Justia Criminal Law Opinion Summaries

In 2004, Gary Pettit pled guilty to third-degree sexual abuse and third-degree kidnapping, Pettit was incarcerated at the Anamosa State Penitentiary. In 2015, the Iowa Department of Corrections (IDOC) informed Pettit that he would be required to complete sex offender treatment. After a sex offender treatment program (SOTP) classification hearing, an administrative law judge (ALJ) affirmed the classification decision, concluding that Pettit was required to complete the SOTP. Pettit filed a petition for judicial review, claiming that the IDOC violated his due process rights by refusing to allow him access to counsel during the classification hearing. The district court determined that Pettit was entitled to counsel at the hearing. The Supreme Court vacated the judgment of the district court and remanded, holding that the district court did not have authority to review the classification hearing under Iowa Code chapter 17A. Remanded for dismissal of Pettit’s petition for judicial review. View "Pettit v. Iowa Department of Corrections" on Justia Law

Defendant was charged with driving while barred. Defendant filed a motion to suppress, which the district court denied. Defendant was subsequently convicted. Defendant appealed the denial of his motion to suppress, arguing that a law enforcement officer, after making a valid traffic stop supported by reasonable suspicion that an offense may being committed, must terminate the stop when the underlying reason for the stop is no longer present. The Supreme Court agreed with Defendant and reversed, holding (1) when the reason for a traffic stop is resolved and there is no other basis for reasonable suspicion, Iowa Const. art. I, 8 requires that the stop must end; and (2) consequently, the law enforcement officer that stopped Defendant in this case violated Defendant’s rights under the Iowa Constitution. View "State v. Coleman" on Justia Law

Appellant pleaded guilty to failure to appear for sentencing. Appellant filed a postconviction relief action asserting that his counsel provided ineffective assistance for several reasons. The district court denied relief. Appellant appealed, arguing that counsel was ineffective by allowing Appellant to plead guilty when a factual basis did not exist for the plea. The court of appeals concluded that it could not reach this issue on appeal because the record was insufficient to determine whether a factual basis existed at the time Appellant pleaded guilty. The Supreme Court vacated the decision of the court of appeals and affirmed the district court judgment, holding (1) a factual basis existed in the record for the court to accept Appellant’s plea; and (2) Appellant’s remaining claims were without merit. View "Yocum v. State" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to theft in the first degree. The district court sentenced Defendant to a term of imprisonment and imposed fines and restitution. The sentencing order also included a provision for the forfeiture of Defendant’s pretrial bond in payment of the various financial obligations imposed as part of his sentence. Defendant moved for reconsideration and requested that he be sentenced to probation. The district court denied the motion. Defendant appealed, arguing, inter alia, that the district court lacked authority to order forfeiture of the bail. The court of appeals affirmed. The Supreme Court vacated the decision of the court of appeals with regard to the issue pertaining to the appearance bond, holding that the district court lacked the authority to forfeit bail as a term of sentencing. View "State v. Letscher" on Justia Law

An inmate pled guilty to domestic abuse assault in a plea bargain that dismissed a related sex abuse charge. After the inmate arrived at a facility of the Iowa Department of Corrections (IDOC), the IDOC required the inmate to participate in a Sex Offender Treatment Program (SOTP). For the initial classification mandating SOTP, the IDOC relied on the dismissed sex abuse charge and the victim’s detailed written statement included in a police report. An administrative law judge (ALJ) upheld the determination following an evidentiary hearing based on the inmate’s admission that he assaulted his girlfriend and the victim’s statement. The district court reversed, concluding that the IDOC cannot use unproven charges to require SOTP. The Supreme Court reversed and reinstated the IDOC’s decision, holding (1) the IDOC may rely on the victim’s written statement in a police report for the initial classification requiring SOTP provided that the inmate is afforded due process; (2) the ALJ may uphold the classification based on the inmate’s testimony admitting to a sexual component to the assault along with other evidence; and (3) the inmate in this case was provided with appropriate procedural protections, and there was no other error in these proceedings. View "State v. Iowa District Court for Jones County" on Justia Law

