Articles Posted in Iowa Supreme Court

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In this appeal, Appellant, who at age thirteen shot and killed his mother, raised challenges to Iowa’s youthful offender laws. Specifically, he argued (1) Iowa Code 232.45(7)(a) does not provide statutory authority to try a thirteen-year-old as a youthful offender, (2) Iowa Code 232.45(7) and Iowa Code 907.3A constitute unconstitutional cruel and unusual punishment, and (3) the sentencing court abused its discretion by incarcerating him. The Supreme Court affirmed Appellant’s conviction as a youthful offender and his fifty-year indeterminate sentence with immediate parole eligibility, holding that the district court did not abuse its discretion in sentencing Appellant to a prison term rather than releasing him on probation or placing him in a transitional facility based on an individualized assessment of Defendant under a constitutional statutory scheme. View "State v. Crooks" on Justia Law

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After Defendant’s initial sentence was voided for illegality, the district court resentenced Defendant to a new term of imprisonment. The district court originally suspended Defendant’s prison sentence and instead ordered a five-year term of probation. Upon resentencing, the court refused to credit the time Defendant spent on probation pursuant to the initial sentence against the new term of imprisonment. The Supreme Court held that the failure to award credit for the time spent on probation violated Defendant’s constitutional right to be free from double jeopardy under the Fifth Amendment. The court held that all time Defendant spent on probation pursuant to the voided sentence must be fully credited against a corrected sentence of incarceration because, when an initial sentence is voided for illegality, any punishments already endured must be credited against the corrected sentence. The dissent disagreed, arguing that probation should not be equated with punishment in the same way incarceration is considered for double jeopardy purposes. View "State v. Jepsen" on Justia Law

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The Supreme Court affirmed Defendant’s conviction for failure to comply with the sex offender registry but vacated the district court sentence, which included sentencing enhancements, and remanded for further sentencing proceedings. The court held (1) despite the legislature’s ambiguous language in Iowa Code 692A.105, the legislature intended for registered sex offenders to provide notification of a change to temporary lodgings within five business days of that change; (2) the evidence was sufficient to show Defendant failed to comply with section 692A.105; (3) the district court properly instructed the jury regarding the applicable law; (4) any alleged prosecutorial misconduct did not prejudice Defendant; (5) Defendant’s stipulations to the sentencing enhancements were meaningless without a factual basis establishing whether he was represented by counsel for his prior convictions, and therefore, the case should be remanded to establish a factual basis on this sentencing issue; and (6) Defendant’s remaining claims of ineffective assistance of counsel failed. View "State v. Coleman" on Justia Law

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The Supreme Court reversed Defendant’s conviction for indecent exposure due to ineffective assistance of counsel and vacated the portion of the district court’s sentence imposing a surcharge for Defendant’s stalking conviction and remanded for the entry of a corrected sentence. Defendant was convicted of indecent exposure and stalking. As relevant to this appeal, the trial court imposed a $100 surcharge on Defendant’s stalking conviction under Iowa Code 911.2B. The Supreme Court reversed the judgment in part and vacated the sentence in part, holding (1) Defendant’s counsel was ineffective as a matter of law by failing to challenge, in a motion for judgment of acquittal, the sufficiency of the evidence of indecent exposure; and (2) the imposition of the second 911.2B surcharge violated the Ex Post Facto Clause. View "State v. Lopez" on Justia Law

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Law enforcement officers executing a search warrant violated Defendant’s rights under Iowa Const. art. I, 8 by searching her purse while she was a visitor present at the premises to be searched but where the search warrant made no motion of her. Prior to trial, Defendant filed a motion to suppress, which the district court denied. Defendant was subsequently found guilty of possessing marijuana. The Supreme Court reversed the district court’s ruling on the motion to suppress and remanded the case to the district court, holding (1) a search of the possessions of a third party at a residence is unconstitutional when the warrant does not support probable cause to search that particular person; and (2) under this court’s applicable caselaw, the search of Defendant’s purse could not be supported based on any of the State’s theories independent of the search warrant. View "State v. Brown" on Justia Law

