Justia Criminal Law Opinion Summaries

A teenage girl reported that Defendant had molested her eight years earlier. Defendant was subsequently charged with two counts of sexual abuse of a minor, indecent contact with a minor, and kidnapping with intent to commit sexual abuse. Defendant filed a motion to dismiss the kidnapping charge as time-barred under Iowa Code 802.3, the general three-year statute of limitations for felonies. The district court denied the motion to dismiss. The Supreme Court reversed the district court’s denial of Defendant’s motion to dismiss after noting that the legislature did not include kidnapping among the four exceptions to the three-year limitations provision, holding that, under the plain meaning of the statutory text, the kidnapping charge is time-barred. Remanded to proceed under the remaining charges. View "State v. Walden" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to voluntary manslaughter, attempted murder, and willful injury causing serious injury. Defendant appealed, arguing that attempted murder and willful injury convictions are both included offenses of voluntary manslaughter and, therefore, must merge with the voluntary manslaughter conviction. The court of appeals affirmed, holding that because voluntary manslaughter can be committed without a specific intent to kill, attempted murder and willful injury resulting in serious injury, which must be committed with a specific intent to kill, are not included offenses of voluntary manslaughter. The Supreme Court vacated the decision of the court of appeals and judgment of the district court, holding that, under the circumstances of this case, the voluntary manslaughter and attempted murder convictions are mutually exclusive because a defendant cannot be convicted of both an attempted homicide and a completed homicide when the convictions are based on the same acts directed against the same victim. View "State v. Ceretti" on Justia Law

When he was seventeen years old, Appellant committed the crime of first-degree robbery. Appellant was sentenced to a term of imprisonment not to exceed twenty-five years. Appellant was sentenced under a statute that required him to serve at least seventy percent of his sentence before he was eligible for parole. Appellant appealed, arguing that his sentence constituted cruel and unusual punishment. The Supreme Court vacated the sentence and remanded to the district court for resentencing, holding that, for the reasons express in State v. Lyle, filed on this same date, the mandatory sentence violated the prohibition against cruel and unusual punishment under the Iowa Constitution. View "State v. Taylor" on Justia Law

The State charged Defendant, a probationer, with burglary and theft after police officers conducted a warrantless search of Defendant’s home. Defendant filed a motion to suppress contending that the search warrant was invalid because it inaccurately described the house to be searched and because an alteration of the warrant based upon a verbal conversation with the issuing judge violated the statutory requirement that search warrant applications be in writing. The district court overruled the motion to suppress, concluding that the search warrant was inadequate but that the warrant was valid because the search was within the contemplation of the probation agreement. The court of appeals affirmed, concluding that the search of the probationer based upon reasonable suspicion of criminal activity and based upon the limited scope of the search was valid under the search and seizure provision of Iowa Const. art I, 8. The Supreme Court reversed, holding that, in accordance with State v. Cullison, the search of Defendant’s home by general law enforcement authorities was unlawful under the Iowa Constitution because the search was based on an invalid warrant. View "State v. Short" on Justia Law

Appellant was a seventeen-year-old high school student when he took a small plastic bag containing marijuana from a fellow student outside the high school. After a jury trial, Appellant was convicted of robbery in the second degree. Appellant was prosecuted as an adult and was sentenced under a statute that required the imposition of a mandatory seven-year minimum sentence of imprisonment. Appellant appealed, arguing that the mandatory minimum was unconstitutional as applied to him. During the pendency of the appeal, the United States decided Miller v. Alabama. The court of appeals affirmed the sentence. The Supreme Court granted review to consider whether Appellant’s sentence was constitutional in light of the cases the Court handed down subsequent to Miller. The Supreme Court vacated the sentence and remanded for resentencing, holding that a statute mandating a sentence of incarceration in a prison for juvenile offenders with no opportunity for parole until a minimum period of time has been served is unconstitutional under the Iowa Constitution. View "State v. Lyle" on Justia Law

Defendant was a pastor who had sexual relations with four women in his congregation. Defendant was convicted of four counts of sexual exploitation by a counselor or therapist and one count of a pattern or practice to engage in sexual exploitation by a counselor or therapist. The court of appeals reversed and remanded for a new trial, holding that the district court failed properly to instruct the jury on the sexual exploitation statute and that the district court abused its discretion in excluding expert testimony concerning differences between pastoral care and pastoral counseling. The Supreme Court vacated the decision of the court of appeals, concluding that the district court did not err in instructing the jury and excluding the proffered expert testimony. The Court then held (1) the district court erred in denying Defendant’s discovery request for one of the victim’s counseling records and erred in the amount of restitution awarded; and (2) the district courts judgment was correct in all other respects. Remanded. View "State v. Edouard" on Justia Law

Defendant pleaded no contest to second-degree sexual assault of a child, a felony, in Wisconsin. The Wisconsin trial court deferred judgment of conviction (DJOC), which allowed the Wisconsin court to refrain from entering an adjudication of guilt and a judgment for four years if Defendant agreed to certain terms. Before the termination of the DJOC, the state of Iowa charged Defendant with a violation of Iowa’s felon-in-possession statute, Iowa Code 724.26, which prohibits felons from possessing firearms in Iowa. Defendant filed a motion to dismiss the Iowa charge, arguing that the predicate Wisconsin felony was not a conviction for purposes of section 724.26. The district court denied the motion. The Supreme Court affirmed, holding that district court properly denied Defendant’s motion to dismiss the case where the Wisconsin court found Defendant guilty upon his tendering of a no contest plea and where Defendant had not completed the terms of his deferred judgment on his felony count. View "State v. Olsen" on Justia Law

Defendant was charged with and pled guilty to criminal transmission of HIV in violation of Iowa Code 709C.1. The district court accepted the plea, sentenced Defendant to twenty-five years suspended and placed Defendant on probation for five years. Defendant subsequently filed an application for postconviction relief, claiming that his trial counsel provided ineffective assistance for allowing him to plead guilty, by failing to challenge the factual basis of the plea, and failing to complete a proper investigation before the plea hearing. The district court denied the application, and the court of appeals affirmed. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the trial court, holding that the guilty plea record did not contain a factual basis to support the plea, and the court in this case could not use the rule of judicial notice to establish the factual basis in the guilty plea record. Remanded. View "Rhoades v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree sexual abuse for performing a sex act on a two-year-old girl. Defendant appealed, arguing that the district court erred by admitting as prior bad acts evidence the fact that child pornography was found on Defendant’s computer and other electronic devices. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court did not abuse its discretion by admitting the evidence that Defendant possessed specific videos involving child sexual abuse, as the evidence was relevant to the issue of the identity of the perpetrator, and the evidence’s probative value was not substantially outweighed by the danger of unfair prejudice. View "State v. Putnam" on Justia Law

After a jury trial, Defendant was found guilty of possession of marijuana and crack cocaine with intent to deliver. The court of appeals reversed, holding that there was insufficient evidence to support the convictions. The Supreme Court reinstated Defendant’s convictions, holding (1) considering the totality of the evidence in this case, the evidence was sufficient to sustain a jury verdict of guilt; and (2) the district court correctly found that the State provided a race-neutral explanation for striking a potential alternate juror, and therefore, there was no Batson error in jury selection. View "State v. Thomas" on Justia Law