Justia Constitutional Law Opinion Summaries

Articles Posted in Iowa Supreme Court
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In this interlocutory appeal, the Supreme Court affirmed the order of the district court prohibiting Defendant from filing any additional pro se supplemental documents in a postconviction relief proceeding, holding that the district court did not err.Under Iowa Code 822.3A, postconviction relief applicants are prohibited from filing "any pro se document, including an application, brief, reply brief, or motion, in any Iowa court." At issue was the constitutionality of the law, which was passed in the spring of 2019 and effective July 1, 2019, to pending postconviction relief proceedings and postconviction relief appeals. Defendant in this case argued that section 822.3A violated his constitutional rights. The Supreme Court rejected the argument, holding that there is no constitutional right to file pro se supplemental documents in postconviction relief proceedings and postconviction appeals. View "Hrbek v. State" on Justia Law

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The Supreme Court reversed the judgment of the district court dismissing the trial information in this case, holding that the State's delay in arresting and formally charging Defendant did not amount to a due process violation.By late 2017, law enforcement had focused on Defendant as the suspected perpetrator of a robbery. However, the police did not file a criminal complaint against Defendant until August 2018 and did not serve an arrest warrant until September 2019. In October 2019, after it was finally filed, the district court dismissed the trial information, concluding that Defendant's due process rights under the Fifth Amendment were violated. The Supreme Court reversed, holding that the State's delay in arresting and charging Defendant did not violate the speedy indictment rule or violate due process where Defendant failed to show actual prejudice. View "State v. Smith" on Justia Law

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The Supreme Court affirmed Defendant's conviction of driving while intoxicated (OWI), holding that defense counsel was not ineffective in declining to seek suppression of certain evidence on the basis that Defendant was subjected to an unconstitutional seizure.An officer observed Defendant illegally park her vehicle and stopped her to enforce the parking violation. Upon smelling marijuana and observing signs of Defendant's intoxication the officer inquired about her intoxication. The officer asked Defendant for her registration and insurance and discovered that her driver's license was revoked. Defendant was convicted of second-offense OWI and driving while license was revoked. The Supreme Court affirmed, holding (1) there was sufficient evidence to support Defendant's OWI conviction; and (2) Defendant's counsel was not ineffective in failing to seek suppression of the evidence because the officer had probable cause to seize Defendant based upon his observation of her traffic violation. View "State v. Warren" on Justia Law

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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

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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

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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

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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

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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

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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

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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