Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the trial court denying Defendant's motion to suppress and convicting him of firearm violations, holding that the law enforcement officer who arrested Defendant did not unlawfully seize Defendant.After a woman called the police to report a suspicion car parked in front of her home an officer responded in a patrol car and pulled alongside the parked car. The officer walked over to talk to the driver, smelled a strong odor of burnt marijuana, and searched Defendant and the car. In his suppression motion, Defendant argued that the officer did not unlawfully seize him. The court of appeals concluded that the trial court did not err in denying the motion to suppress. The Supreme Court affirmed, holding that the officer's conduct in this case did not constitute a seizure, and once the officer detected the odor of burnt marijuana he had a lawful ground to detain and search Defendant and the car. View "State v. Cyrus" on Justia Law

The Supreme Court reversed the judgment of the district court granting Defendant's motion to suppress evidence obtained during a traffic stop, holding that because Defendant's license plate cover violated Iowa Code 321.37 it was reasonable for Iowa State Patrol troopers to stop his SUV, the stop was not unconstitutional, the exclusionary rule did not apply, and there were no grounds to suppress evidence from the stop.Because Defendant's rear license plate was shrouded with a tinted plastic cover troopers found it difficult to read the plate. The troopers stopped Defendant to warn him that the cover violated Iowa law and during the stop uncovered evidence leading to Defendant's charges for operating while intoxicated and child endangerment. The district court granted Defendant's motion to suppress, concluding that the traffic stop was unconstitutional. The Supreme Court reversed, holding (1) the traffic stop was constitutional because the license plate cover violated an Iowa traffic statute; and (2) therefore, the district court erred in suppressing evidence from the stop. View "State v. Griffin" on Justia Law

The Supreme Court affirmed Defendant's judgment of sentence and confirmed what it held in State v. Wilbourn, 974 N.W.2d 58 (Iowa 2022) and State v. Treptow, 960 N.W.2d 98 (Iowa 2021), that if good cause is lacking to bring a criminal appeal, an appellate court has no jurisdiction, and the appeal must be dismissed.Defendant pleaded guilty to second-degree theft and was sentenced to three consecutive five-year sentences of imprisonment. The court of appeals affirmed the sentence after finding good cause to address Defendant's challenge to his sentence under Iowa Code 814.6(1)(a)(3). The court declined to address Defendant's assertion that there was an inadequate factual basis to support his guilty plea to theft based on a lack of good cause. The Supreme Court affirmed in part and vacated the judgment in part, holding (1) because the court of appeals had jurisdiction over this appeal it should have also addressed Defendant's challenge to the factual basis supporting his guilty plea; and (2) even though this Court had jurisdiction over Defendant's appeal, it lacked the authority to resolve his factual basis challenge. View "State v. Rutherford" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant, following a jury trial, of murder in the second degree, obstructing prosecution, and abusing a corpse, holding that the district court did not abuse its discretion by giving a verdict-urging instruction in this case.On appeal, Defendant argued that the district court coerced the jury's verdict by giving a verdict-urging instruction after the court was informed that the jury was divided 11-1 and that one juror was not following the judge's instructions. The court of appeals vacated Defendant's convictions, concluding that the jury's verdict was coerced. The Supreme Court vacated the court of appeals' opinion and affirmed Defendant's convictions, holding that the court of appeals erred in its coercion analysis and that the jury's verdict was not coerced under the circumstances. View "State v. Church" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of first-degree robbery and willful injury causing serious injury, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued, among other things, that the district court imposed an illegal and unconstitutional sentence by failing to merge his two convictions. The Supreme Court affirmed, holding (1) there was sufficient evidence to convict Defendant of willful injury causing serious injury; and (2) the district court did not err by not merging the willful injury causing serious injury conviction with the first-degree robbery conviction because there are additional elements of willful injury causing serious injury that are not encompassed within the elements of first-degree robbery under the dangerous weapon alternative. View "State v. Cook" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions for first-degree robbery and willful injury causing serious injury, holding that Defendant was not entitled to relief on his allegations of error.Defendant's convictions stemmed from his role in the baseball bat attack of a man outside his apartment complex, and a surveillance camera captured some of the altercation. The Supreme Court held (1) there was sufficient evidence to convict Defendant of first-degree robbery based on the victim's testimony and the corroborating surveillance video evidence of the attack; (2) the district court's failure to merge the convictions was not erroneous; and (3) Defendant was not prejudiced by the district court's decision to continue the trial for nine days due primarily to juror illness. View "State v. Brown" on Justia Law

The Supreme Court affirmed the order of the juvenile court granting the State's delinquency petition against Defendant and its motion to waive jurisdiction to allow for Defendant's prosecution as an adult, holding that the juvenile court did not abuse its discretion in granting the waiver and that there was sufficient evidence to support Defendant's conviction.One month after his seventeenth birthday Defendant committed second-degree sexual abuse. The juvenile court issued an order waiving jurisdiction, concluding that there were not reasonable prospectives for rehabilitating Defendant if the juvenile court retained jurisdiction and that the waiver was in the bests interests of Defendant and the community. Defendant was found guilty after a jury trial. The Supreme Court affirmed, holding (1) a rational fact finder could determine beyond a reasonable doubt that Defendant committed second-degree sexual abuse based on the evidence presented; and (2) the juvenile court's waiver decision was supported by the evidence and reasonable. View "State v. Erdman" on Justia Law

The Supreme Court affirmed the summary judgment granted by the district court in favor of the City of Muscatine on claims seeking to hold the City vicariously liable for a former police officer's sexual assault, holding that Plaintiff was not entitled to relief as to her allegations of error.Plaintiff, who was drunk, was offered a ride to a hotel by a police officer. The officer followed Plaintiff to her room and raped her. The officer was convicted of third-degree sexual abuse of an incapacitated person. Plaintiff later sued the officer and the City alleging several tort causes of action. The district court granted summary judgment to the City, determining that Plaintiff failed to prove that the assault was within the scope of the officer's employment. The Supreme Court affirmed, holding that the district court (1) did not err in determining that Plaintiff's sexual assault fell outside his scope of employment; and (2) this Court declines to adopt Plaintiff's proposed aided-by-agency theory to impose vicarious liability on the City. View "Martin v. Tovar" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count each of willful injury and intimidation with a deadly weapon, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that the district court erroneously denied his motion to dismiss because the State charged him more than one year after the three-year statute-of-limitations period was over. In response, the State argued that the district court correctly determined that the statute of limitations tolled between May 25, 2016 and September 21, 2020. The Supreme Court agreed with the State, holding that the district court correctly found that the statute of limitations tolled during the relevant period because Defendant was not publicly resident in Iowa. View "State v. Boone" on Justia Law

The Supreme Court vacated Defendant's sentence and remanded this case for resentencing, holding that the district court imposed an illegal sentence by choosing not to impose the requirements set forth in Iowa Code 124.401(5)(f).Pursuant to a plea agreement, Defendant pleaded guilty to possession of methamphetamine, third or subsequent offense, a class D felony, in violation of section 124.401(5). At the sentencing hearing, Defendant asked that he be sentenced to a fine. The State responded that a fine alone would be an illegal sentence under Iowa Code 901.5. The district court orally sentenced Defendant to the minimum fine only. The State filed a motion to correct an illegal sentence. The Supreme Court vacated the sentence, holding that the district court's fine-only sentence was illegal because, in choosing not to impose probation subject to random drug testing and at least a suspended sentence of the minimum forty-eight-hour term of imprisonment required under section 124.401(5)(f), the sentence lacked statutory authorization. View "State v. Iowa District Court for Woodbury County" on Justia Law