Justia Constitutional Law Opinion Summaries

Defendant was charged with one count of robbery and one count of willful injury causing serious injury. The charges both stemmed from a single incident involving a single victim. Pursuant to a plea agreement, Defendant pleaded guilty to two counts of willful injury causing serious injury. Defendant appealed, arguing that his trial counsel was ineffective for allowing him to enter a guilty plea without a factual basis. The court of appeals vacated one of the willful injury convictions, finding that there was not a sufficient factual basis in the record to support a second independent charge of willful injury causing serious injury. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding that the record established an independent factual basis for the factual charge, and thus, counsel was not ineffective in allowing Defendant to enter guilty pleas to two separate counts of willful injury causing serious injury. View "State v. Velez" on Justia Law

In 2006, the Iowa Department of Revenue assessed the value of Qwest Corporation's Iowa operating property. Qwest protested the assessment by challenging the general assembly's previous decision to tax the personal property of incumbent local exchange carriers (ILECs) but not competitive long distance telephone companies (CLDTCs) or wireless providers operating in Iowa. Specifically, Qwest argued that the tax scheme which taxed ILECs for the value of their personal property but not CLDTCs and wireless providers violated Qwest's equal protection rights. The State Board of Tax Review (Board) concluded that Qwest's constitutional rights were not violated. The district court reversed. The Supreme Court reversed the district court and upheld the Board's assessment on Qwest, holding that imposing a tax on Iowa-based personal property of ILECs but not on that of CLDTCs or wireless service providers did not violate the Iowa Constitution, as the differential tax treatment of these enterprises is rationally related to legitimate state interests in encouraging the development of new competitive telecommunications infrastructure while raising revenue from those providers that historically had a regulated monopoly and continue to enjoy some advantages of that monopoly. View "Qwest Corp. v. State Bd. of Tax Review" on Justia Law

In 2010, Defendant pled guilty to stalking, first offense, with protective order, and fourth-degree criminal mischief. In 2011, Defendant was charged by information with stalking, second offense, or, alternatively, stalking in violation of a protective order. Defendant filed a motion to dismiss, arguing the State had not alleged sufficient facts to support a violation of the stalking statute, as the State had only detailed one incident of harassment. Specifically, Defendant argued that the use of the previous incidents, for which he was convicted, to prove the required course of conduct, would violate the double jeopardy clause. The district court granted the motion. The Supreme Court reversed, holding that the stalking statute, as applied in this case, did not violate the double jeopardy clause. View "State v. Lindell" on Justia Law

Defendant killed her longtime boyfriend. At trial, Defendant raised a defense of justification based on evidence of battered women's syndrome and a defense of insanity based on various diagnoses including depression and an anxiety disorder. Defendant was convicted of first-degree murder. The Supreme Court affirmed the conviction, holding that the district court did not erroneously (1) instruct the jury on the elements of a justification defense; (2) instruct the jury that Defendant bore the burden to prove an insanity defense; and (3) deny Defendant's motion for mistrial after the prosecution violated a ruling in limine during opening statements. View "State v. Frei" on Justia Law

Defendant was arrested and charged with operating a vehicle while under the influence of a controlled substance in violation of Iowa Code 321J.2(1)(c). Defendant asserted an affirmative defense under section 321J.2(7)(b), which provides that an operator of a vehicle cannot be convicted of operating under the influence of a drug if he is taking the drug as prescribed by his doctor and in accordance with the labeling directions of the pharmacy. After a jury trial, Defendant was convicted of operating while intoxicated. The Supreme Court reversed, holding that there was insufficient evidence to support the verdict because the evidence was too speculative for a jury to conclude beyond a reasonable doubt that Defendant failed to take the prescription drugs as directed by his doctor or the pharmacy. View "State v. Schories" on Justia Law

Defendant was one of several adult caregivers for a five-year-old girl suffering from malnutrition. The State charged Defendant with two counts of child endangerment, and a jury found Defendant guilty of child endangerment causing serious injury. Defendant appealed, contending that the district court erred by allowing a caseworker for the Department of Human Services (DHS) to testify that a child abuse report against Defendant was administratively determined to be "founded." The Supreme Court reversed the judgment of the district court and remanded the case for a new trial, holding that it was reversible error to allow testimony that DHS had determined the child abuse complaint against Defendant was founded. View "State v. Huston" on Justia Law

Defendant was charged with second-degree sexual abuse and child endangerment causing bodily injury after he admitted to sexually abusing a seventeen-month-old. Defendant moved to suppress his confession, claiming it was involuntary because the detective made promises of helping Defendant if he admitted to the crime. The district court denied the motion, holding that a promise to get help for a defendant does not constitute a promise of leniency. Defendant was found guilty of the charges. Defendant appealed the denial of his motion to suppress. The court of appeals affirmed, holding that the detective's statements about getting Defendant help were not impermissible promises of leniency. The Supreme Court vacated the court of appeals, reversed the judgment of the district court, and remanded the case for a new trial on both counts, holding (1) the interrogation of Defendant crossed the line into an impermissible promise of leniency, rendering the confession that followed inadmissible; and (2) the error was not harmless. View "State v. Howard" on Justia Law

Plaintiff worked for over ten years for Dentist. When Dentist's wife found out that her husband and Plaintiff often texted each other, she demanded that he terminate Plaintiff's employment. Dentist subsequently terminated Plaintiff's employment. Plaintiff brought this action against Dentist, alleging that Dentist discriminated against her on the basis of sex. The district court granted summary judgment for Dentist, finding that Plaintiff was not fired because of her gender but because she was a threat to Dentist's marriage. The Supreme Court affirmed, holding that Dentist's conduct here did not amount to unlawful sex discrimination in violation of the Iowa Civil Rights Act. View "Nelson v. Knight" on Justia Law

After a jury trial, Defendant was found guilty of second-degree burglary, operating a motor vehicle without the owner's consent, and operating a motor vehicle while intoxicated, second offense. Defendant appealed his burglary conviction. The court of appeals affirmed. The Supreme Court (1) affirmed the appellate court's decision holding that the evidence was sufficient to support the second-degree burglary conviction; (2) vacated the appellate court's decision with respect to Defendant's effectiveness of counsel claims, leaving all three ineffective-assistance-of-counsel claims for postconviction relief proceedings; and (3) affirmed Defendant's convictions for operating a motor vehicle without the owner's consent and operating a motor vehicle while intoxicated. View "State v. Clay" on Justia Law

In 1995, Appellant was convicted of first-degree armed robbery. In 2011, the governor commuted Appellant's sentence. Thereafter, Appellant filed an application for postconviction relief seeking recalculation of his earned time to comply with the governor's commutation of the mandatory minimum portion of his sentence. Specifically, Appellant contended that with the mandatory minimum portion of his sentence removed he was entitled to accumulate earned time at a faster rate than had been available to him under the original sentence, which included a mandatory minimum term of incarceration. If his earned time were calculated at the accelerated rate, Appellant contended he would be entitled to an immediate release. The district court denied his application. The Supreme Court (1) affirmed the district court's determination that the governor's commutation order did not entitle Appellant to an immediate discharge; but (2) reversed the part of the district court's ruling that the commutation had no effect on the rate of Appellant's accumulation of earned time and the resulting tentative discharge, as the legal effect of the governor's commutation order changed the rate at which Appellant could accumulate earned time from the date of the commutation forward. Remanded. View "Lowery v. State" on Justia Law