Justia Criminal Law Opinion Summaries

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

The Supreme Court affirmed Defendant's conviction, holding that the district court did not err in denying Defendant's motion to suppress the results of a chemical breath test where the officer administering the test allegedly violated Defendant's statutory right to obtain additional chemical testing.On appeal, Defendant argued that the district court erred in denying his motion to suppress evidence allegedly obtained in violation of his statutory right under Iowa Code 321J.11. The statute creates a right for a detainee or arrestee to have an independent chemical test administered at the person's own expense in addition to any test administered at the direction of an officer. A detainee or arrestee invokes the statutory right by making "any statement that can be reasonably construed as a request for an independent chemical test." The Supreme Court affirmed, holding that substantial evidence supported the district court's finding that Defendant did not inquire about his right to take an independent test, and therefore, the district court did not err in denying Defendant's motion to suppress evidence. View "State v. Smith" on Justia Law

The Supreme Court affirmed Defendant's sentencing procedure but vacated the portion of Defendant's sentence regarding restitution, holding that remand was necessary for the district court to impose restitution consistent with this Court's decision in State v. Albright, __ N.W.2d __ (Iowa 2019).Defendant was convicted of domestic abuse assault causing bodily injury. The court of appeals affirmed Defendant's sentence. The Supreme Court granted further review and let the court of appeals decision stand as this Court's final decision regarding the issue of whether the district court gave Defendant his right of allocution. As to Defendant's argument that the district court erred in ordering him to pay restitution without first determining his reasonable ability to pay, the Supreme Court held that Defendant's sentence regarding restitution should be vacated and the case remanded for the district court to impose restitution consistent with Albright. View "State v. Weston" on Justia Law

The Supreme Court affirmed Defendant's conviction but vacated the portion of Defendant's sentence regarding restitution, holding that remand was required because the district court did not have the benefit of the procedures outlined in State v. Albright, __ N.W.2d __ (Iowa 2019).The court of appeals affirmed Defendant's conviction, holding that Defendant's counsel was not ineffective for failing to challenge the sufficiency of the evidence. The court further found that the district court did not err in assessing restitution for appellate attorney fees. The Supreme Court granted further review and affirmed Defendant's conviction, letting the court of appeals decision stand as this Court's final decision regarding Defendant's ineffective assistance of counsel claims. As to Defendant's argument that the district court erred in ordering him to pay restitution in the form of appellate attorney fees without first determining his reasonable ability to pay those fees, the Court held that the restitution part of Defendant's sentence regarding those fees should be vacated and the case remanded to the district court to impose restitution consistent with this Court's decision in Albright. View "State v. Dieckmann" on Justia Law

The Supreme Court affirmed the part of the district court's judgment sentencing Defendant to five years' imprisonment but vacated the restitution part of his sentence, holding that remand was required for the district court to impose restitution consistent with this Court's decision in State v. Albright, __ N.W.2d __ (Iowa 2019).Defendant was sentenced to five years' imprisonment for theft in the second degree. The district court also assessed financial obligations to him. The court of appeals affirmed Defendant's sentence. The Supreme Court granted transfer and let the court of appeals decision stand as this Court's final decision regarding Defendant's term of imprisonment. As to Defendant's argument that the district court erred in ordering him to pay restitution in the form of appellate attorney fees without first determining his reasonable ability to pay those fees, the Court held that the restitution part of Defendant's sentence should be vacated and the case remanded for the district court to impose restitution consistent with Albright. View "State v. Steenhoek" on Justia Law

The Supreme Court affirmed Defendant's conviction but vacated that part of the sentencing order regarding restitution and remanded the case to the district court to impose restitution consistent with State v. Albright, __ N.W.2d __(Iowa 2019), holding that remand was necessary because the district court did not have the benefit of the procedures outlined in Albright when it entered its order regarding restitution.Defendant was convicted of second-degree sexual abuse of a child under the age of twelve. On appeal, Defendant argued, among other things, that the district court erred in imposing the jail fee without first determining the amount of the fee. The court of appeals affirmed Defendant's conviction but vacated that portion of the sentence dealing with restitution. The Supreme Court let the court of appeals' decision stand as the Court's final decision, thus affirming Defendant's conviction. As to Defendant's sentence, the Court held that the restitution part of Defendant's sentence should be vacated because Albright, which clarified restitution requirements, was filed after the court of appeals decision in this case. View "State v. Tournier" on Justia Law

The Supreme Court affirmed in part and vacated in part the decision of the court of appeals affirming Defendant's conviction and vacating the part of Defendant's sentence dealing with restitution, holding that there was no error in Defendant's conviction but that the case must be remanded to the district court to impose restitution consistent with State v. Albright, __ N.W.2d __ (Iowa 2019).Defendant was convicted of second-degree murder. On appeal, Defendant argued (1) the district court erred in denying his motion to continue the trial and admitting a video recording of his police interview into evidence, and (2) the court erred in requiring him to make restitution of appellate attorney fees without first determining his reasonable ability to pay those fees. The court of appeals vacated the portion of the sentence dealing with restitution and remanded the case for entry of a corrected sentencing order. The Supreme Court affirmed Defendant's conviction but found that the restitution part of his sentence should be vacated. The Court held that because the district court did not have the benefit of the procedures outlined in Albright when it entered its order regarding restitution, the portion of the sentencing order regarding restitution must be vacated and remanded. View "State v. Crawford" on Justia Law

The Supreme Court affirmed in part and vacated in part the decision of the court of appeals affirming Defendant's conviction and the district court order requiring Defendant to pay restitution for court costs and attorney fees, holding that the part of the sentencing order regarding restitution must be vacated and remanded for resentencing consistent with this Court's decision in State v. Albright, __ N.W.2d __ (Iowa 2019).The court of appeals affirmed Defendant's conviction for first-degree burglary and assault causing bodily injury but remanded the case for resentencing because it found the assault causing bodily injury conviction merged with the first-degree burglary conviction. The court of appeals also affirmed the part of the sentencing order requiring Defendant to pay restitution for court costs and attorney fees. The Supreme Court let the court of appeals' decision stand as the Court's final decision regarding all of Defendant's claims except Defendant's claim that the district court erred in ordering him to pay restitution without first determining his reasonable ability to pay these items of restitution. The Supreme Court vacated the restitution portion of Defendant's sentence, holding that because the district court did not have the benefit of the procedures outlined in Albright when it entered its restitution order, remand was required. View "State v. Mosley" on Justia Law

The Supreme Court vacated the restitution portion of Defendant's sentence and affirmed the remainder of the sentence, holding that the district court erred in ordering restitution without first conducting the applicable reasonable-ability-to-pay analysis but otherwise did not err.Defendant was convicted and sentenced for domestic abuse assault and second-degree burglary. The Supreme Court remanded the case for resentencing in light of this opinion and the Court's opinion in State v. Albright, __ N.W.2d __ (Iowa 2019), holding (1) the district court did not abuse its discretion by considering the risk assessment tools on their face as contained within the presentence investigation report (PSI); (2) Defendant failed to preserve error on his due process and abuse of discretion claims regarding the court's consideration of the risk assessment tools contained in the PSI; (3) the district court did not abuse its discretion in considering the department of correctional services' sentencing recommendation; (4) the district court did not err in requiring Defendant to pay the court costs associated with dismissed charges; but (5) the district court improperly ordered restitution without first determining Defendant's reasonable ability to pay. View "State v. Headley" on Justia Law