restitution, the part of the sentencing order regarding restitution must be vacated and the case remanded to the district court to impose restitution consistent with Albright.Defendant pled guilty to driving while her license was barred. On appeal, Defendant argued that the district court erred in ordering her to pay restitution for attorney fees and correctional costs without determining the amounts of those obligations or her ability to pay court costs. The Supreme Court vacated the part of the sentencing order regarding restitution, holding that remand was necessary for reconsideration in light of Albright. View "State v. Perry" on Justia Law