Justia Criminal Law Opinion Summaries

Defendant did not have a right to counsel under Iowa Const. art. I, section 10 when he voluntarily participated in a noncustodial police interview under the supervision of an Iowa county attorney even though the State’s criminal investigation was focusing on Defendant as the primary suspect at the time.Defendant was found guilty of murder in the first degree. During trial, the district court instructed the jury that it could infer Defendant acted with malice aforethought from his use of a baseball bat. The jury found Defendant killed the victim without justification and with malice aforethought. The court of appeals affirmed the judgment and sentence. The Supreme Court affirmed, holding (1) the level of prosecutorial involvement at the time of the interview did not create a prosecution or case that would trigger the right to counsel under article I, section 10; and (2) the jury could properly infer malice aforethought from Defendant’s use of a deadly weapon even though Defendant did not bring the weapon to the encounter. View "State v. Green" on Justia Law

The Supreme Court held that Defendant must be allowed to withdraw his plea of guilty to a criminal offense because Defendant would not have accepted the plea agreement if he had been provided the effective assistance of counsel to which he was constitutionally entitled.Defendant, who entered the United States without examination by the Department of Homeland Security, pleaded guilty to aggravated misdemeanor forgery. Based on this conviction, he was removed from the United States to Mexico. After Defendant returned to the United States he filed for postconviction relief, asserting that he was denied the effective assistance of counsel because counsel did not advise him pleading guilty to an aggravated felony has severe immigration consequences. The district court agreed and vacated Defendant’s conviction. The court of appeals reversed. The Supreme Court vacated the court of appeals, affirmed the district court, and remanded to allow Defendant to withdraw his plea and stand for trial, holding that counsel provided constitutionally deficient performance, and this deficiency resulted in prejudice. View "Diaz v. State" on Justia Law

Iowa’s forgery statute is preempted on its face by federal immigration law. Further, Iowa’s identity theft statute is field preempted as applied in this case, and enforcement of the identity theft statute is conflict preempted in this case.Appellant was an undocumented citizen who was brought to Iowa by her parents when she was eleven years old. Appellant was educated in Iowa public schools, lived in Iowa continuously, and was a mother of four children who were United States citizens. Appellant applied for and received temporary lawful immigration status from the Department of Homeland Security pursuant to the Department’s Deferred Action for Childhood Arrivals program. Appellant was later prosecuted by the State for using false documents to obtain federal employment authorization. Appellant filed a motion to dismiss, arguing that federal law preempted her prosecution under the Iowa identity theft and forgery statutes. The district court denied the motion, concluding that the charges of identity theft and forgery were state crimes independent of Appellant’s immigration status. The Supreme Court reversed. View "State v. Martinez" on Justia Law

The Supreme Court reversed Defendant’s conviction for domestic abuse assault, third offense, and remanded this case for a new trial, holding that Defendant received ineffective assistance of counsel because his trial counsel failed to request a jury instruction defining “household member.” The court thus vacated the decision of the court of appeals, which affirmed the conviction over a dissent. The majority concluded that defense counsel had breached an essential duty by failing to request the definition instruction but that Defendant failed to show prejudice because the State had presented sufficient evidence of cohabitation. The Supreme Court held (1) because the central issue at trial was whether Defendant and the victim had been cohabitating, the jury should have been given the definition instruction, which accurately set forth the factors bearing on that issue; and (2) therefore, defense counsel’s failure to request the instruction was prejudicial, necessitating a new trial. View "State v. Virgil" on Justia Law

Defendant, a juvenile, pleaded guilty to four counts of willful injury causing serious injury. Pursuant to the plea agreement, the district court sentenced Defendant to indeterminate sentences not to exceed ten years on each of the four counts to run consecutively for a maximum sentence of forty years. No mandatory minimum sentence was imposed, but because Defendant’s crime was a forcible felony, the sentencing judge was unable to consider a deferred judgment or probation as a sentencing option. Defendant filed a motion to correct an illegal sentence, which the district court denied. The Supreme Court affirmed the judgment of the district court, holding (1) the forcible felony sentencing statute, Iowa Code 907.3, is not unconstitutional as applied to juvenile offenders; and (2) in considering a motion to correct an illegal sentence, the district court is not required to conduct an individualized sentencing hearing as to all juveniles regardless of whether the sentence has a mandatory term of years. View "State v. Propps" on Justia Law

