Justia Criminal Law Opinion Summaries

The Supreme Court vacated Defendant’s second-degree robbery conviction and remanded for entry of a judgment of conviction for third-degree robbery and resentencing. On appeal, Defendant argued that the district court erred in giving jury instructions on second- and third-degree robbery that failed to differentiate between those offenses. On review, the court held (1) the instruction on second-degree robbery as given did not accurately state the law; (2) the evidence was sufficient to support a finding of simple assault and conviction for third-degree robbery but insufficient to support the conviction for second-degree robbery; and (3) Defendant’s vagueness challenge to the robbery statutes failed. View "State v. Ortiz" on Justia Law

The Supreme Court vacated Defendant’s second-degree robbery conviction and remanded for entry of a judgment of conviction for third-degree robbery and resentencing. On appeal, Defendant argued that the district court erred in giving jury instructions on second- and third-degree robbery that failed to differentiate between those offenses. On review, the court held (1) the instruction on second-degree robbery as given did not accurately state the law; (2) the evidence was sufficient to support a finding of simple assault and conviction for third-degree robbery but insufficient to support the conviction for second-degree robbery; and (3) Defendant’s vagueness challenge to the robbery statutes failed. View "State v. Ortiz" on Justia Law

The juvenile court did not err in terminating Mother’s parental rights after Mother’s three-month-old daughter was sexually abused by Father, with whom Mother had left the child knowing he was intoxicated.The juvenile court found that the State had proven the grounds for termination of Mother’s parental rights and that termination was in the child’s best interests. The court of appeals reversed. The Supreme Court vacated the decision of the court of appeals and affirmed the juvenile court’s judgment, holding that, where Mother remained incapable of raising the child safely with no indication that her parenting abilities would sufficiently improve in the foreseeable future despite the extensive services provided by social workers with the Iowa Department of Human Services, the juvenile court properly terminated Mother’s parental rights. View "In re A.S." on Justia Law

The juvenile court did not err in terminating Mother’s parental rights after Mother’s three-month-old daughter was sexually abused by Father, with whom Mother had left the child knowing he was intoxicated.The juvenile court found that the State had proven the grounds for termination of Mother’s parental rights and that termination was in the child’s best interests. The court of appeals reversed. The Supreme Court vacated the decision of the court of appeals and affirmed the juvenile court’s judgment, holding that, where Mother remained incapable of raising the child safely with no indication that her parenting abilities would sufficiently improve in the foreseeable future despite the extensive services provided by social workers with the Iowa Department of Human Services, the juvenile court properly terminated Mother’s parental rights. View "In re A.S." on Justia Law

Law enforcement officers executing a search warrant violated Defendant’s rights under Iowa Const. art. I, 8 by searching her purse while she was a visitor present at the premises to be searched but where the search warrant made no motion of her.Prior to trial, Defendant filed a motion to suppress, which the district court denied. Defendant was subsequently found guilty of possessing marijuana. The Supreme Court reversed the district court’s ruling on the motion to suppress and remanded the case to the district court, holding (1) a search of the possessions of a third party at a residence is unconstitutional when the warrant does not support probable cause to search that particular person; and (2) under this court’s applicable caselaw, the search of Defendant’s purse could not be supported based on any of the State’s theories independent of the search warrant. View "State v. Brown" on Justia Law

Defendant was entitled to withdraw his guilty plea to assault causing bodily injury because the district court did not substantially comply with Iowa R. Crim. P. 2.8(2)(b)(2) during the guilty plea colloquy. Specifically, the district court did not substantially comply with Rule 2.8(2)9b)(2) because the written guilty plea form failed to inform Defendant about the mandatory thirty-five precent criminal penalty surcharge applicable to the offense. The Supreme Court thus affirmed the decision of the court of appeals, which, based the district court’s noncompliance with the rule, applied a bright-line rule of automatic reversal. View "State v. Diallo" on Justia Law

Defendant Jason Weitzel appealed the judgment and sentences entered on his guilty pleas to domestic abuse assault, possession of methamphetamine, carrying weapons, and operating while intoxicated. Defendant challenged the adequacy of his guilty plea colloquy, arguing the district court did not advise him about the statutory thirty-five percent criminal penalty surcharges, and this failure invalidated his guilty pleas. The court of appeals held the district court did not substantially comply with Iowa Rule of Criminal Procedure 2.8(2)(b)(2) during the guilty plea colloquy because it omitted information regarding the surcharges, and reversed. The State sought certiorari review, and the Iowa Supreme Court concurred with the appellate court that the district court did not substantially comply with rule 2.8(2)(b)(2) because it failed to inform the defendant about the mandatory thirty-five percent criminal penalty surcharges. Because of the district court’s noncompliance, defendant was entitled to withdraw his pleas. The case was remanded back to the district court for further proceedings. View "Iowa v. Weitzel" on Justia Law

The Supreme Court reversed the order of the district court finding that it did not have subject matter jurisdiction to hear Appellant’s challenge under Iowa Code 822.2.Appellant, a prisoner, filed a postconviction-relief action asserting that the policy of the Iowa Department of Corrections unlawfully extended his time in prison by delaying the start date of the sex offender treatment program based on a sex offender’s tentative discharge date. The district court granted the State’s motion for summary judgment on the ground that it lacked subject matter jurisdiction and dismissed the case. The Supreme Court reversed and remanded the case for further proceedings, holding (1) this was not a case concerning subject matter jurisdiction but did, rather, involve authority to hear the case; and (2) the district court did have authority to hear this case. View "Franklin v. State" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing Appellant’s amended application for postconviction relief.In his application for postconviction relief, Appellant alleged that, pursuant to Iowa Code 822.2(1)(a), his sentence violated several of his civil rights under the United States and Iowa Constitutions. Specifically, Appellant asserted that the Iowa Department of Corrections (IDOC) violated his liberty interest in obtaining parole by failing to provide the sex offender treatment program (SOTP) in a timely manner. The district court found, as a matter of law, that Appellant had not stated a claim for postconviction relief under section 822.2(1)(a). The Supreme Court remanded the case, holding that Appellant should be given an opportunity to amend his application to seek relief under Iowa Code 822.2(1)(e). View "Belk v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of second-degree murder. On appeal, Defendant claimed, among other things, that he was forced to use a peremptory strike to disqualify a potential juror who should have been disqualified for cause, and therefore, reversal was required even though the potential juror was not seated and there was no specific showing of prejudice. The court of appeals affirmed the conviction. The Supreme Court affirmed, holding (1) the actual prejudice test of State v. Neuendorf, 509 N.W.2d 743 (Iowa 1993), rather than the automatic prejudice test of State v. Mootz, 808 N.W.2 207 (Iowa 2012), controlled in this case; and (2) consequently, Defendant could not succeed in this appeal. View "State v. Jonas" on Justia Law