Defendant was on probation after having been convicted of drug offenses related to methamphetamine when his sister and father, concerned that he had relapsed, contacted his probation officer. Probation officers were dispatched to Defendant's residence and, with the father’s consent and without objection from Defendant, entered Defendant’s bedroom. Defendant admitted he had relapsed and used methamphetamine. The State commenced a probation revocation proceeding. Defendant filed a motion to suppress, claiming that the probation officers’ warrantless entry into his bedroom violated article I, section 8 of the Iowa Constitution. The district court denied the motion. The Supreme Court affirmed, holding that assuming, without deciding, that Defendant had a legitimate expectation of privacy in his bedroom, the probation officers’ entry was justified by the special-needs doctrine, and therefore, the entry into Defendant’s room did not violate his rights under article I, section 8 of the Iowa Constitution. View "State v. Brooks" on Justia Law

Defendant pleaded guilty to theft in the third degree. The district court sentenced Defendant to a suspended term of imprisonment and ordered that he pay $2950 in restitution to the victim. At a hearing, the victim stated that she had an insurance policy that had a deductible in the amount of $1000 but that she had not filed a claim with her insurance company for the stolen items. Following the hearing, the district court ordered Defendant to pay $2001 in restitution. Defendant appealed, arguing that the restitution award should be limited to reflect only losses not covered by insurance. The Supreme Court affirmed, holding that the victim was entitled to seek full restitution from Defendant for damages not paid by her insurer and that the victim was under no obligation to act for Defendant’s benefit by seeking coverage for her losses. View "State v. Dubois" on Justia Law

Appellee pled guilty to a crime listed in Iowa Code 902.12, which requires offenders to serve a mandatory minimum term of their sentence before being eligible for parole or work release. Appellee, who was a juvenile when he committed the offense, was sentenced to an indeterminate term of incarceration. The Iowa Department of Corrections (IDOC) classified Appellee’s sentence as category “B” and calculated his earned time accordingly. Appellee later filed a motion for correction of an illegal sentence based on State v. Lyle. The district court resentenced Appellee to an indeterminate term not to exceed ten years, without the mandatory minimum. The IDOC continued to calculate Appellee’s earned time at the rate provided for in category “B” rather than the faster rate provided for in category “A.” Appellee filed a motion to enlarge the sentencing order, arguing that the IDOC was not giving him full credit for his time served. The district court ruled that Appellee’s entire sentence was subject to the accelerated category “A” accumulation rate. The Supreme Court affirmed, holding that Breeden v. Iowa Department of Corrections, decided today, was dispositive and required that Appellant’s earned-time credit be recalculated at the category “A” rate for all his time served. View "State v. Coleman" on Justia Law

Appellant was convicted of attempted murder and terrorism with intent. Appellant was a juvenile when he committed the offenses. Appellant was sentenced to an indeterminate term of incarceration. A mandatory minimum sentence of five years for each offense was also imposed. Appellant received a sentence with a mandatory minimum, and the IDOC calculated Appellant’s earned-time accumulation according to Iowa Code section 903A.2(1). The IDOC classified Appellant’s sentence as category “B” and computed his earned time accordingly. After State v. Lyle was decided the district court resentenced Appellant to an indeterminate term without the mandatory minimum. The IDCO continued to calculate Appellant’s earned-time accumulation at the rate provided for under category “B” rather than the faster rate provided for under category “A.” The district court upheld the sentence. The Supreme Court reversed, holding that Breeden v. Iowa Department of Corrections, decided today, was dispositive and required that Appellant’s earned-time credit be recalculated at the category “A” rate for all his time served. View "James v. State" on Justia Law

Shannon Breeden and Laura Hochmuth, both juveniles when their crimes were committed, were convicted of forcible felonies listed in Iowa Code 902.12. Both offenders were subject to the mandatory minimum requirement to serve at least seven-tenths of their sentences before becoming eligible for parole or work release. Each offender received a sentence with a mandatory minimum, and the Iowa Department of Corrections (IDOC) classified their sentences as category “B” for purposes of calculating earned-time credit. The Supreme Court subsequently decided State v. Lyle, which required resentencing of all offenders serving prison sentences with automatically imposed mandatory minimum terms for crimes committed as juveniles. The district court then resentenced Breeden and Hochmuth to an indeterminate term of years but without a mandatory minimum. The IDOC continued to classify the offenders’ sentences as category “B” such that their earned-time continued to accrue at a slower rate than the rate provided for under category “A.” The court of appeals reversed based on the plain language of section 903A.2(1), which provides that earned-time credit accrues at the faster rate for sentences lacking a mandatory minimum term. The Supreme Court affirmed, holding that removal of the mandatory minimum triggers the faster accrual for earned-time credit. Remanded. View "Breeden v. Iowa Department of Corrections" on Justia Law