Articles Posted in Iowa Supreme Court

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In this interlocutory review on a discovery dispute, the Supreme Court affirmed the decision of the district court ordering counsel for Defendant to provide notice to the State before serving any subpoenas duces tecum on third parties and finding that there was no statutory or constitutional authority to support Defendant’s position that he had a right to issue ex parte subpoenas duces tecum. Defendant, who was charged with child endangerment, resisted the State’s motion regulate discovery and request that the district court enter an order prohibiting Defendant from issuing ex parte subpoenas duces tecum. The district court granted the State’s motion and issued a protective order stating that Defendant was prohibited from issuing any subpoena except under certain circumstances. The Supreme Court affirmed the district court grant of the motion to regulate discovery, holding (1) the proper procedure for Defendant to use if he seeks to issues an ex parte subpoena duces tecum is to file a motion setting forth the basis for the request; and (2) there is no corresponding constitutional violation under the state or federal Constitutions. View "State v. Russell" on Justia Law

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The district court did not abuse its discretion in commencing a criminal trial on June 26 and then postponing the presentation of evidence to July 7, eight days after the June 29 expiration of the speedy trial deadline due to the unavailability of medical experts. Defendant was charged with attempted murder and other offenses. Jury selection was reset for June 26. Eleven days later, on July 7, the State called four witnesses, including a medical expert. The jury found Defendant guilty of the lesser included offenses of assault with intent to inflict serious injury, criminal trespass, and willful injury causing serious injury. The Supreme Court affirmed Defendant’s convictions and sentence, holding (1) assuming, without deciding, that the court’s use of a start-and-stop procedure to avoid the speedy trial deadline should be analyzed under the same standards as a straightforward extension of the speedy trial deadline, the trial court acted within its discretion; and (2) Defendant’s other issues on appeal were without merit. View "State v. McNeal" on Justia Law

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In this employment discrimination case, prejudicial errors in four jury instructions required a new trial. Plaintiff filed claims against her former employer, alleging sexual harassment and retaliation under the Iowa Civil Rights Act (ICRA). The jury returned a verdict for Plaintiff on both counts and awarded damages in the amount of $1.4 million. Employer then filed a motion for new trial, which the district court denied. The Supreme Court reversed, holding (1) workers may bring a direct-liability negligence claim under the ICRA against an employer for supervisor harassment, but the plaintiff must prove that the employe knew or should have known of the harassment and failed to take prompt and appropriate remedial action to end it; (2) the district court did not abuse its discretion in admitting expert testimony on legal standards; but (3) the district court misinstructed the jury in four jury instructions, necessitating a new trial. View "Haskenhoff v. Homeland Energy Solutions, LLC" on Justia Law

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Iowa Const. art. I, section 17 does not categorically prohibit a district court form sentencing a juvenile offender to a minimum term of incarceration without the possibility of parole, provided that the court only imposes the sentence after a complete and careful consideration of the relevant mitigating factors of youth. Defendant, who was a juvenile at the time of his offense, was resentenced to a minimum term of incarceration of seventeen and one-half years for sexual abuse in the second degree. Defendant appealed, arguing that any minimum term of incarceration without the possibility of parole is unconstitutional. The court of appeals affirmed the sentence. The Supreme Court remanded for resentencing, holding that, while the Iowa Constitution does not require abandonment of the practice at issue, the district court abused its discretion in this case by imposing a sentence of incarceration without parole eligibility. View "State v. Roby" on Justia Law

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Defendant did not have a right to counsel under Iowa Const. art. I, section 10 when he voluntarily participated in a noncustodial police interview under the supervision of an Iowa county attorney even though the State’s criminal investigation was focusing on Defendant as the primary suspect at the time. Defendant was found guilty of murder in the first degree. During trial, the district court instructed the jury that it could infer Defendant acted with malice aforethought from his use of a baseball bat. The jury found Defendant killed the victim without justification and with malice aforethought. The court of appeals affirmed the judgment and sentence. The Supreme Court affirmed, holding (1) the level of prosecutorial involvement at the time of the interview did not create a prosecution or case that would trigger the right to counsel under article I, section 10; and (2) the jury could properly infer malice aforethought from Defendant’s use of a deadly weapon even though Defendant did not bring the weapon to the encounter. View "State v. Green" on Justia Law

