Justia Criminal Law Opinion Summaries

A law enforcement officer in this case had probable cause to stop a motorist’s vehicle when it was on a county access road after hours.The district court denied the motorist’s motion to suppress the evidence and convicted the motorist of possession of a controlled substance. The Supreme Court reversed the judgment of the district court, holding that the officer did not have probable cause or reasonable suspicion to stop the motorist’s vehicle. Thereafter, the Court granted the State’s petition for rehearing and withdrew its original petition. Upon further consideration, the Court held that the officer had probable cause to stop the motorist’s vehicle because, at the time the officer stopped the motorist, the closing time in the area where the officer found the motorist’s vehicle was 10:30 p.m., and the officer stopped the motorist after 10:30 p.m. Therefore, at the time of the stop, the officer had probable cause to stop the motorist’s vehicle under the Iowa Constitution. View "State v. Scheffert" on Justia Law

Under Iowa Code 321.561, the State must prove as the essential elements of the offense of driving while barred as a habitual offender that the defendant operated a motor vehicle during the time period his or her license was revoked as a habitual offender. Proof that the Iowa Department of Transportation (IDOT) mailed a notice of revocation to the defendant may be relevant to whether the defendant’s license was in fact revoked, but it is not an actual element of the offense.The Supreme Court affirmed Defendant’s convictions of both operating while intoxicated third offense as a habitual offender and driving while barred. Contrary to Defendant’s contention on appeal, Defendant’s conviction for driving while barred need not be set aside where the State did not prove it mailed notice of revocation to Defendant because proof of mailing is not an essential element of the State’s proof. View "State v. Williams" on Justia Law

Under Iowa Code 321.561, the State must prove as the essential elements of the offense of driving while barred as a habitual offender that the defendant operated a motor vehicle during the time period his or her license was revoked as a habitual offender. Proof that the Iowa Department of Transportation (IDOT) mailed a notice of revocation to the defendant may be relevant to whether the defendant’s license was in fact revoked, but it is not an actual element of the offense.The Supreme Court affirmed Defendant’s convictions of both operating while intoxicated third offense as a habitual offender and driving while barred. Contrary to Defendant’s contention on appeal, Defendant’s conviction for driving while barred need not be set aside where the State did not prove it mailed notice of revocation to Defendant because proof of mailing is not an essential element of the State’s proof. View "State v. Williams" on Justia Law

At issue was whether the evidence was sufficient to support Defendant’s conviction on one count of sexual exploitation by a school employee under Iowa Code 709.15(3)(a)(1) and 709.15(5)(a) where Defendant hugged a student several times.The Supreme Court affirmed Defendant’s conviction, holding (1) Iowa Code 709.15(3)(a)(1) does not require the State to show that a school employee engaged in a pattern, practice, or scheme to engage in sexual conduct with multiple students or over a certain period of time; and (2) the State presented substantial evidence - including dozens of hugs, thousands of communications, and photographs - that Defendant engaged in a pattern, practice, and scheme to engage in sexual conduct with the student at issue. View "State v. Wickes" on Justia Law

The Supreme Court overruled its cases holding that defendants may attack the voluntary and intelligent character of their pleas, holding that the Iowa Constitution allows freestanding claims of actual innocence, and therefore, applicants may bring such claims to attack their pleas even though they entered their pleas knowingly and voluntarily.Appellant filed an application for postconviction relief under Iowa Code 822.2(1)(d), claiming that he was innocent and that he pled guilty because he was “scared.” The district court granted summary judgment for the State, concluding that Appellant waived his claim of actual innocence by pleading guilty. The Supreme Court reversed, holding (1) the Court hereby adopts a freestanding claim of actual innocence that applicants may bring under the postconviction relief statute; and (2) thus, Appellant’s pleas did not preclude him from filing a postconviction-relief action. View "Schmidt v. State" on Justia Law

The Supreme Court overruled its cases holding that defendants may attack the voluntary and intelligent character of their pleas, holding that the Iowa Constitution allows freestanding claims of actual innocence, and therefore, applicants may bring such claims to attack their pleas even though they entered their pleas knowingly and voluntarily.Appellant filed an application for postconviction relief under Iowa Code 822.2(1)(d), claiming that he was innocent and that he pled guilty because he was “scared.” The district court granted summary judgment for the State, concluding that Appellant waived his claim of actual innocence by pleading guilty. The Supreme Court reversed, holding (1) the Court hereby adopts a freestanding claim of actual innocence that applicants may bring under the postconviction relief statute; and (2) thus, Appellant’s pleas did not preclude him from filing a postconviction-relief action. View "Schmidt v. State" on Justia Law

