Justia Constitutional Law Opinion Summaries

Articles Posted in Iowa Supreme Court
by
The Supreme Court of Iowa was asked to consider whether the Iowa Constitution supports a legislative privilege that protects legislators from compelled production of documents related to legislation. The court concluded that the Iowa Constitution does indeed contain a legislative privilege that protects legislators from compelled document production, particularly in relation to communications with third parties about the legislative process. The case arose from subpoenas served on several Iowa legislators by the League of Latin American Citizens of Iowa (LULAC). LULAC sought discovery of communications related to recent legislative changes to voting procedures. The legislators objected to the subpoenas, arguing they were protected from compelled document production by a legislative privilege under the Iowa Constitution. The court ruled that the privilege extends to communications with third parties where the communications relate directly to the legislative process of considering and enacting legislation. However, the court did not decide whether this legislative privilege was absolute or qualified, as it concluded that the requested documents were not relevant to LULAC's claims and were therefore protected by the legislative privilege, regardless of its extent. The court reversed the district court's judgment granting in part LULAC's motion to compel and remanded with instructions to quash the subpoenas. View "Smith v. Iowa District Court for Polk County" on Justia Law

by
In this case heard by the Supreme Court of Iowa, the defendant, Morgan Marie McMickle, was charged with operating a motor vehicle while intoxicated (OWI). McMickle was stopped by law enforcement after rear-ending another vehicle and leaving the scene. The investigating officer obtained a search warrant to collect a blood sample from McMickle for chemical testing, which showed a blood alcohol content over three times the legal limit. Additionally, McMickle repeatedly asked to speak to her lawyer but was denied. She later filed a motion to suppress evidence, arguing that the use of a search warrant instead of the statutory implied consent procedure violated her rights, and that her right to counsel was violated under Iowa Code section 804.20.The district court granted McMickle's motion, determining that the officer's use of a search warrant was not authorized, that the officer had no statutory authority to collect and test bodily specimens, and that the officer's actions violated McMickle's constitutional rights to equal protection and due process. Additionally, the court found that the officer's refusal of McMickle's requests to speak to her lawyer violated her rights under section 804.20. As a result, the court ordered the suppression of McMickle's statements and the results of the blood test.However, the Supreme Court of Iowa reversed the district court's decision. The court held that the statutory implied consent procedure was not the exclusive means by which an officer can investigate suspected OWI offenses, and that a law enforcement officer's decision to obtain and execute a search warrant did not violate a suspect's constitutional rights. The court also ruled that although McMickle's rights under section 804.20 were violated, the blood test results should not have been suppressed because they were obtained through a legally issued search warrant, independent of any violation of section 804.20. The case was remanded back to the lower court. View "State of Iowa v. McMickle" on Justia Law

by
In the state of Iowa, a police officer investigated a suspected case of driving a motor vehicle while intoxicated. The officer pulled over the suspect, Colby Laub, and obtained a search warrant to collect a breath specimen for chemical testing after Laub refused to participate in field sobriety testing. The chemical testing showed that Laub had a blood alcohol content well above the legal limit, and he was subsequently arrested. Laub moved to suppress the evidence of the chemical breath test, as well as statements he had made to the officer, arguing that the officer was required to invoke the statutory implied consent procedure and give him the opportunity to refuse to provide a sample, rather than proceed with a search warrant. The district court agreed with Laub and granted his motion on the grounds that the officer had no statutory authority to obtain a search warrant to collect and test bodily specimens, and that doing so violated Laub's constitutional rights to equal protection and due process. The state appealed this decision.The Supreme Court of Iowa reversed the district court's decision. The court found that the district court erred in holding that the statutory implied consent procedure is the only way a law enforcement officer can obtain a bodily specimen and conduct chemical testing in investigating an OWI case. The court noted that the officer's decision to obtain a search warrant instead of invoking the statutory implied consent procedure did not violate the defendant's rights to equal protection or due process. The court also disagreed with the district court's interpretation of the statute, stating that the statutory implied consent law is not the exclusive means by which a law enforcement officer can obtain a breath sample in an OWI case. Therefore, the court reversed the district court's suppression ruling and remanded the case for further proceedings. View "State of Iowa v. Laub" on Justia Law

