Justia Criminal Law Opinion Summaries

The Supreme Court reversed the ruling of the district court approving a third five-year extension of a no-contact order that was originally entered after a serious incident of domestic violence in 2009, holding that Defendant carried his burden of showing that he no posed a threat to the safety of the victim and that substantial evidence did not support the extension.In 2021, the victim again applied for an extension of the no-contact order. The district court approved the five-year extension of the no-contact order to 2026. The court of appeals affirmed. The Supreme Court vacated the decision of the court of appeals, holding that, under the circumstances, where Defendant had completed therapy and ten years had elapsed since any violation of the no-contact order, there was not substantial evidence to support the extension of the no-contact order from 2021 to 2026. View "State v. Petro" on Justia Law

The Supreme Court dismissed this appeal brought by Defendant after pleading guilty to criminal gang participation, holding that Defendant's failure to file a motion in arrest of judgment to preserve his argument for appeal precluded relief in this direct appeal.Defendant pleaded guilty pursuant to a plea agreement. The court expressly advised Defendant of the requirement to file a motion in arrest of judgment in order to challenge his guilty plea on appeal. Defendant never filed a motion in arrest of judgment but did appeal, arguing that his conviction and guilty plea should be vacated because his plea lacked a factual basis. The Supreme Court dismissed the appeal, holding that this court lacked jurisdiction to hear Defendant's appeal. View "State v. Hanes" on Justia Law

The Supreme Court upheld Defendant's convictions and sentences for several drug offenses and other misdemeanors, holding that the trial court did not err in denying Defendant's motion to suppress or in denying Defendant's retained attorney's requests to enter limited appearances.On appeal, Defendant argued, among other things, that the district court erred in denying his motion to suppress because the arresting officer's recollection that Defendant had a driving status of "barred" as of several months before did not amount to a reasonable suspicion to justify a traffic stop. The Supreme Court affirmed, holding (1) while the officer's information about Defendant's driver's license status was several months old, it gave the officer reasonable suspicion to justify stopping Defendant's vehicle; and (2) if a constitutional right to have a retained attorney enter a limited appearance exists, it is subject to reasonable regulation by the district court, and the district court in this case did not abuse its discretion in denying Defendant's requested limited appearances. View "State v. Sallis" on Justia Law

In this criminal case, the Supreme Court dismissed Appellant's appeal for lack of jurisdiction, holding that Appellant's pro se notice of appeal filed while he was represented by counsel was a nullity under Iowa Code 822.3A.The version of section 822.3A that controlled this case prohibits the filing of pro se documents by represented parties and the court's consideration thereof. The legislature subsequently amended the statute to allow pro se notices of appeal by represented litigants. Appellant filed this action for postconviction relief, and the court denied relief on all claims. Appellant's lawyers did not file a timely notice of appeal, and at issue was whether Appellant's pro se notice of appeal was valid. The Supreme Court dismissed the appeal, holding that Defendant was not entitled to a delayed appeal because his pro se notice of appeal was a nullity and his counsel's notice of appeal was untimely. View "Jones v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for domestic abuse assault and other offenses but vacated his sentence, holding that the prosecutor did not satisfy her promise to make a specific sentencing recommendation, entitling Defendant to resentencing before a different judge.Defendant agreed to plead guilty if the prosecutor recommended suspended sentences on all counts. Defendant pleaded guilty. At sentencing, the prosecutor asked the court to adopt the parties' plea agreement but then qualified her request with certain comments during sentencing. The district court declined to impose suspended sentences and instead sentenced Defendant to an indeterminate combined term of imprisonment with a suspended sentence to follow. The Supreme Court vacated the sentence, holding that the prosecutor's comments at sentencing breached her obligation under the plea agreement to recommend suspended sentences. View "State v. Patten" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder arising from events in 1990 after his fourth trial, held almost thirty years after the crime, holding that Defendant was not entitled to relief on any of his claims of error.On appeal, Defendant argued that his conviction must be reversed due to juror misconduct, the improper admission of certain testimony, the erroneous exclusion of hearsay evidence, and a violation of due process. The Supreme Court disagreed and affirmed his conviction, holding that none of Defendant's allegations of error warranted reversal of his convictions. View "State v. Liggins" on Justia Law

