Justia Criminal Law Opinion Summaries

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

Defendant was convicted of operating while intoxicated, second offense. Defendant appealed the district court’s denial of his motion to suppress the breath-test result obtained after his arrest, arguing that he had been denied his statutory right to an independent chemical test. The court of appeals reversed, concluding that the district court erred in denying Defendant’s motion to suppress. The Supreme Court affirmed, holding (1) Defendant’s statutory right to an independent chemical test was violated when he made statements that could be reasonably construed as a request for an independent test under Iowa Code 321J.11 but law enforcement denied his request, and (2) the error was not harmless. Remanded for a new trial. View "State v. Lukins" on Justia Law

Defendant was charged with and found guilty of driving under revocation. Defendant appealed, arguing that the district court’s admission of a certified abstract of his driving record and affidavits of the mailing of suspension notices violated his rights under the Confrontation Clauses of the United States and Iowa Constitutions. The court of appeals concluded that the admission of the disputed documents did not violate the Confrontation Clauses. The Supreme Court affirmed, holding (1) the admission of the certified abstract of Defendant’s driving record did not violate the Confrontation Clauses; and (2) the admission of the affidavits of the mailing of suspension notices violated the Confrontation Clauses, but their admission into evidence was harmless error. View "State v. Kennedy" on Justia Law

Police officers stopped Defendant’s vehicle after discovering that the vehicle’s license plate frame covered up the county name on the license plate, which the officers believed violated Iowa Code 321.37(3). As a result of the stop, Defendant was charged with possession with intent to deliver crack cocaine, a drug tax stamp violation, and driving under suspension. A district court judge denied Defendant’s motion to suppress, concluding that the license plate frame violation gave no reason to stop Defendant but that the stop was lawful based on a reasonable suspicion of drug dealing. A different judge who presided at trial upheld the stop based on the license plate violation alone. After a jury trial, Defendant was found guilty as charged. The court of appeals affirmed, which held that the traffic stop was lawful based on reasonable suspicion of drug dealing without deciding the license plate issue. The Supreme Court affirmed the conviction without reaching the issue of whether the traffic stop was lawful based on reasonable suspicion of drug dealing, holding that a license plate frame that covers up the county name violates Iowa Code 321.37(3) and provides a valid basis for a traffic stop. View "State v. Harrison" on Justia Law