Justia Criminal Law Opinion Summaries

Defendant was approached by law enforcement officers while walking on the side of the road at 1:10 a.m. The officers asked Defendant if he would consent to a search of his person, and Defendant consented to a search. Defendant was subsequently charged with possessing methamphetamine. Defendant moved to suppress the evidence, arguing that the warrantless search violated the Federal and State Constitutions. The district court denied the motion, concluding that Defendant voluntarily consented to the search. On appeal, Defendant argued that the search violated Iowa Const. art. I, section 8, which requires police to “advise an individual of his or her right to decline to consent to a search.” The Supreme Court affirmed, holding (1) Defendant’s article I, section 8 argument was not preserved for appellate review; and (2) because the totality of the circumstances indicated that Defendant voluntarily consented to the search, the search was valid under the Fourth Amendment. View "State v. Prusha" on Justia Law

Plaintiff sued his former criminal defense attorneys for legal malpractice, alleging that they allowed him to plead guilty to a crime that lacked a factual basis. The district court granted summary judgment in favor of the attorneys on the basis that Plaintiff could not show he was actually innocent of any offense that formed the basis for the underlying criminal case. The Supreme Court reversed, holding that a criminal defendant’s showing of actual innocence is not a prerequisite to bringing a legal malpractice against his or her former criminal defense attorney. Instead, innocence or guilt should be taken into account when determining whether the traditional elements of a legal malpractice claim have been established. Remanded. View "Barker v. Capotosto" on Justia Law

Defendant was charged with first-degree burglary, third-degree burglary, and domestic abuse. The district court found Defendant to be indigent and appointed private counsel to represent him. Defendant pled not guilty and filed an application for appointment of a private investigator at state expense. After the district court hired a hearing on the application, Defendant filed a motion requesting the portion of hearing concerning the merits of his application to be conducted ex parte. The district court denied the motion for an ex parte hearing, concluding that the State had a right to participate in the hearing on the merits of the application. The Supreme Court reversed, holding that Defendant was entitled to an ex parte hearing on the merits of his application for appointment of a private investigator at state expense. Remanded. View "State v. Dahl" on Justia Law

Defendant was convicted of second-degree murder for delivering the first, nonlethal blow to the victim in a fatal beating. Defendant’s blow knocked the victim down, and then others kicked and stomped the victim to death. The Supreme Court affirmed in part and reversed in part, holding (1) substantial evidence supported the jury’s guilty verdict on theories of principal liability and accomplice liability; (2) there was not substantial evidence to support the theory of joint criminal conduct that was also submitted to the jury; and (3) because the jury returned a general verdict of guilty and there was the possibility that at least one juror found Defendant guilty only on the basis of the invalid theory of joint criminal conduct, Defendant’s conviction must be reversed. Remanded for a new trial. View "State v. Tyler" on Justia Law

After Defendant, who had been released from custody on an unsecured appearance bond, made threatening remarks about Assistant Dubuque County Attorney Brigit Barnes, the district court revoked Defendant’s bond and set the matter for trial. Defendant subsequently filed a motion for recusal or disqualification of both Barnes individually and the entire Dubuque County Attorney’s Office. The district court granted the motion to recuse, concluding that, in light of the alleged threats Defendant made against Barnes, the county attorney’s office could not proceed with an unbiased prosecution of the allegations against Defendant. The Supreme Court reversed the disqualification order, holding that the district court’s decision was untenable because it was not supported by substantial evidence and was based on an erroneous application of the law. View "State v. Iowa Dist. Court for Dubuque County" on Justia Law

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