Justia Criminal Law Opinion Summaries

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

Defendant pleaded guilty to attempted murder and was sentenced to twenty-five years in prison. Defendant appealed, claiming his counsel provided ineffective assistance because counsel permitted him to plead guilty without an established factual basis for each element of the crime. The court of appeals vacated Defendant's conviction and sentence and remanded the case, concluding that the guilty plea colloquy failed to establish a factual basis for the underlying charge. The Supreme Court vacated the court of appeals' decision and affirmed the conviction and sentence of the district court, holding that the minutes of testimony provided an adequate factual basis to support Defendant's guilty plea. View "State v. Finney" on Justia Law

Defendant was charged with and convicted of operating a motor vehicle while under the influence. Defendant appealed, contending that the district court erred in denying his motion to suppress the evidence obtained from the stop of his vehicle after the police received an anonymous tip reporting a drunk driver. The Supreme Court reversed and suppressed all evidence seized from the stop, holding that the investigatory stop of Defendant was illegal under the Fourth Amendment, as a bare assertion by an anonymous tipster reporting drunk driving, without relaying to the police a personal observation of erratic driving or other facts to establish the driver is intoxicated, does not provide reasonable suspicion to stop a vehicle. Remanded for a new trial. View "State v. Kooima" on Justia Law

Defendant pleaded guilty to possession of marijuana. At the hearing on Defendant's plea and sentencing, the sentencing court threatened to convict Defendant, instead of deferring judgment, if Defendant's declined to answer the court's inquiry on whether he would test positive on a drug test. Defendant invoked his right to remain silent. The court deferred judgment but imposed 250 hours of community service and a $350 penalty. The Supreme Court vacated Defendant's sentence and remanded for resentencing, holding that the district court improperly penalized Defendant for invoking his right against self-incrimination by imposing 250 hours of community service unconnected to any legitimate penological goal related to the court's drug-test inquiry. Remanded for resentencing. View "State v. Washington" on Justia Law

After a jury trial, Defendant was convicted of five counts of sexual exploitation of a minor and three counts of sexual exploitation by a school employee. Defendant appealed, arguing, among other things, that he could not be convicted of sexual exploitation by a school employee because none of the students involved with Defendant at the time of the events charged in the trial information were in an existing teacher-student relationship with Defendant. The court of appeals affirmed Defendant's convictions. The Supreme Court affirmed, holding that the district court did not err in (1) concluding that a contemporaneous teacher-student relationship was not required for Defendant to be convicted of sexual exploitation by a school employee; (2) concluding that physical contact between a school employee and student was not required to support a conviction for sexual exploitation by a school employee; and (3) refusing to sever Defendant's charges into multiple trials. View "State v. Romer" on Justia Law

The State charged Defendant by way of trial information of "assault domestic abuse causing bodily injury - enhanced" and "assault domestic abuse by use or display of a weapon." At the close of evidence during the trial, the State moved to amend the trial information to add a habitual offender enhancement. Defendant's trial counsel did not object to the amendment, and the district court granted the State's motion. Defendant was subsequently convicted Defendant of the underlying charge in count I. After Defendant was sentenced, Defendant appealed, asserting that his trial counsel was ineffective for failing to object to the State's motion to amend the trial information. The court of appeals denied relief. The Supreme Court affirmed Defendant's conviction and sentence but vacated the court of appeals decision to reject Defendant's ineffective-assistance claim, holding (1) under certain circumstances, an amendment to add a habitual offender enhancement to a trial information should not be allowed after the close of the evidence; but (2) the record in this case was insufficient to resolve Defendant's ineffective assistance of counsel claim. View "State v. Brothern" on Justia Law

Defendant, a parolee, was charged with four drug-related crimes after a search of her house by narcotics police officers revealed firearms and marijuana. Defendant filed a motion to suppress the marijuana as evidence at trial, arguing that it was obtained in violation of her Fourth Amendment rights because she did not consent to the search. The district court found that Defendant gave advance consent to search her property without a warrant or probable cause by signing a parole agreement and that the search was justified under exigent circumstances and the community caretaking function. Defendant was then convicted as charged. The Supreme Court reversed, holding (1) three of Defendant's convictions must be dismissed for a lack of substantial evidence; and (2) the warrantless search of Defendant's home and seizure of the evidence violated the Iowa Constitution, as (i) Defendant's parole agreement did not justify the search of her home, and (ii) no exception to the warrant requirement justified the search. View "State v. Kern" on Justia Law

Appellant pleaded guilty to first-degree harassment. While Appellant was incarcerated for the offense, the State sought to have him committed as a sexually violent predator (SVP) under Iowa Code 229A. A jury found Appellant was an SVP, and Appellant was ordered for commitment. The Supreme Court remanded the case. On retrial, the jury against concluded Appellant was an SVP, and Appellant was again ordered committed. The Supreme Court affirmed, holding (1) Appellant failed to meet his burden to show by a preponderance of the evidence that he was prejudiced by his counsel's advise to sign a speedy trial waiver; (2) Appellant was not prejudiced by his trial counsel's failure to adequately argue the trial should have been bifurcated to protect Appellant's due process rights; and (3) the prosecution did not misstate the evidence during trial. View "In re Detention of Blaise" on Justia Law