Justia Criminal Law Opinion Summaries

The case involves Amy Lois Rasmussen, who was charged with two counts of assault causing bodily injury and one count of simple assault following a confrontation with three women outside Boone City Hall. The confrontation turned physical, resulting in injuries to all three women. Rasmussen entered an Alford guilty plea to the two counts of assault causing bodily injury, and in exchange, the State dismissed a related simple misdemeanor charge involving the third victim. The district court rejected both parties’ sentencing recommendations and sentenced Rasmussen to consecutive one-year sentences for each count. It also issued no-contact orders prohibiting Rasmussen's contact with the two victims of assault causing bodily injury and the victim in the dismissed simple misdemeanor case.The case was initially reviewed by the Iowa Court of Appeals, which affirmed Rasmussen's sentence and the no-contact orders. Rasmussen appealed, arguing that the district court considered improper factors in determining her sentence and lacked jurisdiction to issue a no-contact order regarding the victim in the dismissed simple misdemeanor case.The Supreme Court of Iowa affirmed Rasmussen's conviction and sentence concerning the consecutive one-year sentences and the no-contact orders involving the two victims of assault causing bodily injury. However, it found that the no-contact order in the dismissed case was void. The court held that the district court lacked jurisdiction to enter a no-contact order after it dismissed the charge related to the third victim. The court remanded the issue to the district court for a hearing solely on whether a no-contact order involving the third victim should be entered in the serious misdemeanor case. View "State of Iowa v. Rasmussen" on Justia Law

The case revolves around Abel Gomez Medina, who was convicted of sexual abuse and indecent contact with a minor. The minor, identified as Dorothy, was his stepdaughter. She reported the abuse to her school counselor, stating that it had been ongoing since she was eleven years old. Dorothy's stepbrother, Frank, also testified that he had witnessed inappropriate behavior between Medina and Dorothy. The defense presented witnesses who claimed they had never seen anything inappropriate between Medina and Dorothy.Prior to the trial, the State moved to permit Dorothy and Frank to testify via closed-circuit television, citing the potential trauma caused by in-person testimony. The district court granted this for Dorothy but denied it for Frank. During the trial, Dorothy turned eighteen and Medina objected to her continuing to testify via closed-circuit television, arguing that the statute permitting such testimony only applied to minors. The district court overruled this objection, citing a different paragraph of the statute that allowed for closed-circuit testimony for victims or witnesses with mental illnesses, regardless of age.Medina appealed his conviction, arguing that allowing Dorothy to testify via closed-circuit television violated both the Iowa Code and the Confrontation Clause of the United States Constitution. The court of appeals affirmed Medina's convictions, holding that permitting Dorothy’s closed-circuit testimony satisfied constitutional requirements while she was a minor, and that by meeting the requirements under Iowa Code after she turned eighteen, Medina’s claim of a Confrontation Clause violation similarly failed. Medina then filed an application for further review of the court of appeals ruling, which was granted by the Supreme Court of Iowa.The Supreme Court of Iowa affirmed the decisions of the lower courts. It concluded that Medina had failed to preserve error on his Confrontation Clause argument concerning Dorothy’s testimony after she turned eighteen. The court also found that the district court had properly applied the statute to permit Dorothy’s closed-circuit testimony, based on the evidence presented at the pretrial hearing. The court let the court of appeals decision stand on Medina's arguments that the district court abused its discretion by allowing the prosecutor to comment during closing argument and by excluding 911 call logs. View "State v. Medina" on Justia Law

The case involves a convicted felon, Adam Aaron Rhodes, who was charged with possession of a firearm, a muzzleloader replica of an antique firearm, in violation of Iowa Code section 724.26(1). Rhodes argued that his muzzleloader, used to kill a deer, was not a firearm within the meaning of the statute because it was a replica of an antique firearm, which is excluded from the statutory definition of "offensive weapon," and federal law excludes such muzzleloaders from the federal definition of "firearm."The district court disagreed with Rhodes, finding him guilty of possessing a "firearm" under the common meaning of the term and the court's precedent. The court defined a "firearm" broadly to include "any instrument which will or is designed to discharge a projectile by the force of a chemical explosive such as gun powder." The court also rejected several affirmative defenses raised by Rhodes, including a void for vagueness constitutional challenge. Rhodes was sentenced to probation for a period not to exceed five years.On appeal, the Supreme Court of Iowa affirmed the district court's judgment. The court held that Rhodes's muzzleloader falls within the meaning of "firearm" in section 724.26. The court reasoned that the Iowa legislature declined to enact the federal definition of "firearm" and that the court's precedents apply the common meaning of "firearm" that encompasses this muzzleloader rifle. The court also rejected Rhodes's argument that the court should follow the federal felon-in-possession statute, 18 U.S.C. § 922(g), when interpreting Iowa’s felon-in-possession statute. The court concluded that the Iowa legislature is free to adopt the federal exception for antique firearms but has not done so. View "State of Iowa v. Rhodes" on Justia Law

