Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was convicted of first-degree murder. The trial court instructed the jury on both the premeditation and felony-murder alternatives of first-degree murder, with the underlying predicate felony being terrorism. In 2006, the Supreme Court decided State v. Heemstra, which was not given retroactive effect. If Heemstra had been controlling at the time of Defendant’s conviction, terrorism could not have been used as the predicate felony and the felony-murder instruction could not have been given as a theory to convict Defendant. Defendant later filed this second application for postconviction relief, arguing that his conviction should be vacated and a new trial ordered because the nonretroactive application of Heemstra violates constitutional due process, separation of powers, and equal protection guarantees. Defendant also argued for the first time on appeal that his postconviction counsel were ineffective. The Supreme Court affirmed, holding (1) the nonretroactivity of the rule set forth in Heemstra does not violate the due process, separation of powers, or equal protection clauses of the Iowa Constitution or the equal protection clause of the United States Constitution; and (2) Defendant’s postconviction counsel provided effective assistance. View "Nguyen v. State" on Justia Law

Defendant was approached by law enforcement officers while walking on the side of the road at 1:10 a.m. The officers asked Defendant if he would consent to a search of his person, and Defendant consented to a search. Defendant was subsequently charged with possessing methamphetamine. Defendant moved to suppress the evidence, arguing that the warrantless search violated the Federal and State Constitutions. The district court denied the motion, concluding that Defendant voluntarily consented to the search. On appeal, Defendant argued that the search violated Iowa Const. art. I, section 8, which requires police to “advise an individual of his or her right to decline to consent to a search.” The Supreme Court affirmed, holding (1) Defendant’s article I, section 8 argument was not preserved for appellate review; and (2) because the totality of the circumstances indicated that Defendant voluntarily consented to the search, the search was valid under the Fourth Amendment. View "State v. Prusha" on Justia Law

Plaintiff, who was employed as an engineer and paramedic for the City of Clinton fire department, requested light-duty assignments when she became pregnant. The fire chief denied Plaintiff’s request, determining that she was not entitled to light duty under the city administrative policy because she did not have a disabling injury that occurred on the job. When Plaintiff’s pregnancy had advanced, she took a leave of absence by using accrued vacation and sick leave time. Once she exhausted the vacation and sick leave, her leave of absence was unpaid. After Plaintiff gave birth, she brought a lawsuit against the City of Clinton and three of its employees, alleging pregnancy discrimination under Iowa Code 216.6(2) and violations of her equal protection and due process rights under the Iowa Constitution. The district court granted summary judgment in favor of Defendants. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) the Court’s test for the evaluation of pregnancy discrimination claims is hereby adapted in this opinion; and (2) the material facts of this case do not support equal protection and due process claims under the Iowa Constitution. Remanded for consideration of the statutory civil rights claim under the new standard. View "McQuistion v. City of Clinton" on Justia Law

Appellant was a passenger in an out-of-state vehicle that had been pulled over for traffic violations. The state trooper decided to detain the drive and Appellant while a narcotics dog was called in. The narcotics dog alerted on the vehicle. A subsequent search of the car revealed small amounts of marijuana, $33,100 in cash, and evidence of marijuana dealing. In a criminal proceeding, Appellant was ultimately acquitted of marijuana possession. Meanwhile, in the forfeiture proceeding for the $33,100, Appellant alleged he was the owner of the $33,100. Appellant filed a motion to suppress, arguing that the money had been seized in violation of his constitutional rights. The district court denied Appellant’s motion to suppress based on res judicata from Appellant’s criminal proceeding, concluding that the denial of Appellant’s motion to suppress in his criminal case had preclusive effect in the forfeiture case. The court then ordered the money forfeited. The court of appeals affirmed. The Supreme Court reversed, holding (1) res judicata did not apply in this case because Appellant was acquitted in the criminal case; and (2) the trooper prolonged the stop in violation of the Fourth Amendment beyond what was necessary to address the observed traffic violations. Remanded. View "In re Property Seized from Robert Pardee" on Justia Law

When he was seventeen years old, Appellant committed the crime of first-degree robbery. Appellant was sentenced to a term of imprisonment not to exceed twenty-five years. Appellant was sentenced under a statute that required him to serve at least seventy percent of his sentence before he was eligible for parole. Appellant appealed, arguing that his sentence constituted cruel and unusual punishment. The Supreme Court vacated the sentence and remanded to the district court for resentencing, holding that, for the reasons express in State v. Lyle, filed on this same date, the mandatory sentence violated the prohibition against cruel and unusual punishment under the Iowa Constitution. View "State v. Taylor" on Justia Law

