Justia Constitutional Law Opinion Summaries

Defendant was charged with and pled guilty to criminal transmission of HIV in violation of Iowa Code 709C.1. The district court accepted the plea, sentenced Defendant to twenty-five years suspended and placed Defendant on probation for five years. Defendant subsequently filed an application for postconviction relief, claiming that his trial counsel provided ineffective assistance for allowing him to plead guilty, by failing to challenge the factual basis of the plea, and failing to complete a proper investigation before the plea hearing. The district court denied the application, and the court of appeals affirmed. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the trial court, holding that the guilty plea record did not contain a factual basis to support the plea, and the court in this case could not use the rule of judicial notice to establish the factual basis in the guilty plea record. Remanded. View "Rhoades v. State" on Justia Law

Grain Processing Corporation (GPC) operated a local corn wet milling facility in Muscatine. Plaintiffs, eight individuals who resided within one and one-half miles of GPC’s facility, filed a lawsuit on behalf of themselves and other similarly situated Muscatine residents, claiming that GPC’s operations caused harmful pollutants and noxious odors to invade their land. Plaintiffs based their claims on common law and statutory nuisance and the common-law torts of trespass and negligence. GPC filed a motion for summary judgment prior to class certification, claiming (1) Plaintiffs’ common law and statutory claims were preempted by the Federal Clean Air Act; (2) alternatively, the common law claims were preempted by the state statutory companion to the CAA; and (3) the issues raised by Plaintiffs were political questions. The district court granted summary judgment for GPC. The Supreme Court reversed, holding that Plaintiffs’ claims (1) were not preempted by the CAA; (2) were not preempted by Iowa Code 455B; and (3) were not subject to dismissal by operation of the political question doctrine. View "Freeman v. Grain Processing Corp." on Justia Law

Plaintiff, the workers’ compensation commissioner, filed an amended petition against the State and individual defendants named in their official and individual capacities. Plaintiff’s claims stemmed from his refusal to resign upon the Governor-elect’s demand for resignation and Plaintiff's subsequent reduction in salary. The attorney general provided a certification certifying that the individual defendants were acting within the scope of their employment at the time of the allegations contained in the amended petition, and therefore, certain immunities applied to various counts of the petition. The district court dismissed those counts alleging that the individual defendants acted outside the scope of their employment, concluding that the attorney general’s certification was applicable to all of Plaintiff’s claims. The Supreme Court reversed, holding (1) the Iowa Tort Claims Act applies only to torts committed by state employees when acting within the scope of their employment; and (2) therefore, the attorney general’s certification was not applicable to Plaintiff’s common law claims alleging that the individual defendants acted outside the scope of their employment. Remanded. View "Godfrey v. State " on Justia Law

Defendant was convicted of operating while intoxicated, second offense. Defendant appealed the district court’s denial of his motion to suppress the breath-test result obtained after his arrest, arguing that he had been denied his statutory right to an independent chemical test. The court of appeals reversed, concluding that the district court erred in denying Defendant’s motion to suppress. The Supreme Court affirmed, holding (1) Defendant’s statutory right to an independent chemical test was violated when he made statements that could be reasonably construed as a request for an independent test under Iowa Code 321J.11 but law enforcement denied his request, and (2) the error was not harmless. Remanded for a new trial. View "State v. Lukins" on Justia Law

Defendant was charged with and found guilty of driving under revocation. Defendant appealed, arguing that the district court’s admission of a certified abstract of his driving record and affidavits of the mailing of suspension notices violated his rights under the Confrontation Clauses of the United States and Iowa Constitutions. The court of appeals concluded that the admission of the disputed documents did not violate the Confrontation Clauses. The Supreme Court affirmed, holding (1) the admission of the certified abstract of Defendant’s driving record did not violate the Confrontation Clauses; and (2) the admission of the affidavits of the mailing of suspension notices violated the Confrontation Clauses, but their admission into evidence was harmless error. View "State v. Kennedy" on Justia Law

Police officers stopped Defendant’s vehicle after discovering that the vehicle’s license plate frame covered up the county name on the license plate, which the officers believed violated Iowa Code 321.37(3). As a result of the stop, Defendant was charged with possession with intent to deliver crack cocaine, a drug tax stamp violation, and driving under suspension. A district court judge denied Defendant’s motion to suppress, concluding that the license plate frame violation gave no reason to stop Defendant but that the stop was lawful based on a reasonable suspicion of drug dealing. A different judge who presided at trial upheld the stop based on the license plate violation alone. After a jury trial, Defendant was found guilty as charged. The court of appeals affirmed, which held that the traffic stop was lawful based on reasonable suspicion of drug dealing without deciding the license plate issue. The Supreme Court affirmed the conviction without reaching the issue of whether the traffic stop was lawful based on reasonable suspicion of drug dealing, holding that a license plate frame that covers up the county name violates Iowa Code 321.37(3) and provides a valid basis for a traffic stop. View "State v. Harrison" on Justia Law