In this case, the Supreme Court of Iowa was asked to determine who should bear the costs of a technology vendor hired to review a large volume of emails seized under a search warrant for potential attorney-client privileged communications. The emails belonged to a criminal defendant, Craig Juan Merrill, who was charged with multiple counts of ongoing criminal conduct, theft, assault, and misconduct in office. The search warrant stipulated that the seized materials would be reviewed by the district court to ensure no attorney-client privileged materials were inadvertently handed over to the prosecution.However, due to the large volume of emails and technical difficulties, the district court was unable to complete the review and decided to hire a technology vendor to assist. The question of who should bear the costs of this vendor became a point of contention. The district court initially ordered the prosecution to pay the costs, but left open the possibility that the costs could be taxed to the defendant at the conclusion of the case.The State of Iowa filed a petition for writ of certiorari with the Supreme Court of Iowa, arguing that the district court acted illegally in assessing the costs of the privilege review against the prosecution. The State contended that the judicial branch should bear the costs, as the vendor was effectively acting as a special master to assist the court.The Supreme Court of Iowa sustained the writ, ruling that the judicial branch should be responsible for the costs of the technology vendor. The court reasoned that the district court had voluntarily assumed the responsibility of conducting the initial privilege review and, when it was unable to do so, it was compelled to employ a third-party vendor. Under these unique circumstances, the court concluded that the judicial branch must bear the costs of the vendor it employed. View "State of Iowa v. Iowa District Court For Emmet County" on Justia Law

The case involves a defendant, Brandon Lee, who was convicted of two counts of first-degree robbery, willful injury causing serious injury, willful injury causing bodily injury, theft in the first degree, and impersonating a public official. The charges stemmed from an incident where Lee, posing as a law enforcement officer, assaulted a husband and wife in their home and stole $50,000 from their safe.The case was first heard in the Iowa District Court for Linn County, where Lee was found guilty of all six charges. He was sentenced to twenty-five years for each conviction of robbery in the first degree, ten years for willful injury causing serious injury, five years for willful injury causing bodily injury, ten years for theft in the first degree, and two years for impersonating a public official. The sentences for the two robbery convictions were ordered to be served consecutively, for a total of fifty years, with a minimum sentence of thirty years before being eligible for parole. The remaining sentences were ordered to be served concurrently to each other and consecutively to the robbery convictions.The case was then brought to the Supreme Court of Iowa on appeal. Lee argued that there was insufficient evidence to sustain a conviction for two counts of first-degree robbery, asserting that he did not intend to commit two separate and distinct thefts. The Supreme Court disagreed, finding that the evidence was sufficient to conclude that Lee intended to commit two separate and distinct thefts. Therefore, the Supreme Court affirmed both convictions and sentences for first-degree robbery. View "State of Iowa v. Lee" on Justia Law

The defendant, Christopher James Wilson, was charged with two counts of indecent exposure after he was seen masturbating in public by two women, E.H. and T.A., at a gas station. Wilson followed the women to another location where he continued his actions. He was subsequently arrested and charged. After a jury trial, he was convicted on both counts and sentenced to an enhanced sentence under Iowa Code section 901A.2(1) to an indeterminate prison term of two years for the first count and an indeterminate prison term of two years for the second count. The sentence for count one was ordered to run consecutively to the sentence for count two.Wilson appealed his conviction and sentence, arguing that the unit of prosecution for indecent exposure is per exposure, not per viewer. Therefore, he contended that there was insufficient evidence to convict him on two separate counts of indecent exposure. He also argued that the district court did not provide sufficient reasons for imposing a consecutive sentence under Iowa Rule of Criminal Procedure 2.23(3)(d).The Supreme Court of Iowa affirmed the lower court's decision. The court held that the unit of prosecution for indecent exposure is one count per viewer, not one count per exposure. Therefore, there was sufficient evidence to support a conviction on two counts of indecent exposure. The court also found that the district court provided sufficient reasoning for imposing a consecutive sentence. The court noted that the district court's reasoning for imposing consecutive sentences may be the same reasons the court relied on for the imposition of incarceration. The court concluded that the district court's statement that the only appropriate sentence was to send Wilson to prison for as long of a period of time as possible implied that the sentences should run consecutively. View "State v. Wilson" on Justia Law

