Justia Criminal Law Opinion Summaries

Appellant pleaded guilty to one count of criminal transmission of HIV. Appellant later filed an application for postconviction relief alleging that his trial counsel provided ineffective assistance by allowing Appellant to plead guilty to a charge for which there was no factual basis. The lower courts denied relief, but the Supreme Court reversed and remanded the case. On remand, the State dismissed the charges against Appellant. Appellant then filed an action under Iowa Code 663A claiming that he was wrongfully imprisoned by the State and was entitled to compensation. The district court granted the State’s motion to dismiss, concluding that Appellant was not entitled to relief because he had pled guilty in a criminal case that provided the basis for the imprisonment. The Supreme Court affirmed, holding that section 663A.1(1)(b) categorically excludes all persons who plead guilty from Iowa’s wrongful imprisonment statute, and therefore, Appellant was not entitled to pursue a claim for wrongful imprisonment under section 663A. View "Rhoades v. State" on Justia Law

Defendant pled not guilty to the charge of delivering methamphetamine. During jury selection, the prosecutor posed hypothetical questions approximating the facts of the case, intimated the State possessed additional evidence supporting guilt but could only present some of it, and implied that the State only prosecutes guilty people. The jury later returned a verdict finding Defendant guilty. Defendant filed a motion in arrest of judgment and motion for new trial. The trial court denied the motion, concluding that the State’s comments and questions were not so inflammatory as to deny Defendant a fair trial. The court of appeals concluded that the prosecutor’s questions ventured into a gray area but concluded that the remarks did not cause juror bias or make the trial unfair. The Supreme Court affirmed, holding (1) of the four lines of voir dire inquiry challenged by objection and preserved for appellate review, two were permissible; and (2) the district court mitigated any prejudice resulting from the two lines of questionable voir dire inquiry, the court’s remediate efforts were adequate under the circumstances presented here. View "State v. Martin" on Justia Law

After a jury trial, Defendant was convicted of three counts of delivery of a controlled substance. The court of appeals reversed, concluding that defendant’s right to a fair trial by an impartial jury was violated due to certain statements a prospective juror made during voir dire. The Supreme Court vacated the decision of the court of appeals and affirmed in part and reversed in part the judgment of the district court, holding (1) the district court did not deny Defendant a fair trial by an impartial jury because the statements the prospective juror made during voir dire were not so prejudicial as to warrant a presumption they tainted at least one member of the jury panel; (2) the district court did not abuse its discretion by declining to holding a hearing to permit defense counsel to show cause for missing an extended discovery and deposition deadline; (3) the record was inadequate to assess whether prejudice resulted from defense counsel’s breach of an essential duty, and Defendant may bring his ineffective assistance claim in a future postconviction relief action; and (4) the district court applied the incorrect standard in denying Defendant’s motion for new trial on the ground the verdicts were contrary to the weight of the evidence. Remanded. View "State v. Ary" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to possession of a controlled substance first offense. The judgment and sentence provided that Defendant’s driver’s license shall be revoked for 180 days and provided for several surcharges on top of the fine. Defendant appealed, arguing that his written plea was defective because it failed to disclose the statutory minimum sentence of two days in jail, the mandatory six months’ revocation of his driver’s license, and the surcharges that were added to his fine. The court of appeals affirmed Defendant’s plea and sentence. The Supreme Court vacated the decision of the court of appeals and vacated the judgment and sentence imposed by the district court, holding (1) Defendant’s plea was involuntary because revocation of the driver’s license of a person convicted of a drug possession offense is mandatory, immediate, and part of the punishment for that offense, and therefore, the court must inform the defendant of this consequence before accepting his guilty plea; and (2) Defendant had a right to be informed of fine surcharges. Remanded. View "State v. Fisher" on Justia Law

The juvenile court adjudicated J.C. a delinquent child after finding beyond a reasonable doubt that J.C. committed assault with intent to commit sexual abuse. The court of appeals affirmed. At issue before the Supreme Court was whether the juvenile court violated J.C.’s constitutional right to confrontation by admitting the out-of-court statements made by a four-year-old victim to a physician during a medical assessment and to a forensic interviewer. The Supreme Court affirmed, holding (1) admission of the physician’s testimony and report did not violate J.C.’s confrontation rights under either the Sixth Amendment or the Iowa Constitution; and (2) any error in admission of the forensic interviewer’s testimony was harmless beyond a reasonable doubt. View "In re J.C." on Justia Law

