Justia Constitutional Law Opinion Summaries

The Supreme Court vacated Defendant's sentence in connection with her Alford plea to four counts of child endangerment entered pursuant to a plea agreement, holding that the State breached the plea agreement with Defendant and that Defendant's original counsel was ineffective for failing to object. On appeal, Defendant argued that, pursuant to the plea agreement between the parties, the State was obligated to jointly recommend a deferred judgment. Instead, at the sentencing hearing, the State recommended, and the court imposed, a two-year suspended prison sentence without objection from defense counsel. The court of appeals affirmed Defendant's conviction and sentence. Thereafter, amendments to Iowa Code 814.6 and 814.7, enacted in Senate File 589, were signed into law and became effective. The State argued before the Supreme Court that Senate File 589 foreclosed relief in this appeal. The Supreme Court held (1) sections 814.6 and 814.7, as amended, do not apply to a direct appeal from a judgment and sentence entered before July 1, 2019; and (2) the State breached the plea agreement and Defendant's counsel was ineffective. The Supreme Court remanded the case for the State's specific performance of the plea agreement and resentencing by a different judge. View "State v. Macke" on Justia Law

In this civil action filed against the police investigator, the prosecutors, and the municipalities that investigated and prosecuted a criminal case in which Plaintiff was eventually acquitted the Supreme Court affirmed in part and reversed in part the judgment of the district court denying Defendants' motions to dismiss, holding that the district court erred in concluding that Baldwin v. City of Estherville, 951 N.W.2d 259 (Iowa 2018), displaced the judicial process immunity. Specifically, the Court held (1) the district court erred in part in denying the prosecutor defendants' motion to dismiss because the judicial process immunity barred all claims in the petition against the prosecutors and the county except for a claim relating to an ethics complaint; and (2) the district court correctly denied the motion to dismiss with respect to the police defendants' argument regarding the judicial process immunity but erred in denying the police defendants' motion to dismiss Plaintiff's defamation claim. View "Venckus v. City of Iowa City" on Justia Law

The Supreme Court affirmed the judgment of the district court ruling in favor of the Iowa Parole Board (Board) as to Petitioner's action challenging the manner in which the Board considers whether persons convicted of offenses while a juvenile should be granted parole, holding that the district court did not err. Petitioner was sixteen years old when he committed the crime of kidnapping. In his petition for judicial review brought pursuant to the Iowa Code 17A.19, Petitioner sought a declaratory judgment that a variety of substantive and procedural rights are required when a juvenile offender is considered for parole. The district court denied the Board's motion to dismiss and then proceeded to rule in favor of the Board on the merits. The Supreme Court affirmed, holding (1) dismissal was not appropriate without analyzing the merits of the underlying constitutional claims; (2) the statute and rules governing the parole process can be applied in a constitutional manner through the required Graham-Miller lens; (3) a juvenile offender has a liberty interest in the proper application of Graham-Miller principles under the Due Process Clause; and (4) Petitioner failed to establish any constitutional violations. View "Bonilla v. Iowa Board of Parole" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence discovered by law enforcement after a stop of Defendant's automobile that resulted in her arrest for driving while barred, holding that the district court did not err in denying Defendant's motion to suppress. Specifically, the Court held (1) Defendant was not subject to an impermissible pretextual seizure because the subjective motivations of an individual officer in making a traffic stop are irrelevant as long as the officer has objectively reasonable cause to believe the motorist violated a traffic law; (2) Defendant's stop was supported by reasonable suspicion; and (3) Defendant's claim that her trial court provided ineffective assistance for declining to challenge whether the vehicle's license plate was malfunctioning failed on the merits. View "State v. Haas" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress all evidence obtained after a stop of his vehicle, holding that the subjective motivations of an individual officer for making a traffic stop are irrelevant as long as the officer has objectively reasonable cause to believe the motorist violated a traffic law. A police officer observed Defendant making an improper turn and, after following Defendant, noticed Defendant's vehicle had an improperly functioning license plate light. The vehicle information for the registered owner - who was not Defendant - revealed the registered owner's affiliation to gang activity. The officer pulled Defendant over and discovered Defendant's open beer container in the center cupholder. Defendant filed a motion to suppress, arguing that the stop was unconstitutional because the officer's reasons for the stop were not the traffic violations themselves. The Supreme Court affirmed, holding that traffic stops for traffic violations are reasonable regardless of the officer's subjective motivation. View "State v. Brown" on Justia Law

