Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the district court concluding that Defendant was not entitled to a new trial after the Supreme Court remanded the case with instructions for the district court to hold a hearing under Iowa R. Evid. 5.412, holding that the district court did not abuse its discretion.After a jury trial, Defendant was found guilty of assault with intent to commit sexual abuse toward K.S. and other crimes and sentenced to a term of imprisonment. On appeal, Defendant argued that the district court erred by failing to conduct a rule 5.412 hearing before deciding whether to exclude evidence that K.S. had previously made false allegations of sexual abuse. The Supreme Court reversed and conditionally remanded with directions for the district court to conduct an in camera rule 5.412 hearing. On remand, the district court held a hearing and declined to grant a new trial. The Supreme Court affirmed, holding that the district court did not abuse its discretion by concluding that Defendant had failed to prove that K.S. had made prior false claims of sexual abuse. View "State v. Trane" on Justia Law

The Supreme Court held that In re T.H., 913 N.W.2d 578 (Iowa 2018) applies only to juvenile sex offenders whose cases are prosecuted and resolved in juvenile court and declined Defendant's invitation to apply its holding to a juvenile offender who is prosecuted and convicted in district court.At age seventeen, Defendant confessed to sexually abusing three children. Defendant was convicted on four class B felony counts and, at age twenty, was sentenced to terms of imprisonment. The court suspended the prison sentences, placed Defendant on probation, and imposed the special sentence of lifetime parole applicable to class B felonies under Iowa Code section 903B.1. The court further required Defendant to register as a sex offender under Iowa Code 692A.103(1). Defendant appealed, arguing that it is unconstitutional under In re T.H. to require a juvenile to register as a sex offender. The Supreme Court reversed in part, holding (1) In re T.H. does not apply to juvenile sex offenders prosecuted in district court; (2) registration under chapter 692A is not part of the "sentence" that can be suspended under section 901.5(13); and (3) Iowa Code 901.5(13) allowsed the district court to suspend Defendant's Iowa Code 903B.1 special sentence in whole or in part. View "State v. Hess" on Justia Law

The Supreme Court affirmed Defendant's conviction of robbery in the first degree and felony murder with robbery in the first degree serving as the predicate felony, holding that the district court did not err or abuse its discretion.During the course of a robbery, Defendant beat Jeremy McDowell, who was high on methamphetamine, with a bat. McDowell died of a cardiac arrhythmia either during or immediately after the beating. On appeal from his convictions, Defendant argued that did not intend to cause McDowell's death, and therefore, the evidence was insufficient to convict him. The Supreme Court affirmed, holding (1) there was substantial evidence supporting the district court's verdict; (2) the evidence was sufficient establishing Defendant caused McDowell's death; and (3) the district court did not manifestly abuse its discretion in denying Defendant's motion for a new trial. View "State v. Stendrup" on Justia Law

The Supreme Court reversed Defendant's conviction for second-degree sexual abuse, holding that Defendant's constitutional right to a public trial was violated when the trial court closed his trial during the COVID-19 pandemic.Defendant was set to stand trial on felony charges in March 2020, but his trial was repeatedly rescheduled due to COVID. The district court ultimately concluded that allowing anyone in to attend Defendant's trial, including his family and friends, violated COVID protocols previously set by the Supreme Court. The district court also rejected the option of live-streaming the trial. The jury subsequently convicted Defendant of second-degree sexual abuse. The Supreme Court reversed, holding that the district court's exclusion of all members of the public from Defendant's trial violated Defendant's constitutional rights, requiring a new trial. View "State v. Brimmer" on Justia Law

