Justia Criminal Law Opinion Summaries

Appellant was a registered sex offender who was not permitted to loiter within 300 feet of a public library. In 2012, Appellant was arrested for sitting on a park bench located across the street from the main entrance of a public library. Appellant was facing the library and had been sitting on the bench, which was seventy-two feet from the front door of the library, for approximately forty-five minutes. The district court subsequently convicted Defendant of loitering within 300 feet of a public library in violation of Iowa Stat. 692A.113(1)(g). On appeal, Appellant contended that there was insufficient evidence was “loitering” within the meaning of the statute. The Supreme Court reversed the conviction and remanded for new findings, conclusions, and judgment because it was unclear whether the district court applied the appropriate legal standard in this case. View "State v. Showens" on Justia Law

After a jury trial, Defendant was convicted of sexual exploitation by a school employee in violation of Iowa Code 709.15(3)(a) and (5)(a). At the time of the offense, Defendant was a worker at a local pipe manufacturer who, while not a licensed teacher, coached high school basketball under a coaching authorization. Defendant appealed, arguing that he was not a school employee as the term is used under section 709.15(3)(a), and therefore, he was not subject to criminal prosecution under this statute. The Supreme Court reversed and remanded with instructions to dismiss the case, holding that a coach who holds a teaching or other professional license is subject to the statute, but a mere holder of a coaching authorization without a professional license within the meaning of Iowa Code 272.1(7) does not fall under the sexual exploitation statute. View "State v. Nicoletto" on Justia Law

After a jury trial in 2007, Tammy Smith was convicted of child endangerment resulting in serious injury against her four-year-old son. The court of appeals affirmed on appeal. In 2009, Smith applied for postconviction relief based on evidence that her son communicated that his injury occurred when he placed his arm in the washing machine. The court of appeals held that this was newly discovered evidence and remanded for a new trial. On remand, the district court vacated Smith’s conviction and dismissed the case against Smith. In 2011, Smith filed a petition for wrongful imprisonment. The district court found that Smith did not establish by clear and convincing evidence neither she nor anyone else committed the crime of child endangerment. The court of appeals affirmed. The Supreme Court affirmed, holding that substantial evidence supported the district court’s finding that Smith did not establish her wrongful imprisonment action by clear and convincing evidence. View "Smith v. State" on Justia Law

After a jury trial, Defendant was convicted of voluntary manslaughter and five counts of intimidation with a dangerous weapon with intent. The Supreme Court vacated Defendant’s convictions on three counts of intimidation with a dangerous weapon with intent and affirmed his remaining convictions, holding (1) trial counsel was ineffective for failing to move for a judgment of acquittal after the verdict on the intimidation counts because the evidence did not support the verdicts that Defendant committed five separate and distinct acts of intimidation with a dangerous weapon with intent; (2) however, substantial evidence supported two separate and distinct crimes of intimidation with a dangerous weapon with intent; (3) the record was inadequate to decide Defendant’s separate allegation of ineffective assistance of counsel; and (4) the district court did not abuse its discretion in failing to admit certain photographs into evidence. Remanded. View "State v. Ross" on Justia Law

Pursuant to a plea agreement, Defendant pled guilty to three counts of intimidation with a dangerous weapon with intent and one count of a felon in possession of a firearm. Defendant appealed, arguing, inter alia, that his counsel was ineffective for allowing him to plead guilty to three counts of intimidation with a dangerous weapon with intent, as there was no factual basis to support three separate and distinct acts. The Supreme Court reversed the judgment of the district court on the three separate charges of intimidation with a dangerous weapon, holding that trial counsel was ineffective for allowing Defendant to plead guilty to the three separate charges when no factual basis existed to establish Defendant's shooting of his gun in the air was three separate and distinct acts. Remanded. View "State v. Gines" on Justia Law

Defendant approached two separate tellers at a bank and demanded that each teller give him money from their cash drawers. After a jury trial, Defendant was convicted of two counts of robbery in the second degree. On appeal, Defendant contended that only one robbery occurred and that substantial evidence did not support the two robbery convictions. The court of appeals affirmed. The Supreme Court also affirmed, holding (1) the district court did not impose an illegal sentence by failing to combine the two robbery convictions into a single count, as the record contained substantial evidence that Defendant had the intent to commit two separate and distinct thefts; and (2) substantial evidence supported the two robbery convictions. View "State v. Copenhaver" on Justia Law

In 2002, David Buchwald pleaded guilty to a single count of lascivious acts with a child. Upon his release from prison in 2004, Buchwald was required to register as a sex offender for ten years. In 2011, Buchwald petitioned for modification of this requirement. After determining that Buchwald met the requirements of the statutory registration modification provision, the district court granted modification and reduced the duration of Buchwald’s registration obligation to five years. Because five years had elapsed before Buchwald petitioned for modification, the district court ordered Buchwald removed from the registry. The State filed a petition for writ of certiorari, arguing that the district court erred in determining that Buchwald was eligible for modification under the provision. The Supreme Court granted the petition and transferred the case to the court of appeals. Upon further review, the Supreme Court annulled the writ, holding that the district court’s modification and removal order was legal under the statutory provision. View "State v. Iowa Dist. Court for Story County" on Justia Law

After a jury trial, Defendant was convicted of kidnapping in the first degree, among other charges. Defendant was a juvenile at the time of the kidnapping. The district court sentenced Defendant to life imprisonment without the possibility of parole for the kidnapping conviction. After the U.S. Supreme Court decided Graham v. Florida, Defendant filed a motion to correct an illegal sentence on the kidnapping conviction, contending that his sentence violated the Eighth Amendment of the U.S. Constitution. The district court agreed that the sentence was unconstitutional and corrected Defendant’s conviction to life in prison with immediate parole eligibility. Defendant appealed, claiming, inter alia, that his sentence was unconstitutional under both the U.S. and the Iowa Constitutions. The court of appeals affirmed Defendant’s conviction and sentence as corrected. The Supreme Court conditionally affirmed, holding that Defendant’s sentence was constitutional under the U.S. Constitution. Because Defendant’s claims that his sentence was illegal under the Iowa Constitution were not fully developed, the Court did not reach those claims. Remanded. View "State v. Hoeck" on Justia Law

Defendant was charged with several crimes based on his involvement in a shooting. The jury found Defendant guilty of intimidation with a dangerous weapon with intent, among other crimes. At the same time, the jury answered “no” to a special interrogatory asking whether Defendant had possessed a firearm. The district court concluded that the verdicts were inconsistent and proposed that the matter be resubmitted to the jury. However, Defendant and the State requested that the court accept the verdicts as rendered. Accordingly, the district court accepted the verdicts. Defendant subsequently appealed. The court of appeals reversed and remanded for a new trial on the intimidation charge, finding the special interrogatory answer in direct conflict with the jury’s guilty verdict. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding that the verdicts were not inconsistent based on how the case was charged to the jury. View "State v. Merrett" on Justia Law

After a jury trial, Defendant was convicted of escape. Defendant appealed, arguing, among other things, that the district court abused its discretion when it refused to instruct the jury that the crime of absence from custody was a lesser included offense of escape. The court of appeals denied each claim raised by Defendant and affirmed. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the district court, holding that the crime of absence from custody is a lesser included offense of the crime of escape. Remanded for a new trial. View "State v. Miller" on Justia Law