The State charged Defendant, a probationer, with burglary and theft after police officers conducted a warrantless search of Defendant’s home. Defendant filed a motion to suppress contending that the search warrant was invalid because it inaccurately described the house to be searched and because an alteration of the warrant based upon a verbal conversation with the issuing judge violated the statutory requirement that search warrant applications be in writing. The district court overruled the motion to suppress, concluding that the search warrant was inadequate but that the warrant was valid because the search was within the contemplation of the probation agreement. The court of appeals affirmed, concluding that the search of the probationer based upon reasonable suspicion of criminal activity and based upon the limited scope of the search was valid under the search and seizure provision of Iowa Const. art I, 8. The Supreme Court reversed, holding that, in accordance with State v. Cullison, the search of Defendant’s home by general law enforcement authorities was unlawful under the Iowa Constitution because the search was based on an invalid warrant. View "State v. Short" on Justia Law

Appellant was a seventeen-year-old high school student when he took a small plastic bag containing marijuana from a fellow student outside the high school. After a jury trial, Appellant was convicted of robbery in the second degree. Appellant was prosecuted as an adult and was sentenced under a statute that required the imposition of a mandatory seven-year minimum sentence of imprisonment. Appellant appealed, arguing that the mandatory minimum was unconstitutional as applied to him. During the pendency of the appeal, the United States decided Miller v. Alabama. The court of appeals affirmed the sentence. The Supreme Court granted review to consider whether Appellant’s sentence was constitutional in light of the cases the Court handed down subsequent to Miller. The Supreme Court vacated the sentence and remanded for resentencing, holding that a statute mandating a sentence of incarceration in a prison for juvenile offenders with no opportunity for parole until a minimum period of time has been served is unconstitutional under the Iowa Constitution. View "State v. Lyle" on Justia Law

Plaintiffs, fourteen African-Americans, brought a class action suit against the State, including thirty-seven different executive branch departments, under the Federal Civil Rights Act and the Iowa Civil Rights Act. In their complaint, Plaintiffs alleged that the State unlawfully discriminates against African Americans in employment. The district court entered judgment in favor of the State. The Supreme Court affirmed, holding that Plaintiffs did not meet their burden of establishing that the underlying documents did not provide sufficient information to allow employment practices to be separated for meaningful statistical analysis, and therefore, Defendant was entitled to summary judgment under the Iowa Civil Rights Act.View "Pippen v. State" on Justia Law

Aaron Cannon, a student at Palmer College of Chiropractic, was blind and requested that Palmer make accommodations for his visual disability. Palmer denied the request, explaining that it could not provide the proposed accommodations and curricular modifications because they would fundamentally alter its educational program. Cannon eventually withdrew from the program. Cannon filed a complaint with the Davenport Civil Rights Commission, arguing that Palmer had discriminated against him on the basis of his disability. The Commission granted relief, finding that Palmer had failed to comply with the applicable federal and state disability laws. The district court reversed. The Supreme Court reversed, holding that the Commission did not erroneously interpret or irrationally apply the applicable law in concluding that Palmer failed to establish that Cannon’s suggested accommodations would fundamentally alter its curriculum. View "Palmer College of Chiropractic v. Davenport Civil Rights Comm'n" on Justia Law

John Goodpaster worked as a customer service manager for Schwan’s Home Service, Inc., the largest home delivery frozen foods company in the nation, at Schwan’s Des Moines location. Goodpaster’s duty was to sell and deliver company products, and a basic requirement of Goodpaster’s job was that he drive a commercial vehicle. When Goodpaster began experiencing medical problems, his sales began to decrease, and he was eventually terminated. Goodpaster sued Schwan’s under the Iowa Civil Rights Act (ICRA) for disability discrimination and retaliation, claiming his employment was terminated because he had multiple sclerosis. The district court granted summary judgment in favor of Schwan’s. The Supreme Court reversed, holding (1) multiple sclerosis is a disability contemplated by the ICRA; and (2) a genuine issue of material fact existed regarding whether Goodpaster was qualified to perform the essential functions of his position. Remanded. View "Goodpaster v. Schwan's Home Serv., Inc." on Justia Law