The Supreme Court reversed the ruling of the district court finding Iowa Code 815.1(4)(c) to be unconstitutional, holding that the State is not constitutionally required to provide ancillary services to an indigent defendant represented by private counsel if funds available to the counsel can reasonably be expected to cover the services.In 2019, the General Assembly enacted section 815.1, thereby changing the process by which an indigent defendant can obtain state funding for investigation costs when the defendant chooses to be represented by privately-retained counsel. The district court found section 815.1 unconstitutional under the Sixth Amendment, severed section 815.1(4)(c) from the statute, and granted Defendant's request for ancillary services at state expenses. The Supreme Court reversed, holding that the State is constitutionally permitted to consider the funds available to a retained attorney in determining whether it is required to provide state funding for ancillary services. View "Amaya v. State Public Defender" on Justia Law

The Supreme Court affirmed Defendant's convictions for drug- and firearm-related offenses, holding that the district court did not abuse its discretion by granting defense counsel's motion to withdraw and did not err in concluding that Defendant knowingly, voluntarily, and intelligently waived his right to counsel.The district court granted defense counsel's motion to withdraw from representation of Defendant approximately three weeks before Defendant's speedy trial expiration date. Although the district court offered to appoint another attorney to represent Defendant, Defendant demanded that he represent himself with the assistance of standby counsel. After conducting colloquies the district court allowed Defendant to proceed pro se with the assistance of standby counsel. The Supreme Court affirmed Defendant's convictions, holding that the district court (1) did not abuse its discretion by granting defense counsel’s motion to withdraw based on defense counsel’s statements that professional considerations required termination of the representation; and (2) correctly concluded that Defendant knowingly, intelligently, and voluntarily waived his right to counsel after engaging in a thorough colloquy. View "State v. Miller" on Justia Law

Vangen was convicted of criminal mischief in the fourth degree after the prosecution presented alternative theories to the jury—she either used a baseball bat to smash the windows of a car or she drove others to the scene and one of them smashed the windows. She argued that neither was supported by sufficient evidence, but even if one was supported, a 2019 statute requiring the jury’s general verdict to be affirmed as long as one theory was supported violates her constitutional rights (Iowa Code 814.28–prohibiting an appellate court from reversing “a verdict on the basis of a defective or insufficient theory if one or more of the theories presented . . . is sufficient to sustain the verdict on at least one count”). The Iowa Supreme Court affirmed. Both theories presented to the jury were supported by sufficient evidence, so the court declined to address the challenge to Iowa Code section 814.28. View "State of Iowa v. Vangen" on Justia Law

In 2005, Sandoval was convicted of two counts of first-degree murder and two counts of attempted murder. He was sentenced to serve concurrent terms of life imprisonment without the possibility of parole for the murder convictions and 25 years’ imprisonment for the attempted murder convictions. Sandoval unsuccessfully challenged his convictions on direct appeal and in three different applications for postconviction relief.The Iowa Supreme Court affirmed the dismissal of Sandoval’s fourth application for postconviction relief, which the district court held was barred by the three-year statute of limitations of Iowa Code section 822.3. Sandoval argued that because he was only 19 at the time he murdered two people, his mandatory life sentences without the possibility of parole violated the federal and state constitutional prohibitions against “cruel and unusual punishment.” U.S. Const. amend. VIII; Iowa Const. art. I. The court disagreed. Sandoval’s mandatory sentences of lifetime incarceration without the possibility of parole for committing these offenses are not categorically prohibited by either the Federal Constitution or the state constitution. View "Sandoval v. State of Iowa" on Justia Law