Justia Criminal Law Opinion Summaries

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

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

The district court order disqualifying an attorney from representing a criminal defendant, based primarily on speculative evidence of a potential conflict, constituted “an untenable ground for the district court to exercise its discretion.”The Supreme Court reversed the order of the district court granting the State’s motion to disqualify attorney Steven Gardner from defending Carlos Ramon Mulatillo on felony drug charges. Less than two weeks before the jury trial was to commence, Mulatillo and Gardner were informed of the name of a confidential informant and the potential conflict of interest between Gardner and this individual. Gardner had previously represented the confidential informant for approximately one month on felony drug charges. After a Watson hearing, the district court concluded that there was a serious potential for a conflict of interest that precluded Gardner from representing Mulatillo. The Supreme Court reversed, holding that the evidence provided by the State did not rise to the level of substantial evidence that was necessary to prove that Gardner’s continued representation of Mulatillo created a serious potential for an actual conflict of interest. View "State v. Mulatillo" on Justia Law

The district court order disqualifying an attorney from representing a criminal defendant, based primarily on speculative evidence of a potential conflict, constituted “an untenable ground for the district court to exercise its discretion.”The Supreme Court reversed the order of the district court granting the State’s motion to disqualify attorney Steven Gardner from defending Carlos Ramon Mulatillo on felony drug charges. Less than two weeks before the jury trial was to commence, Mulatillo and Gardner were informed of the name of a confidential informant and the potential conflict of interest between Gardner and this individual. Gardner had previously represented the confidential informant for approximately one month on felony drug charges. After a Watson hearing, the district court concluded that there was a serious potential for a conflict of interest that precluded Gardner from representing Mulatillo. The Supreme Court reversed, holding that the evidence provided by the State did not rise to the level of substantial evidence that was necessary to prove that Gardner’s continued representation of Mulatillo created a serious potential for an actual conflict of interest. View "State v. Mulatillo" on Justia Law

After Defendant’s initial sentence was voided for illegality, the district court resentenced Defendant to a new term of imprisonment. The district court originally suspended Defendant’s prison sentence and instead ordered a five-year term of probation. Upon resentencing, the court refused to credit the time Defendant spent on probation pursuant to the initial sentence against the new term of imprisonment. The Supreme Court held that the failure to award credit for the time spent on probation violated Defendant’s constitutional right to be free from double jeopardy under the Fifth Amendment. The court held that all time Defendant spent on probation pursuant to the voided sentence must be fully credited against a corrected sentence of incarceration because, when an initial sentence is voided for illegality, any punishments already endured must be credited against the corrected sentence. The dissent disagreed, arguing that probation should not be equated with punishment in the same way incarceration is considered for double jeopardy purposes. View "State v. Jepsen" on Justia Law

After Defendant’s initial sentence was voided for illegality, the district court resentenced Defendant to a new term of imprisonment. The district court originally suspended Defendant’s prison sentence and instead ordered a five-year term of probation. Upon resentencing, the court refused to credit the time Defendant spent on probation pursuant to the initial sentence against the new term of imprisonment. The Supreme Court held that the failure to award credit for the time spent on probation violated Defendant’s constitutional right to be free from double jeopardy under the Fifth Amendment. The court held that all time Defendant spent on probation pursuant to the voided sentence must be fully credited against a corrected sentence of incarceration because, when an initial sentence is voided for illegality, any punishments already endured must be credited against the corrected sentence. The dissent disagreed, arguing that probation should not be equated with punishment in the same way incarceration is considered for double jeopardy purposes. View "State v. Jepsen" on Justia Law

At issue was whether a conceded error in the admission of evidence in this criminal case was harmless.Defendant was charged with operating while intoxicated (OWI), third offense. During trial, the district court admitted, over Defendant’s objection, the results of Defendant’s breath test. The jury found Defendant guilty. Defendant appealed, arguing that the trial court erroneously admitted the test result in light of Iowa Code 321J.5(2). On appeal, the State conceded that the test results should not have been admitted but that Defendant failed to preserve error below or, alternatively, any error was harmless. The Supreme Court reversed and remanded the case for a new trial, holding that Defendant did preserve error and that the error was not harmless. View "State v. Ness" on Justia Law

At issue was whether the magistrate court had subject matter jurisdiction to extend a no-contact order in a simple misdemeanor case under Iowa Code chapter 664A and whether a right to appeal exists from the extension of a no-contact order in a simple misdemeanor case.Defendant appealed from a district court order affirming a magistrate’s extension of a no-contact order for five years. The Supreme Court reversed the district court order extending the no-contact order and remanded the case for entry of an order terminating the no-contact order. The court held (1) the magistrate had subject matter jurisdiction to extend the no-contact order under chapter 664A; but (2) the district court’s findings of fact and decision were not supported by substantial evidence in the record. View "State v. Vance" on Justia Law