The relief-required rule, which ordinarily requires proof that a criminal client had been exonerated from the underlying conviction, does not apply to a convicted criminal suing one of his defense attorneys for legal malpractice over an alleged missed opportunity to shorten his period of supervised probation.In this case, Plaintiff’s defense attorney successfully vacated two of Plaintiff’s convictions. Meanwhile, Plaintiff was incarcerated for a probation violation. The district court later determined, sua sponte, that Plaintiff’s term of supervised probation should have ended earlier, which would have avoided almost one year in prison. The district court granted summary judgment to the defendant attorney based on the relief-required rule. The court of appeals reversed, ruling that Plaintiff could sue over the sentencing error without proving his exoneration from the conviction as long as he obtained relief from the sentencing error. The Supreme Court affirmed, holding that Plaintiff here must prove relief from the sentencing error allegedly caused by the malpractice, not the underlying conviction. View "Kraklio v. Simmons" on Justia Law

The Supreme Court reversed Defendant’s conviction for robbery in the first degree and remanded for entry of judgment and sentencing for robbery in the second degree, holding that Defendant’s conviction for robbery in the first degree as an aider and abettor was not supported by sufficient evidence.Defendant agreed to be the getaway driver for his two codefendants, who were going to rob a pharmacy. The codefendants robbed the pharmacy, but Defendant did not give them a ride because they were apprehended by the police before the planned rendezvous took place. All three individuals were convicted of first-degree robbery because a gun had been used in the robbery. On appeal, Defendant argued that the evidence was insufficient to support his conviction because he did not know a gun would be used in the robbery. The court of appeals affirmed. The Supreme Court reversed, holding (1) proof that Defendant had knowledge or intent of the use of the gun was required to support his conviction under an aiding and abetting theory; and (2) there was insufficient evidence to convict Defendant of first-degree robbery as an aider and abettor due to a failure of proof on the dangerous weapon element. View "State v. Henderson" on Justia Law

Iowa Code 902.1(2)(a)(1), which gives the district court the option to sentence a juvenile offender convicted of murder in the first degree to life imprisonment without the possibility of parole, is unconstitutional based on the Supreme Court’s holding in State v. Sweet, 879 N.W.2d 811 (Iowa 2016), which held that such a sentence for all juvenile offenders violates article I, section 17 of the Iowa Constitution. However, the unconstitutional portion of the statute does not render the remainder of section 902.1(2)(a) unconstitutional.Defendant was convicted of first-degree murder as a juvenile offender. Defendant challenged his sentence of life imprisonment with the possibility of parole after serving a minimum term of twenty-five years confinement. Defendant filed a motion to correct an illegal sentence, arguing that the sentencing scheme for juvenile offenders convicted of first-degree murder set forth in section 902.1(2) was cruel and unusual punishment under the Iowa Constitution. The Supreme Court held (1) section 902.1(2)(a)(1) is unconstitutional, but the remainder of section 902.1(2) is constitutional; and (2) Defendant’s case must be remanded for resentencing under State v. Roby, 897 N.W.2d 127 (Iowa 2017), which was decided subsequent to Defendant’s resentencing. View "State v. Zarate" on Justia Law

The Supreme Court reversed the district court’s dismissal of Appellant’s motion to reinstate its application for postconviction relief (PCR), which the district court dismissed for want of prosecution under Iowa R. Civ. P. 1.944, holding that Lado v. State, 804 N.W.2d 428 (Iowa 2011) controlled this matter.In Lado, the Supreme Court held that PCR counsel was ineffective in failing to avoid dismissal of a PCR application under Rule 1.944 and that the error was structural. On appeal in the instant case, the court of appeals declined to consider Appellant’s Lado argument because it was raised for the first time in his reply brief. The Supreme Court vacated the decision of the court of appeals, reversed the orders of the district court, and remanded for further proceedings, holding that Appellant’s ineffective assistance argument should be considered for several reasons even though it was not raised until the reply brief. View "Villa v. State" on Justia Law