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Defendant Jason Weitzel appealed the judgment and sentences entered on his guilty pleas to domestic abuse assault, possession of methamphetamine, carrying weapons, and operating while intoxicated. Defendant challenged the adequacy of his guilty plea colloquy, arguing the district court did not advise him about the statutory thirty-five percent criminal penalty surcharges, and this failure invalidated his guilty pleas. The court of appeals held the district court did not substantially comply with Iowa Rule of Criminal Procedure 2.8(2)(b)(2) during the guilty plea colloquy because it omitted information regarding the surcharges, and reversed. The State sought certiorari review, and the Iowa Supreme Court concurred with the appellate court that the district court did not substantially comply with rule 2.8(2)(b)(2) because it failed to inform the defendant about the mandatory thirty-five percent criminal penalty surcharges. Because of the district court’s noncompliance, defendant was entitled to withdraw his pleas. The case was remanded back to the district court for further proceedings. View "Iowa v. Weitzel" on Justia Law

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West Central Cooperative was an agricultural cooperative owned by farmers. Westco Agronomy Co., L.L.C. was a wholly-owned subsidiary of West Central formed in 2005 for the purpose of streamlining delivery of agronomy products, including seed, fertilizer, and chemicals. In 2002, Westco hired Chad Hartzler to work in the agronomy division selling seed and eventually chemicals. He was later promoted to sales director but retained oversight of some of Westco’s largest accounts, including the Wollesens. A dispute arose over the relationships of these parties, resulting in a three-week jury trial and a substantial damages verdict in favor of the customer and against the cooperative. The Iowa Supreme Court limited its consideration of the case to three matters raised in the cooperative’s application for further review: (1) the district court properly denied the cooperative’s motion for new trial based on inconsistent verdicts; (2) the district court did not abuse its discretion in denying the cooperative’s pretrial motion to have equitable issues tried first; and (3), with respect to the constitutionality of Iowa Code section 706A.2(5) (2011), the statute unconstitutionally shifts the burden to the defendant. Specifically, any person who provides property or services that end up being used to facilitate “specified unlawful activity” must prove his or her own lack of negligence to avoid liability. However, the Supreme Court found the burden-shifting provision contained in section 706A.2(5)(b)(4) could be severed from the rest of the statute. Accordingly, while the Court otherwise affirmed the district court, it reversed the district court’s dismissal of this claim. View "Westco Agronomy Company, LLC v. Wollesen" on Justia Law

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The Supreme Court reversed the judgment of the district court dismissing Appellant’s amended application for postconviction relief. In his application for postconviction relief, Appellant alleged that, pursuant to Iowa Code 822.2(1)(a), his sentence violated several of his civil rights under the United States and Iowa Constitutions. Specifically, Appellant asserted that the Iowa Department of Corrections (IDOC) violated his liberty interest in obtaining parole by failing to provide the sex offender treatment program (SOTP) in a timely manner. The district court found, as a matter of law, that Appellant had not stated a claim for postconviction relief under section 822.2(1)(a). The Supreme Court remanded the case, holding that Appellant should be given an opportunity to amend his application to seek relief under Iowa Code 822.2(1)(e). View "Belk v. State" on Justia Law

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The claims brought by the City of Eagle Grove alleging two properties owned by Cahalan Investments, LLC were abandoned and in an advanced state if disrepair and praying for a transfer of ownership from Cahalan to the City under Iowa Code 657A.10A fit within the public-nuisance exception recognized in Lucas v. South Carolina Coastal Council, 505 U.S. 1003 (Iowa 1992), and did not result in a taking requiring compensation to Cahalan. The district court dismissed the City’s petitions seeking ownership of the properties at issue in this case, concluding that the transfer of ownership without just compensation to Cahalan would constitute an unconstitutional taking. The Supreme Court reversed, holding that transfer of title to the two properties under section 657A.10A would not constitute a taking under the circumstances presented in this case, and therefore, there was no constitutional requirement of just compensation. View "City of Eagle Grove, Iowa v. Cahalan Investments, LLC" on Justia Law

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The Supreme Court reversed the judgment of the district court denying Defendant’s motion to suppress evidence obtained after an officer stopped his vehicle for being on a county access road after hours. The district court determined that Defendant violated Iowa Code 350.5 by entering the county access area after hours, regardless of whether there was a sign posted to identify the county access area or the park hours. The Supreme Court disagreed, holding (1) the officer did not have probable cause or reasonable suspicion to stop Defendant’s vehicle when it was on the county access road after hours because, without a proper posting of the closing time, the officer did not have probable cause or reasonable suspicion to stop Defendant; and (2) therefore, the district court should have suppressed any drug evidence found in Defendant’s vehicle. View "State v. Scheffert" on Justia Law