The Supreme Court answered questions certified to it by the United States District Court for the Northern District of Iowa, holding, among other things, that a municipality can assert qualified immunity to a claim for damages for violation of the Iowa Constitution based on its officers' exercise of "all due care." Specifically, the Supreme Court held (1) the due care exemption under Iowa Code 670.4(1)(c) could provide the City immunity; (2) section 670.4(1)(e) precludes an award of punitive damages against the municipality that employed the constitutional tortfeasor; (3) in a Godfrey v. State, 898 N.W.2d (Iowa 2017), action a court cannot award attorney fees against the municipal employer of the constitutional tortfeasor unless there is a statute expressly allowing such an award; and (4) it is appropriate to retroactively apply this Court's conclusion that in a Godfrey action, common law attorney fees may be available against the municipal employer of the constitutional tortfeasor. View "Baldwin v. City of Estherville, Iowa" on Justia Law

The Supreme Court reversed the judgment of the district court summary judgment for the State on Appellant's application for postconviction relief (PCR) after denying Appellant's request to appoint an expert, holding that the district court abused its discretion in denying the expert and that the summary disposition was erroneous. After a jury trial, Appellant was found guilty of first-degree murder. Appellant was sentenced to life imprisonment. In her petition for postconviction relief Appellant asserted, among other claims, that her trial counsel was ineffective for failing to raise battered woman syndrome (BWS) in her trial and for not adducing BWS evidence. To prove her claim, Appellant sought a court-appointed BWS expert. The district court denied Appellant's request to appoint an expert and, simultaneously, cited Appellant's failure to provide an expert in granting summary judgment. The Supreme Court reversed, holding that the summary disposition was erroneous where the court, among other errors, concluded that the record did not show facts to support Appellant's claim that BWS should have been raised at her trial. View "Linn v. State" on Justia Law

The Supreme Court vacated the decision of the court of appeals reversing Defendant's conviction of second-degree murder, holding that Defendant was not entitled to a new trial on any of his allegations of error. After trial, Defendant filed a motion for a new trial alleging, among other things, that the trial court erred in refusing to disqualify a juror who allegedly made out-of-court statements regarding Defendant's guilt and misconduct and bias related to extraneous information reaching the jury about a possible riot if a certain verdict was not returned. The district court denied the motions for a new trial and entered judgment. The court of appeals reversed, concluding that juror misconduct and bias warranted a new trial. The Supreme Court vacated the decision of the court of appeals and affirmed the district court judgment, holding that Defendant was not entitled to a new trial under the facts of this case. View "State v. Christensen" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming in part and reversed in part the judgment and sentence of the district court convicting Defendant of operating while intoxicated (OWI) second offense, holding that the clause of the OWI statutes that makes it unlawful for a person to operate a motor vehicle with any amount of a controlled substance in his or her person does not violate the Due Process Clause of either the United States or Iowa Constitution as applied to the facts of this case. The court of appeals found Iowa Code 321J.2(a)(c), which makes it unlawful for a person to operate a motor vehicle "[w]hile any amount of a controlled substance is present in the person," does not violate due process guarantees but reversed the judgment and sentence after concluding that the district court failed to engage in a proper colloquy before accepting a stipulation relating to the prior conviction for OWI. The Supreme Court only addressed the due process claim and affirmed the court of appeals as to the remaining issues, holding that section 321J.2(1)(c) does not violate the requirements of due process under the federal or state Constitutions as applied to this case. View "State v. Newton" on Justia Law

The Supreme Court conditionally affirmed Defendant's conviction and sentence for first-degree murder but remanded for further proceedings consistent with decisions it also filed today in State v. Lilly, __ N.W.2d __ (Iowa 2019), and State v. Veal, __ N.W.2d __ (Iowa 2019), and this opinion, holding that further consideration of Defendant's claim that his jury was not drawn from a fair cross section of the community, in violation of the Sixth Amendment to the United States Constitution and article I, section 10 of the Iowa Constitution, was warranted. Defendant, an African-American, was charged with first-degree murder in a county that was approximately 2.3 percent African-American in population. The jury pool of unexcused jurors, however, contained only one African-American. The Supreme Court held (1) as in Lilly and Veal, the appropriate course of action is to remand the case to offer Defendant a further opportunity to develop his arguments that his Sixth Amendment right to an impartial jury was violated; and (2) Defendant's remaining claims of error did not warrant a new trial. View "State v. Williams" on Justia Law