by
The Supreme Court of Iowa ruled that the State University of Iowa, Iowa State University of Science and Technology, and the University of Northern Iowa were required to be members of the Iowa Individual Health Benefit Reinsurance Association (IIHBRA) and therefore had to pay assessments to the association. The universities had argued that they were not members of IIHBRA and that the statute requiring them to pay assessments violated the Iowa Constitution, which prohibits the state from acting as a surety for another. The court rejected these arguments, finding that the statutory scheme did not violate the constitution and that the universities, as providers of health benefit plans, were indeed members of IIHBRA. The court also ruled that IIHBRA was statutorily authorized to impose late payment fees against its members. However, the court denied IIHBRA's request for attorney fees and costs. The court affirmed in part, reversed in part, and remanded the case for further proceedings. View "Iowa Individual Health Benefit Reinsurance Ass’n v. State University of Iowa" on Justia Law

by
In this case from the Supreme Court of Iowa, the defendant, Stephen Arrieta, a truck driver, was pulled over at a weigh station after his vehicle failed a "PrePass" check. During the stop, an Iowa Department of Transportation officer requested a K-9 unit to conduct a free air sniff of the truck and trailer. The drug dog alerted to the presence of drugs in the sleeper compartment of the cab, and Arrieta admitted to having marijuana inside. Arrieta was subsequently charged with possession of a controlled substance.Arrieta appealed the denial of his motion to suppress the marijuana. His main argument was that the officer unlawfully extended the time of his stop, known as a Level 3 inspection, to allow the K-9 handler to arrive and search his truck. Arrieta cited Rodriguez v. United States, a Supreme Court case that ruled such extensions of traffic stops without reasonable suspicion of criminal activity are unconstitutional.The Supreme Court of Iowa agreed with Arrieta, finding that he was detained longer than necessary to complete the Level 3 inspection, in violation of the Fourth Amendment. The court concluded that the officer had effectively completed his tasks before the arrival of the K-9 unit and that the 25-minute delay until the K-9 unit's arrival was unjustified. As such, Arrieta was improperly detained when the free air sniff occurred, and any evidence obtained as a result of the search should have been suppressed.The court vacated the decision of the Court of Appeals and reversed and remanded the judgment of the district court. View "State of Iowa v. Arrieta" on Justia Law

by
The Supreme Court affirmed Defendant's conviction for operating while intoxicated (OWI) and eluding, holding that the district court did not abuse its discretion in admitting evidence about a preliminary breath test (PBT) and that the evidence was sufficient to support the convictions.During the underlying jury trial, the district court admitted a portion of an officer body cam video showing Defendant agreeing to a PBT, after which the edited video jumped to Defendant's arrest for OWI. The Supreme Court held (1) this juxtaposition of the PBT and arrest violated Iowa R. Evid. 5.403 because it had minimal probative value while strongly implying that Defendant had failed the PBT, but the error was harmless; and (2) there was sufficient evidence to sustain Defendant's eluding conviction. View "State v. Amisi" on Justia Law

by
The Supreme Court held that the district court and court of appeals did not err in finding that Defendant was not seized before the law enforcement officer who eventually arrested him discovered his probable intoxication and that Defendant was lawfully detained on grounds of probable intoxication.In his motion to suppress, Defendant argued that he had been seized when the officers partially blocked him in while he was parked in a parking lot, trained a spotlight on him, and shined flashlights into his car from both sides. The trial court concluded that Defendant had not been "seized" before the police discovered his intoxication. The court of appeals affirmed, concluding that the officers' actions were not "sufficiently coercive" to constitute a seizure. The Supreme Court affirmed, holding that Defendant was lawfully detained because the officers did not seize him before his intoxication was observed. View "State v. Wittenberg" on Justia Law

by
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

by
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

by
The Supreme Court affirmed the judgment of the district court ordering Respondent's continued hospitalization following his court-ordered psychiatric treatment, holding that respondents in proceedings brought under Iowa Code chapter 229 do not have a federal constitutional right to represent themselves and forego the legal representation required by the statute.Respondent, who had a history of self-harm, suicide threats, and refusal to take his medications, was ordered to be involuntarily hospitalized under chapter 229. A series of subsequent court orders left Respondent's commitment in place for the next two years. Thereafter, Respondent moved to terminate his commitment and asked to proceed pro se. The district court denied Respondent's motion to proceed pro se and ordered his continued hospitalization. The Supreme Court affirmed, holding (1) the Sixth Amendment right to counsel and right to self-representation in criminal cases do not apply to Chapter 229 proceedings; and (2) the district court's factual findings were supported by substantial evidence and binding on appeal. View "In re V.H." on Justia Law