This case that arose out of the same facts and presented the same issues addressed in a companion case also decided today, State v. Williams, __ N.W.2d __ (Iowa 2017). At issue was whether Defendants’ rights were violated by the failure to bring formal charges against them within forty-five days of their arrest. The district court denied Defendant’s motions to dismiss for violation of their speedy trial rights. Relying on case precedent interpreting the speedy trial to find that the time to file an indictment commenced when Defendant reasonably believed he had been arrested, the court of appeals reversed. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court based on the reasoning in Williams, holding that the speedy indictment rule is properly interpreted to commence upon arrest only when the arrest is completed by making an initial appearance. View "State v. Smith" on Justia Law

The speedy indictment rule is properly interpreted to commence upon arrest only when the arrest is completed by making an initial appearance.At issue in this case was whether Defendants’ rights were violated by the failure to bring formal charges against them within forty-five days of their arrest. The district court denied Defendants’ motions to dismiss for violation of their speedy indictment rights. The court of appeals reversed, relying on case precedent interpreting the speedy indictment rule to find that the time to file an indictment commenced when Defendant in this case reasonably believed he had been arrested. The Supreme Court reversed, holding that the speedy indictment rule is triggered from the time a person is taken into custody, but only when the arrest is completed by taking the person before a magistrate for an initial appearance. View "State v. Williams" on Justia Law

The speedy indictment rule commences upon arrest only when the arrest is completed by making an initial appearance. Therefore, the speedy indictment rule does not require the dismissal of a trial information against a defendant filed more than forty-five days after the defendant was taken into custody, interrogated, and released without the filing of a criminal complaint. This case arose out of the same facts and presented the same issues address in a companion case also decided today, State v. Williams, __ N.W.2d __ (Iowa 2017). The district court concluded that Defendant’s speedy indictment rights had not been violated. The court of appeals reversed. Based on the reasoning in Williams, the Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court. View "State v. Washington" on Justia Law

Appellant pled guilty to one count of third-degree sexual abuse as the result of a sex act that occurred involving Appellant, who was seventeen years old, and T.C., who was thirteen years old. On appeal, Appellant argued that his lifetime special sentence of parole and the lifetime requirement that he register as a sex offender violated the cruel and unusual punishment and due process clauses of the United States and Iowa Constitutions. The court of appeals affirmed. The Supreme Court affirmed, holding that Appellant’s lifetime special sentence and lifetime registration requirement were not cruel and unusual punishment because a juvenile offender can petition the Iowa Department of Corrections for discharge from both the special sentence and the registration requirement. View "State v. Graham" on Justia Law

Iowa’s search warrants do not authorize anticipatory warrants, but where the federal government conducts a search pursuant to a valid federal search warrant for purposes of a federal investigation, the fact that such a warrant would not have been statutorily authorized in Iowa does not require the results of the search to be suppressed in Iowa courts.As a package containing methamphetamine entered this country from Mexico, federal agents intercepted the package and then made a controlled delivery of the package to its intended recipient in Iowa. The agents obtained from a federal magistrate judge a federal anticipatory search warrant authorizing a search to be conducted once the package reached its intended recipient. After a controlled delivery, the recipient of the package was detained, and federal agents searched his residents. The federal government turned the case over to Iowa for prosecution, and the recipient of the package (Defendant) was convicted of possession of methamphetamine with intent to deliver and drug stamp violations. The Supreme Court affirmed the convictions, holding that the trial court’s admission of the results of the search accorded a proper recognition to the bona fide actions of the federal government pursuant to that government’s lawful authority. View "State v. Ramirez" on Justia Law