Defendant was charged with attempted murder, robbery, and willful injury. During jury deliberations, Defendant moved for a mistrial or, alternatively, a poll of the jurors about their possible exposure to a factually inaccurate media account of the case. The district court denied the motions, concluding that a factually inaccurate media article that appeared online during Defendant’s trial had not prejudiced Defendant. The Supreme Court affirmed, holding that the factually inaccurate article did not raise serious questions of possible prejudice, and therefore, the district court did not abuse its discretion in denying Defendant’s motion for a mistrial and alternative motion to poll the jury. View "State v. Gathercole" on Justia Law

Defendants participated in an insurance fraud ring that staged car accidents in Illinois. Defendants lived in Wisconsin and Illinois and had never been to Iowa before their extradition. A Wisconsin insurance company paid Defendants’ claims through its Wisconsin bank account. Two of the insurer’s employees interviewed Defendants by phone from the insurer’s Davenport, Iowa branch office. The insurance fraud was reported to detectives at the Davenport Police Department, and all three defendants were arrested in their home states and extradited to Iowa. Defendants were charged with five criminal offenses. Defendants moved to dismiss for lack of jurisdiction. The district court granted the motions to dismiss. The Supreme Court (1) affirmed the district court’s dismissal of one charge, as the State failed to show that any defendant submitted a false written statement or certificate in Iowa; and (2) reversed the district court’s dismissal of the other criminal charges, holding that the phone calls between Defendants and the insurer’s investigators in Davenport induced payments on false insurance claims, a detrimental effect in Iowa, which constituted an element of four of the five crimes charged. View "State v. Rimmer" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The trial court instructed the jury on both the premeditation and felony-murder alternatives of first-degree murder, with the underlying predicate felony being terrorism. In 2006, the Supreme Court decided State v. Heemstra, which was not given retroactive effect. If Heemstra had been controlling at the time of Defendant’s conviction, terrorism could not have been used as the predicate felony and the felony-murder instruction could not have been given as a theory to convict Defendant. Defendant later filed this second application for postconviction relief, arguing that his conviction should be vacated and a new trial ordered because the nonretroactive application of Heemstra violates constitutional due process, separation of powers, and equal protection guarantees. Defendant also argued for the first time on appeal that his postconviction counsel were ineffective. The Supreme Court affirmed, holding (1) the nonretroactivity of the rule set forth in Heemstra does not violate the due process, separation of powers, or equal protection clauses of the Iowa Constitution or the equal protection clause of the United States Constitution; and (2) Defendant’s postconviction counsel provided effective assistance. View "Nguyen v. State" on Justia Law

Defendant pled guilty to two counts of sexual abuse in the third degree. The district sentenced Defendant to two concurrent, indeterminate ten-year sentences. Defendant appealed, arguing that the district court applied the wrong Code section at his sentencing and that the error could not be corrected by the use of a nunc pro tunc order. The court of appeals agreed with Defendant and vacated the judgment and sentence to allow the district court to amend the judgment and sentence to reflect Defendant’s intent in entering the plea. On remand, the district court resentenced Defendant to two indeterminate ten-year sentences to be served consecutively instead of merely correcting the error in the sentencing order. The Supreme Court vacated the judgment and sentence of the district court, holding that the district court exceeded its mandate when it resentenced Defendant upon remand. Remanded. View "State v. Pearson" on Justia Law

After a jury trial, Defendant was found guilty of domestic abuse assault and domestic abuse assault causing bodily injury. Defendant appealed, arguing that the district court erred in (1) admitting hearsay statements made to police and medical personnel, and (2) failing to merge the two convictions for purposes of sentencing. The court of appeals (1) concluded that the district court erred by admitting the alleged victim’s statements to police but did not err in admitting the alleged victim’s statements made to the nurse or doctor and that Defendant was not prejudiced by the admission of the hearsay statements to police; and (2) merged the convictions and affirmed the judgment and sentence for domestic abuse assault causing bodily injury. The Supreme Court affirmed in part and vacated in part the decision of the court of appeals, holding that the trial court erred by admitting the alleged victim’s hearsay statements through the testimony of the emergency room nurse and doctor without sufficient foundation, and the error was prejudicial. View "State v. Smith" on Justia Law