Jesse McCollaugh was found guilty of child exploitation after his wife discovered videos on his phone of her 15-year-old sister using the bathroom, which McCollaugh had secretly recorded. The videos showed the minor partially nude, unaware she was being filmed. McCollaugh admitted to recording the videos and having a sexual problem. He was charged with one count of sexual exploitation of a minor, to which he pleaded not guilty. After a bench trial, the district court found McCollaugh guilty and sentenced him to a prison term not exceeding two years, and required him to register as a sex offender.Before the Supreme Court of Iowa, McCollaugh appealed his conviction, arguing that the evidence was insufficient to support his conviction because it failed to establish that the minor had the purpose of engaging in nudity to arouse or satisfy the sexual desires of a person who may view the visual depiction. The Supreme Court disagreed with McCollaugh's interpretation of the statute, stating that the relevant "purpose" that the State must prove is identified after the word "purpose" in the definition, not before. The court held that the State must prove the purpose of purchasing or possessing a visual depiction of the nude minor—not the minor’s purpose in being nude. The court found sufficient evidence to prove McCollaugh’s purpose for taking the videos was for his sexual gratification and affirmed his conviction. McCollaugh also argued that the district court relied on an improper factor in its sentencing order, but the Supreme Court found no evidence that the district court relied on the improper factor and affirmed the sentence. View "State v. McCollaugh" on Justia Law

The case involves Clayton Curtis Brown, who was convicted of possession of a firearm as a felon, aggravated eluding, and driving while barred. The charges stemmed from an incident where Brown eluded a police officer's attempt to initiate a traffic stop. The officer later found the car abandoned and discovered a loaded handgun under the driver's seat and ammunition in the center console and under the front passenger seat. Brown's personal items were also found in the car.The Iowa Court of Appeals reversed Brown's convictions for possession of a firearm as a felon and aggravated eluding, concluding there was insufficient evidence to show that Brown knowingly possessed the handgun. Brown also contested the sufficiency of the evidence to support his convictions, arguing that the State failed to prove his identity as the driver of the car that eluded the officer.The Supreme Court of Iowa disagreed with the lower court's decision. The court held that the State's evidence, including the officer's testimony, the location of the firearm, and the presence of Brown's personal effects in the car, was sufficient to support the jury's conclusion that Brown had constructive possession of the firearm. The court also found that there was sufficient evidence to support the jury's determination that Brown was driving the car when it eluded the officer. Therefore, the Supreme Court of Iowa vacated the portion of the court of appeals decision reversing those convictions and affirmed the district court judgment in full. View "State of Iowa v. Brown" on Justia Law

The Supreme Court of Iowa ruled in a case involving an individual, Faron Alan Starr, who was arrested and denied his request to call a family member to get an attorney. Starr was suspected of an assault and stealing two firearms. After his arrest, he was taken to a police station where he initially equivocated about speaking to the police without an attorney. However, he later requested to call his father to obtain a lawyer, which was refused by the police officer. The officer proceeded to question Starr about his actions and whereabouts of the stolen firearms.Starr was charged with multiple offenses, and he subsequently filed a motion to suppress his statements and any evidence derived from them, asserting violations of his constitutional and statutory rights. The district court granted the motion, finding a violation of Starr's rights under Iowa Code section 804.20, which mandates that an arrested person be allowed to call and consult a family member or an attorney without unnecessary delay upon arrival at the place of detention.The Supreme Court of Iowa affirmed the lower court's decision, holding that while public safety concerns could potentially justify a delay in honoring an arrested person's rights under Iowa Code section 804.20, the circumstances of this case did not warrant such a delay. The court noted that the police did not address the issue of the missing firearms until nearly two hours after Starr was taken into custody for questioning at the police station. Therefore, the delay in permitting Starr to call a family member was deemed unnecessary. View "State of Iowa v. Starr" on Justia Law

The Supreme Court of Iowa upheld the decision of the Iowa Court of Appeals and the district court that sentenced a recidivist drug offender, Jacob Lee Goble, to an indeterminate prison sentence of up to five years. Goble, who had pleaded guilty to a class "D" felony, appealed on the grounds that the sentencing court improperly considered parole as a factor in determining his sentence. The court mentioned parole once in the context of Goble's need for a structured setting for his rehabilitation and protection of the community.The Supreme Court of Iowa, however, found that the mention of parole in this context was not inappropriate. The court stated that the district court did nothing to circumvent the parole board’s discretion in determining the release date, and its reference to parole is authorized by statute. Goble’s sentence was therefore affirmed, and his claim that the sentencing court relied on an improper factor by mentioning parole was rejected.The court also differentiated this case from precedent where it was held impermissible for the district court to impose a longer prison sentence for the purpose of delaying the defendant’s release on parole. In this case, the district court’s choice was limited to imposing a five-year indeterminate sentence with immediate parole eligibility or suspending that sentence and placing Goble on probation. The court concluded that the district court did not impose a longer sentence to circumvent the parole board’s discretion. View "State of Iowa v. Goble" on Justia Law