Justia Criminal Law Opinion Summaries

Anthony Geltz was prosecuted as a juvenile and adjudicated delinquent for sexual abuse in the second degree for an offense he committed when he was fourteen years old. After Geltz turned eighteen, the State petitioned to have him declared a sexually violent predator (SVP) under Iowa Code 229A.2(11). The district court ordered Geltz confined as an SVP based on Geltz's previous offense. The Supreme Court reversed, holding (1) a juvenile adjudication does not constitute a predicate conviction required to commit an offender as an SVP pursuant to section 229A.2; and (2) therefore, the district court erred in committing Geltz as an SVP solely on the basis of his juvenile adjudication for the offense he committed at age fourteen. View "In re Detention of Geltz" on Justia Law

Defendant pled guilty to four counts of fraudulent practices for willfully failing to file his Iowa income tax returns and pay taxes for the years 2006 through 2009. After a restitution hearing, the district court ordered Defendant to pay restitution in the form of unpaid taxes but denied the State's request for penalties and interest as part of the restitution order. The Supreme Court reversed the district court's denial of penalties and interest as part of the restitution order, holding that the court erred by not including in its restitution order (1) the requested civil tax penalties, as the civil tax penalties were properly awarded as an element of pecuniary damages in the restitution order; and (2) prejudgment and postjudgment interest at the statutory rate under Iowa Code 421.7. View "State v. Hagen" on Justia Law

After a jury trial, Defendant was convicted of third-degree sexual abuse. Six years later, the Supreme Court overturned Defendant's conviction and sentence and remanded for a new trial. The second trial resulted in Defendant's acquittal. Defendant subsequently filed an application to be declared a wrongfully imprisoned individual pursuant to Iowa Code 663A.1. The district court granted the application. The State appealed. The Supreme Court reversed and remanded, holding (1) Defendant was eligible to bring a wrongful imprisonment claim when he was acquitted on retrial; (2) the district court erred by failing to consider testimony that had been presented at Defendant's two criminal trials in making the wrongful imprisonment determination, even though the State did not show the witnesses were no longer available; and (3) while substantial evidence supported the district court's finding of innocence on the existing record, a remand was necessary for the court to consider the full record, including the prior testimony. View "State v. DeSimone" on Justia Law

Defendant was the driver in an accident that resulted in the deaths of Mark Empen and Lindsay Gibbs. Defendant entered into civil settlement agreements with the estates of Empen and Gibbs. Defendant subsequently pleaded guilty to two counts of homicide by vehicle. The district court sentenced Defendant to a term of imprisonment and ordered Defendant to pay restitution to the victims' families. Several years later, Defendant applied for an order stating he had satisfied his restitution obligation, arguing that the settlement amounts paid to the victims' estates should be set off against the restitution amounts he was ordered to pay the families. The district court denied the applications. The Supreme Court reversed, holding that Defendant was entitled to a setoff for the settlement payments made to each estate. View "State v. Driscoll" on Justia Law

Defendant pleaded guilty to theft and agreed to enter a drug court program. The district court also ordered that Defendant participate in residential treatment at the Iowa Residential Treatment Center (IRTC). As a result of drug court program violations, Defendant was incarcerated in jail for a period of time. Defendant was later arrested for another violation of the terms of the drug court program. The district court then removed Defendant from participation in the drug court program and imposed a sentence for second-degree theft as a habitual offender pursuant to the plea bargain. Upon resentencing, the district court denied Defendant credit for time spent at IRTC and for the time Defendant spent in jail. The Supreme Court vacated the district court sentence in part, holding that Defendant was entitled to credit for time spent at the IRTC and for time spent in jail as a result of his drug court program violations. View "State v. Calvin" on Justia Law

After a jury trial, Defendant was convicted of the second-degree murder of his live-in girlfriend. The Supreme Court affirmed, holding that the district court did not reversibly err by (1) failing to submit an instruction on the lesser included offense of voluntary manslaughter, as the evidence of provocation was insufficient to support admission; (2) excluding hearsay evidence relevant to Defendant's diminished-capacity defense based on his posttraumatic stress disorder, as Defendant failed to lay a foundation supporting any exception to the hearsay rule; (3) declining to obtain and review the victim's mental health records for exculpatory information; and (4) denying Defendant's motion for a new trial. View "State v. Thompson" on Justia Law

After a jury trial, Defendant was convicted of six counts of child endangerment and sentenced to fifty years in prison. The victim was Defendant's seven-week-old son. The baby suffered fifteen rib fractures, a broken arm, and a permanent brain injury over a three-week period. The victim's mother (Mother) pled guilty to child endangerment. On appeal, the Supreme Court (1) vacated Defendant's convictions as to two counts for the baby's broken ribs, holding that the evidence was insufficient to sustain the convictions; (2) reversed the trial court's denial of Defendant's motion for an in camera review of Mother's mental health records under Iowa Code 622.10(4), a statute the Court upheld as constitutional; and (3) otherwise affirmed. View "State v. Neiderbach" on Justia Law

Following a jury trial, Defendant, a juvenile, was convicted of first-degree murder and mandatorily sentenced to life without parole. Defendant subsequently pursued numerous postconviction relief actions, including an application to correct his sentence. After the Supreme Court remanded the case to the district court to consider the constitutionality of Defendant's sentence, the U.S. Supreme Court decided Miller v. Alabama, which held that the constitution prohibited a sentencing scheme mandating life in prison without possibility of parole for juvenile offenders. Before Defendant's hearing, the Governor commuted Defendant's sentence to life with no possibility for parole for sixty years. At the hearing before the district court, Defendant argued he should still be resentenced under Miller. The district court (1) concluded that the Governor exceeded his authority by commuting Defendant's sentence because the commutation circumvented the individualized sentencing required under Miller, and (2) resentenced Defendant to life in prison with the possibility of parole after twenty-five years. The Supreme Court affirmed, holding (1) Defendant's commuted sentence still amounted to cruel and unusual punishment; and (2) consequently, the district court properly resentenced Defendant in light of Miller. View "State v. Ragland" on Justia Law

After a jury trial, seventeen-year-old Defendant was convicted of two counts of first-degree robbery and two counts of first-degree burglary. The district court imposed a fifty-year sentence, of which Defendant was required to serve thirty-five years, at which point she would become eligible for parole. The Supreme Court vacated Defendant's sentence, holding (1) Defendant's sentence of a minimum of thirty-five years without the possibility of parole for the crimes involved in this case violated the core teachings of Miller v. Alabama; and (2) an individualized sentencing hearing was required in this case. Remanded. View "State v. Pearson" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to second-degree murder and first-degree robbery. Defendant was sixteen years old at the time he committed the offenses. The district court imposed a seventy-five-year aggregate sentence, of which Defendant was required to serve 52.5 years. Defendant's alleged actions took place before the Supreme Court's decision in Miller v. Alabama. On appeal, the Supreme Court affirmed Defendant's convictions but vacated his sentence, holding (1) Defendant's 52.5-year minimum prison term triggered the protections to be afforded under Miller - namely, an individualized sentencing hearing to determine the issue of parole eligibility; and (2) a district court must recognize and apply the core teachings of Roper v. Simmons, Graham v. Florida, and Miller in making sentencing decisions for long prison terms involving juveniles. Remanded. View "State v. Null" on Justia Law