Justia Criminal Law Opinion Summaries

In this case, the Supreme Court considered whether an internal audit created by Broadlawns Medical Center as a result of the theft of drugs by an employee was a public record under the Iowa Open Records Act. The district court concluded that, because the internal audit was provided to the Iowa Board of Pharmacy in order to assist in its investigation of licensing matters arising from the theft, the internal audit amounted to investigative materials in the hands of a licensing board under Iowa Code 272C.6(4) and was not subject to disclosure. The Supreme Court (1) reversed the judgment of the district court holding that the internal audit was not subject to disclosure, as the internal pharmacy audit was a public record, not a confidential record, and other statutory exceptions asserted to prevent public disclosure were inapplicable; and (2) affirmed the rulings of the district court that the plaintiff failed to establish the basis for nondisclosure under Iowa Code 22.7(61).

Rachel Overbay, the driver of a vehicle, was involved in an accident and transferred to the hospital. A law enforcement officer requested a blood sample from Overbay. Overbay, however, was incorrectly informed that her refusal of the requested chemical test would automatically lead to revocation of her driving privileges. In fact, Overbay's refusal of the blood test would not have been deemed final but would have led to her being offered a different chemical test. Overbay agreed to provide the blood sample, and the results showed a blood alcohol content of more than twice the legal limit. The State subsequently charged Overbay with operating a motor vehicle while under the influence of alcohol. The district court granted Overbay's motion to suppress, finding that Overbay's consent to the blood test was not voluntary because it was based on misleading information. The court of appeals affirmed. The Supreme Court vacated the court of appeals and reversed the district court, holding that consistent with precedent, inaccurate information does not render a driver's consent involuntary when the record indicates that the inaccuracy did not affect the driver's decision. Remanded.

Defendant Jerin Mootz was convicted for assault on a police officer resulting in bodily injury. During voir dire, Mootz sought to use a peremptory challenge to remove a Hispanic juror. The district court found Mootz was using his strikes in a racially discriminatory manner, denied the strike, and seated the juror. The court of appeals affirmed the conviction, finding that the district court erred in refusing to allow the strike of the potential juror, but that Mootz had not shown that the error prejudiced him. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the district court, holding (1) the trial court erred when it prohibited Mootz from using his peremptory challenge to remove the juror; (2) Mootz, or any other similarly situated defendant, was not required to show actual prejudice in order to reverse his conviction; and (3) automatic reversal is required whenever a defendant is denied the use of a peremptory challenge based on an erroneous interpretation of Batson v. Kentucky and its progeny and the objectionable juror is improperly seated.

Robert Lowe was charged with several criminal counts related to Lowe's alleged manufacture of methamphetamine. Lowe moved to certain suppress statements he made to the police. The district court granted the motion, determining that because the statements had been made in response to a promise of leniency they were rendered involuntary. The Supreme Court affirmed, holding (1) the consent that led to the search of the premises was proper and the motion to suppress the physical evidence obtained as a result of the search was properly denied; and (2) when police reinitiated questioning of Lowe after he requested an attorney, they violated his constitutional rights under Miranda, and because there was not sufficient exigency to justify such questioning, the public safety exception to Miranda did not apply under the facts of this case. Therefore, Lowe's statements were properly suppressed.

After his vehicle collided with and killed a bicyclist, Defendant was convicted of homicide by vehicle, operating while intoxicated, and leaving the scene of an accident. The court of appeals affirmed his convictions but remanded for a sentencing correction. The Supreme Court granted further review to determine whether the State must prove in a prosecution under Iowa Code 707.6A(1) that Defendant's intoxication was a proximate cause of the victim's death and, if so, whether Defendant's trial counsel was ineffective for failing to raise the issue below. The Supreme Court affirmed the conviction, holding (1) the State must prove Defendant's intoxicated driving caused the victim's death to sustain a conviction for homicide by vehicle; and (2) the record was not adequate to determine whether Defendant's trial counsel was ineffective in failing to raise the causation issue, and therefore, the claim of ineffective assistance of counsel was preserved for postconviction proceedings.

Dennis Richards was convicted of second-degree murder and second-degree arson for strangling his ex-wife to death and setting her house on fire. The court of appeals reversed and remanded for a new trial after concluding that Richards should have been allowed to call a physical therapist in his defense even though the witness had been disclosed a day late. The Supreme Court vacated the decision of the court of appeals and affirmed Richards' convictions, holding that even if the district court erred in excluding the therapist, any error was harmless in light of the overwhelming evidence of Richards' guilt.

Lee Breuer was the apparent driver in a one-car accident. Breuer and the passenger were transported to the hospital, where a deputy sheriff asked Breuer to provide a breath test. Breuer refused. An officer then obtained a warrant authorizing withdrawal of a blood specimen from Breuer. Before the officer arrived at the hospital with the warrant, the deputy sheriff advised Bruer that his blood would be withdrawn by force if necessary, and Breuer acquiesced to a blood draw. The passenger in Breuer's vehicle subsequently died as a result of injuries sustained in the accident. The State charged Breuer with homicide by vehicle. Breuer filed a motion to suppress the results of the blood draw, which the district court denied. The court of appeals affirmed. The Supreme Court affirmed, holding that neither the state or federal constitution required the search warrant to be physically present before the search could begin.

Jose Aguilera was convicted of second-degree murder. In his second application for postconviction relief, Aguilera contended that he was denied due process when the prosecution failed to turn over an Iowa Division of Criminal Investigation file containing several witness statements prior to Aguilera's initial trial. The district court found the material was suppressed and that it was favorable but that it was not material to the issue of guilt and dismissed the application. The court of appeals affirmed. The Supreme Court vacated the court of appeals and reversed the district court, holding that because the suppressed, favorable statements that were not turned over by the State had a reasonable probability of impacting the outcome of the trial, a Brady violation occurred, and Aguilera's due process rights were violated. Remanded.

Matthew Elliott was found guilty by a jury of willful injury causing serious injury and child endangerment resulting in death. The court of appeals affirmed. At issue on appeal was whether the district court erred in allowing hearsay testimony from a detective when it allowed the detective to testify about a certain interview. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the district court, holding that the disputed testimony was hearsay, and the error was not harmless because the improper admission of the hearsay evidence was prejudicial to Elliott's substantive rights. Remanded for a new trial.

Following a jury trial, Robert Krogmann was convicted for attempted murder and willful injury. On appeal, Krogmann contended that (1) the district court erred in granting the State's pretrial request to freeze all his personal assets and requiring that he apply to the court for permission to use those assets for his legal defense, and (2) the prosecutor committed reversible misconduct by asking an inflammatory question at trial. The Supreme Court affirmed, holding (1) while the Court had concerns about the propriety of the asset freeze, Krogmann failed to preserve error on this issue; and (2) error was not preserved as to the incident of asserted prosecutorial misconduct, and this incident would not have amounted to reversible error in any event.