Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress, holding that observations of a driver holding a phone in front of his face and actively manipulating the screen for at least ten seconds justified stopping the driver to resolve any ambiguity about whether the driver was violating Iowa Code 321.276.Section 321.276 allows drivers to use cell phones for some limited purposes while prohibiting most others. Defendant was stopped when officers believed he might be violating the statute. In his motion to suppress, Defendant argued that the officers lacked reasonable suspicion that Defendant was committing a traffic violation. The district court denied the motion. The Supreme Court affirmed, holding that the officers had reasonable suspicion Defendant was violating section 321.276 to support an investigatory stop. View "State v. Struve" on Justia Law

The Supreme Court affirmed Defendant's convictions for attempting to obtain a prescription drug by deceit, as a habitual offender, and conspiracy to commit a nonforcible felony, holding that Defendant's constitutional challenge to Iowa Code 814.6A was unavailing.Specifically, the Supreme Court held (1) the district court did not abuse its broad discretion in admitting, over Defendant's objections, evidence regarding Defendant's residential address, which was offered to prove Defendant's knowledge, motive, and intent; and (2) section 814.6A, a newly-enacted law that prohibits a represented defendant from filing pro se documents, does not violate the constitutional separation-of-powers doctrine. The Court then denied Defendant's motion to accept his pro se supplemental brief. View "State v. Thompson" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for operating while intoxicated first offense, holding that a peace officer does not violate a duty under Iowa Code 321J.11(2) by agreeing to a detainee's request for a retest on the machine that has already tested the detainee's blood alcohol level without also informing the detainee of the statutory right to an independent test at the detainee's expense.Specifically, the Supreme Court held (1) an officer must inform the detainee of the right to an independent test only in circumstances when the detainee has reasonably asked about that right or when a failure to disclose that right could be misleading; and (2) because neither of those circumstances were present in this case, the district court did not err in denying Defendant's motion to suppress. View "State v. Casper" on Justia Law

The Supreme Court affirmed Defendant's convictions and sentences for eluding while speeding and several unrelated offenses, holding that trial counsel was not ineffective for failing to challenge Defendant's eluding charge on double jeopardy grounds based on his guilty plea to speeding in the same incident.At age seventeen, Defendant pled guilty to a speeding citation without pleading guilty to the accompanying charge of eluding. When Defendant turned eighteen, the State charged him by trial information with eluding while speeding. Defendant pled guilty to the eluding charge. The court of appeals affirmed. The Supreme Court affirmed, holding (1) speeding is a lesser included offense that at trial would merge into a conviction for eluding while speeding, but under the circumstances of this case, Defendant cannot use double jeopardy principles as a sword to defeat his conviction for eluding; and (2) therefore, Defendant's ineffective assistance of counsel claims fail. View "State v. Roby" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court reversing the decision of the Iowa Department of Human Services (DHS) that a child-care provider must pay back benefits the provider received during agency review of her cancelled provider agreement, holding that DHS erred in refusing to consider the provider's unjust enrichment defense to the recoupment proceeding.At issue was whether the provider was given constitutionally sufficient notice of DHS's intent to recoup payments. DHS sent the provider a notice cancelling the provider agreement and noted that any benefits the provider got while her appeal was being decided "may have to be paid back if the Department's action is correct." DHS affirmed its decision to cancel the provider's agreement but did not find, until years later, that the provider had to pay back the $16,000. The district court reversed DHS's decision on recoupment and denied attorney fees under Iowa Code 625.29(1)(b). The Supreme Court reversed in part, holding (1) DHS's notice met procedural due process requirements, but the DHS should have been allowed an opportunity to raise unjust enrichment as an offset to DHS's effort to recoup overpayments; and (2) where DHS's role was primarily adjudicative, DHS was not liable for attorney fees. View "Endress v. Iowa Department of Human Services" on Justia Law