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The Supreme Court held that Defendant must be allowed to withdraw his plea of guilty to a criminal offense because Defendant would not have accepted the plea agreement if he had been provided the effective assistance of counsel to which he was constitutionally entitled. Defendant, who entered the United States without examination by the Department of Homeland Security, pleaded guilty to aggravated misdemeanor forgery. Based on this conviction, he was removed from the United States to Mexico. After Defendant returned to the United States he filed for postconviction relief, asserting that he was denied the effective assistance of counsel because counsel did not advise him pleading guilty to an aggravated felony has severe immigration consequences. The district court agreed and vacated Defendant’s conviction. The court of appeals reversed. The Supreme Court vacated the court of appeals, affirmed the district court, and remanded to allow Defendant to withdraw his plea and stand for trial, holding that counsel provided constitutionally deficient performance, and this deficiency resulted in prejudice. View "Diaz v. State" on Justia Law

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The Supreme Court reversed Defendant’s conviction for domestic abuse assault, third offense, and remanded this case for a new trial, holding that Defendant received ineffective assistance of counsel because his trial counsel failed to request a jury instruction defining “household member.” The court thus vacated the decision of the court of appeals, which affirmed the conviction over a dissent. The majority concluded that defense counsel had breached an essential duty by failing to request the definition instruction but that Defendant failed to show prejudice because the State had presented sufficient evidence of cohabitation. The Supreme Court held (1) because the central issue at trial was whether Defendant and the victim had been cohabitating, the jury should have been given the definition instruction, which accurately set forth the factors bearing on that issue; and (2) therefore, defense counsel’s failure to request the instruction was prejudicial, necessitating a new trial. View "State v. Virgil" on Justia Law

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Appellant pled guilty to one count of third-degree sexual abuse as the result of a sex act that occurred involving Appellant, who was seventeen years old, and T.C., who was thirteen years old. On appeal, Appellant argued that his lifetime special sentence of parole and the lifetime requirement that he register as a sex offender violated the cruel and unusual punishment and due process clauses of the United States and Iowa Constitutions. The court of appeals affirmed. The Supreme Court affirmed, holding that Appellant’s lifetime special sentence and lifetime registration requirement were not cruel and unusual punishment because a juvenile offender can petition the Iowa Department of Corrections for discharge from both the special sentence and the registration requirement. View "State v. Graham" on Justia Law

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Deputy Dan Furlong prepared a warrant application to search a residence. The detective brought the application before a judicial officer and, without signing the application, orally swore to the trust of the application in the presence of the judicial officer. The judicial officer approved and signed the warrant. After the warrant was executed Defendants were charged with several drug charges. Defendants moved to suppress the results of the search based on the detective’s failure to sign the warrant application. The district court granted the motions to suppress. The Supreme Court reversed, holding (1) Iowa Code 808.3 permits the warrant applicant to swear to the truth of the warrant application in the presence of the judicial officer even if, inadvertently, the applicant fails to sign it; and (2) in this case, the issuance of the warrant complied with section 808.3. View "State v. Angel" on Justia Law

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Defendant appealed his convictions and sentences following two bench trials, challenging the underlying searches in each of the two cases. Specifically, Defendant argued that the district court erred in denying his motions to suppress firearms and drugs seized by his stepfather, a police officer with the Davenport Police Department, while his stepfather was off duty. Defendant argued that the searches were unconstitutional because his stepfather conducted the searches while exercising state action as a law enforcement official. The district court denied each motion to suppress. After bench trials, Defendant was found guilty of the charges. The Supreme Court affirmed the denial of the motions to suppress, holding that Defendant’s off-duty police officer stepfather was acting in his private capacity, and not in his governmental capacity as a law enforcement officer, when he conducted the searches of Defendant’s person and vehicle. View "State v. Brown" on Justia Law