In this interlocutory appeal, the Supreme Court reversed the decision of the district court ordering certain records produced to Plaintiff in discovery before trial, holding that the district court erred by relying on civil discovery rules to compel production of the records at issue.Plaintiff's daughter was killed in a motorcycle accident. Plaintiff brought a tort action against the driver of the motorcycle and settled without subpoenaing the county sheriff's investigative reports. After a criminal investigation and prosecution of the driver was complete Plaintiff brought this enforcement action under Iowa Code chapter 22 against the county sheriff's department seeking to obtain its complete investigation file. The district court ordered the records produced to Plaintiff in discovery before trial without ruling on their confidentiality. The Supreme Court reversed, holding that the district court erred in compelling disclosure of the sheriff's investigation materials to Plaintiff's counsel. View "Vaccaro v. Polk County" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court convicting Defendant of first-degree burglary, first-degree robbery, assault causing serious injury while participating in a public offense and willful injury causing serious injury, holding that remand was required for entry of an order merging Defendant's conviction for willful injury causing serious injury with first-degree robbery.The court of appeals primarily affirmed the judgment of the district court but agreed with Defendant that his conviction for willful injury causing serious injury merged with his conviction for first-degree robbery. The Supreme Court affirmed, holding (1) the district court's rulings were all correct except as to Defendant's merger claim; and (2) a defendant's prior conviction for vehicular homicide by reckless driving under Iowa Code 707.6A(2) is a "crime of similar gravity" to a forcible felony for purposes of applying the sentencing enhancement set forth in Iowa Code 902.11. View "State v. Bloom" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction for possession of a controlled substance with intent to deliver, holding that Iowa R. Evid. 5.106 and the common law doctrine of completeness cannot trump Iowa R. Evid. 5.402.Specifically, the Supreme Court held (1) Defendant's right to a jury drawn from a fair cross section of the community under Iowa Const. art. I, 10 was not violated; (2) Defendant's claims of ineffective assistance of counsel were not properly before the Court and must be raised in the first instance on postconviction review; (3) the district court did not abuse its discretion in excluding certain documents proffered by Defendant as a discovery sanction; (4) the district court did not abuse its discretion in showing the jury an abbreviated version of a law enforcement officer's bodycam video; and (5) the evidence was sufficient to support the convictions. View "State v. Tucker" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of first-degree murder for killing his mother, holding that the district court did not err in admitting testimony from a probation officer and the mother's friend as statements of the mother's then-existing mental state under Iowa R. Evid. 5.803(3).Defendant's mother sent an email to Defendant's probation officer hours before Defendant killed her stating that she was "scared" and that she needed "help." During trial, Defendant's defense to the first-degree murder charge was that he acted impulsively out of rage. Over Defendant's objection, the trial court allowed the probation officer and the mother's friend to testify about the mother's fear of Defendant and her plan to stop financially supporting him. The Supreme Court affirmed, holding that the district court correctly admitted the two individuals to testify under Rule 5.803(3) about previous statements the mother made because they constituted relevant hearsay statements. View "State v. Thompson" on Justia Law

The Supreme Court affirmed in part and vacated in part the decision of the court of appeals in this postconviction proceeding declining to reverse Appellant's second-degree murder conviction but ordering the return of a previously-forfeited $50,000 cash bond, holding that postconviction relief was not a proper way to overturn the forfeiture order.To obtain pretrial release, Defendant had to post a $200,000 cash bond with $50,000 subject to the condition that it would be forfeited for purposes of restitution if Defendant were convicted. Defendant was subsequently found guilty of second-degree murder. The district court denied Defendant's later-filed application for postconviction relief. The court of appeals reversed as to the bond forfeiture order, ruling that Defendant's counsel provided ineffective assistance in failing to challenge the order. The Supreme Court affirmed except as to the bond forfeiture issue, holding that postconviction relief was not available to set aside the order directing that Defendant's cash bond be forfeited for victim restitution. View "Farnsworth v. State" on Justia Law

The Supreme Court reversed the order of the district court granting Defendant's motion to suppress his breath test because no interpreter was available and the advisory was read to him in English, holding that the police officer discharged his duty by making all reasonable efforts to obtain a Tigrinya interpreter before reading the advisory to Defendant in English.Defendant was from Eritrea, and his primary language was Tigrinya. Defendant, who was pulled over for traffic violations, agreed to do a preliminary breath test, which came back over the legal limit. He was then arrested and transported to a law enforcement center. The arresting officer contacted a commercial service known as Language Line to obtain an on-demand Tigrinya interpreter for the implied consent advisory, but not such interpreter was available. The officer then read Defendant the advisory. Defendant was subsequently charged with operating while intoxicated second offense. Defendant moved to suppress the evidence of his blood alcohol content from the DataMaster test on the grounds that he did not give consent. The district court sustained the motion. The Supreme Court reversed, holding that the officer complied with Iowa Code 321J.8 by making reasonable efforts and using reasonable methods to convey to Defendant the implied consent advisory. View "State v. Baraki" on Justia Law