The Supreme Court affirmed in part and vacated in part the court of appeals' decision and affirmed in part and reversed in part the judgment of the district court, holding that a child-care provider whose provider agreement and registration was cancelled should be allowed to raise unjust enrichment as an offset to the Iowa Department of Human Services' (DHS) effort to recoup $31,815 for child-care services the provider rendered during agency review.This appeal was a companion case to Endress v. Iowa Department of Human Services, __ N.W.2d __ (Iowa 2020), also decided today. DHS attempted to recoup child-care service payments during agency review of the provider's cancelled provider agreement and registration. On appeal, the court of appeals held that DHS's notice concerning recoupment of overpayments was constitutionally deficient. The Supreme Court (1) vacated the court of appeals' decision on the constitutional issue, holding that DHS's notice of recoupment met procedural due process requirements; and (2) remanded the case to the district court to remand to DHS for consideration of the provider's equitable relief, holding that the provider should have been allowed to pursue her claim for unjust enrichment. View "Pfaltzgraff v. Iowa Department of Human Services" on Justia Law

The Supreme Court affirmed Defendant's conviction for assault on a peace officer with a dangerous weapon, a felony, and several misdemeanors, holding that Defendant did not receive ineffective assistance of counsel.After Defendant pleaded guilty, he absconded. He was later returned to custody. On appeal, Defendant argued that he received ineffective assistance of counsel because the plea bargain contained an unlawful term. Specifically, Defendant argued that the plea bargain's provision that he would be released from jail for a forty-eight-hour furlough after pleading guilty was illegal and that his trial counsel committed ineffective assistance in obtaining the illegal benefit for him. The Supreme Court affirmed, holding that where Defendant entered into the plea agreement with the illegally lenient sentence, he could not benefit from that sentence and then attack the plea bargain. View "State v. Gordon" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder after declining Defendant's invitation to change constitutional precedent to further limit the admissibility of eyewitness identifications following police photo arrays, holding that the double-blind procedures used in this case were not unduly suggestive and that Defendant received effective assistance of counsel.On appeal, Defendant argued (1) because the police used unduly suggestive photographic identification procedures the district court erred by failing to grant his motion to suppress the resulting identification; and (2) trial counsel was ineffective for failing to request jury instructions on eyewitness identifications that reflect modern scientific research. The court of appeals affirmed the conviction while preserving for possible postconviction relief action Defendant's ineffective assistance of counsel claim. The Supreme Court affirmed in part and vacated in part the court of appeals' decision, holding (1) the eyewitness identification was not unduly suggestive; and (2) contrary to the decision of the court of appeals, the record was adequate to decide the ineffective assistance of counsel claim challenging the jury instruction on eyewitness identification, and this claim is rejected on the merits. View "State v. Booth-Harris" on Justia Law

The Supreme Court vacated in part and affirmed in part the decision of the court of appeals declining relief on Defendant's claims that his trial counsel provided ineffective assistance for failing to object to the crime victim's first-time, in-court identification of Defendant, holding that Defendant's trial counsel did not provide constitutionally deficient representation for failing to object to the victim's trial testimony.The court of appeals affirmed Defendant's conviction, concluding that the record was inadequate to decide Defendant's ineffective-assistance-of-counsel claims but preserved those claims for post conviction proceedings. The Supreme Court vacated the judgment in part, holding (1) the record was adequate to decide Defendant's ineffective-assistance-of-counsel claim, but the claim is rejected because precedent permits first-time, in-court identifications; and (2) the court of appeals decision stands on the remaining issues. View "State v. Doolin" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder in the second degree, holding that Defendant's Fifth Amendment rights were invaded when the trial judge instructed the jury that Defendant was required to notify law enforcement of his use of deadly force, but the error was harmless.During trial, Defendant asserted the defense of justification in his shooting of the victim. At issue on appeal was whether the district court abused its discretion by giving a jury instruction incorporating the terms of Iowa Code 704.2B. The instruction included a statement that a person using deadly force is required to notify law enforcement about his use of deadly force. Defendant argued before the Supreme Court that both section 704.2B and the jury instruction incorporating that section violated his Fifth Amendment rights. The Supreme Court affirmed, holding (1) instructing the jury that a homicide defendant is required to notify a law enforcement agency of his use of deadly force violates the defendant's Fifth Amendment rights; but (2) any error in this case was harmless beyond a reasonable doubt. View "State v. Gibbs" on Justia Law