After taking self-care leave under the Family and Medical Leave Act (FMLA), Plaintiff was terminated from her employment with the State. A jury found the State terminated Plaintiff in violation of her rights under the FMLA. The district court awarded Plaintiff money damages and ordered the State to reinstate Plaintiff to her former position. The State appealed and successfully requested a stay of Plaintiff’s reinstatement pending the outcome of the appeal. The Supreme Court subsequently held that sovereign immunity precluded Plaintiff’s judgment for money damages against the State. On remand, the district court once again ordered Plaintiff reinstated and awarded lost wages and benefits from the date of the original reinstatement order, concluding that the State had waived its sovereign immunity by seeking a stay of the reinstatement order and promising to pay Plaintiff’s interim wages and benefits if the Court affirmed the original order. The Supreme Court affirmed, holding (1) Plaintiff’s pleadings were sufficient to preserve her right to Ex parte Young remedies, and the parties litigated the reinstatement remedy by consent; and (2) the Eleventh Amendment to the U.S. Constitution does not bar an award of wages and benefits for the period during which a reinstatement order was stayed. View "Lee v. State" on Justia Law

After a jury trial, Defendant was convicted of voluntary manslaughter and five counts of intimidation with a dangerous weapon with intent. The Supreme Court vacated Defendant’s convictions on three counts of intimidation with a dangerous weapon with intent and affirmed his remaining convictions, holding (1) trial counsel was ineffective for failing to move for a judgment of acquittal after the verdict on the intimidation counts because the evidence did not support the verdicts that Defendant committed five separate and distinct acts of intimidation with a dangerous weapon with intent; (2) however, substantial evidence supported two separate and distinct crimes of intimidation with a dangerous weapon with intent; (3) the record was inadequate to decide Defendant’s separate allegation of ineffective assistance of counsel; and (4) the district court did not abuse its discretion in failing to admit certain photographs into evidence. Remanded. View "State v. Ross" on Justia Law

As a condition of her employment, Employee signed an agreement to arbitrate claims with Employer. Employee later filed a complaint with the Iowa Civil Rights Commission (ICRC), alleging that Employer had discriminated against her because of her pregnancy. The ICRC subsequently filed a statement of charges with the Iowa Department of Inspections and Appeals (DIA). Employer filed a motion to dismiss the ICRC’s charges or, in the alternative, compel arbitration. The DIA denied Employer’s motion on the ground that ICRC was not a party to the arbitration agreement and, consequently, not bound by it. On judicial review, the district court remanded instructions for the ICRC to dismiss the matter pending arbitration by the parties, concluding that the Federal Arbitration Act (FAA) preempted state law. The Supreme Court reversed, holding the FAA did not require arbitration of this proceeding because it was brought by an entity that was not bound to arbitrate under generally applicable principles of contract law, where the ICRC was not a party to the agreement and its interest was not derivative of Employee’s. View "Rent-A-Center, Inc. v. Iowa Civil Rights Comm'n" on Justia Law

After a jury trial, Defendant was convicted of kidnapping in the first degree, among other charges. Defendant was a juvenile at the time of the kidnapping. The district court sentenced Defendant to life imprisonment without the possibility of parole for the kidnapping conviction. After the U.S. Supreme Court decided Graham v. Florida, Defendant filed a motion to correct an illegal sentence on the kidnapping conviction, contending that his sentence violated the Eighth Amendment of the U.S. Constitution. The district court agreed that the sentence was unconstitutional and corrected Defendant’s conviction to life in prison with immediate parole eligibility. Defendant appealed, claiming, inter alia, that his sentence was unconstitutional under both the U.S. and the Iowa Constitutions. The court of appeals affirmed Defendant’s conviction and sentence as corrected. The Supreme Court conditionally affirmed, holding that Defendant’s sentence was constitutional under the U.S. Constitution. Because Defendant’s claims that his sentence was illegal under the Iowa Constitution were not fully developed, the Court did not reach those claims. Remanded. View "State v. Hoeck" on Justia Law