Justia Constitutional Law Opinion Summaries

The district court found Defendant guilty of fraudulent practice in the third degree for possessing 218 packs of cigarettes lacking tax stamps. At issue on appeal was whether "the amount of money or value of property or service involved" in this crime was the amount of the unpaid tax or, rather, the value of the cigarettes. Defendant contended the degree of the crime should be based on the unpaid cigarette tax, which was insufficient to convict her of third-degree fraudulent practice. The district court determined the degree of fraudulent practice was based on the value of the cigarettes, not the amount of the unpaid tax. The court of appeals affirmed. The Supreme Court affirmed, holding that, under Iowa Code 453A.36, the possession of unstamped cigarettes was the fraudulent practice, not the unpaid tax, and therefore, the district court correctly entered judgment against Defendant for third-degree fraudulent practice. View "State v. Messer" on Justia Law

Appellant was convicted of first-degree in murder in 2005. In 2009, Appellant filed an application for postconviction relief alleging his trial was ineffective for (1) failing to raise the defense of temporary insanity or diminished capacity, and (2) failing to adequately support the request for bifurcation of his trial. Appellant also asserted his appellate counsel on direct appeal was ineffective for failing to appeal the trial court's denial of his request for bifurcation. The postconviction court denied Appellant's application. The court of appeals affirmed, finding that the postconviction court did not rule on Appellant's specific claims, and Appellant failed to preserve error by filing a subsequent motion under Iowa R. Civ. P. 1.904. The Supreme Court affirmed the denial of Appellant's application for postconviction relief, holding (1) the postconviction court did rule on Appellant's claims, and the claims were properly preserved for appeal; but (2) Appellant's claims lacked merit. View "Lamasters v. State" on Justia Law

The operator of an establishment offering nude and seminude dance performances sought an injunction restraining a city from enforcing its ordinance regulating nude and seminude dancing. The district court found that state law did not preempt the ordinance and that the ordinance was constitutional. The Supreme Court reversed the judgment of the district court, holding that state law preempts enforcement of the ordinance because the ordinance attempts to regulate nude dancing, and therefore, the ordinance is unenforceable against the establishment. Remanded to the district court with instructions to enter an order enjoining the city from enforcing its ordinance against the establishment.

This case required the Supreme Court to decide whether filmmakers receiving tax credits from the State of Iowa under the State's tax credit program could enjoin the State from releasing summaries of their films' final budgets to the public. The district court determined they could. The Supreme Court reversed, holding (1) the budget summaries do not qualify as trade secrets under Iowa Code 22.7(3); (2) the budget summaries cannot be considered "reports to governmental agencies which, if released, would give advantage to competitors and serve no public purpose" under Iowa Code 22.7(6); and (3) the filmmakers failed to meet Iowa Code 22.8's requirements for injunctive relief by demonstrating disclosure would not be in the public interest and would substantially and irreparably injure any person or persons. Remanded.

The American Civil Liberties Union of Iowa Foundation submitted an open records request to the Atlantic Community School District records custodian requesting information pursuant to Iowa's Open Records Act concerning the discipline of two school district employees after the school district disciplined them for performing a strip search of five students. The district court entered summary judgment in favor of the school district. The Supreme Court affirmed, holding that the district court did not err in finding that the disciplinary information sought was exempt from disclosure under Iowa Code 22.7(11), which exempts from disclosure "personal information in confidential personnel records of public bodies including...cities, boards of supervisors, and school districts."

Defendant was charged with murder in the first degree. Defendant provided notice he would be relying on the defense of insanity to the charge. The jury rejected the insanity defense and found Defendant guilty of first-degree murder. The district court sentenced Defendant to life in prison without the possibility of parole and ordered him to pay restitution for his attorney and expert witness fees. The court of appeals affirmed the conviction and restitution orders. Defendant appealed, claiming (1) the instructions given by the district court did not accurately define insanity, and (2) his own instruction should have been given. The Supreme Court affirmed, holding (1) the instructions given by the district court, when read as a whole, fairly and accurately advised the jury of the legal standard it was to apply to Defendant's insanity defense; and (2) due process under the Iowa Constitution does not require the district court to inform the jury of the consequences of a not-guilty-by-reason-of-insanity verdict under the facts of this case.

Tenant brought claims against her landlord, the City of Dubuque, and a City official (Defendants), asserting that they unlawfully caused her eviction from her apartment. Tenant alleged, among other things, that the conduct of Defendants violated a number of her statutory rights under the Iowa Uniform Residential Landlord and Tenant Act (IURLTA). To the extent the Dubuque ordinance authorized the action of Defendants, Tenant argued the ordinance was preempted by the IURLTA. The district court concluded that Tenant was entitled to the return of her security deposit but denied all other relief. The Supreme Court affirmed in part and reversed in part, holding (1) the ordinance was not preempted by the IURLTA and there was no violation of federal law in this case; (2) the ordinance was not unconstitutionally vague and any procedural due process claim was moot; (3) the landlord violated the IURLTA when he removed the belongings of Tenant from the apartment, and landlord's withholding of Tenant's security deposit was a bad faith violation of IURLTA. Remanded.

In 2007, two University of Iowa football players were accused of sexually assaulting another student in a campus dorm room. The incident led to criminal charges, internal actions by the University, an external criticism of the University. The incident also led to the present lawsuit, which concerned Open Records Act requests that the Iowa City Press-Citizen served on the University. Dissatisfied with the University's initial response to those requests, the Press-Citizen filed suit. The lawsuit resulted in more documents being produced and others being submitted for in camera review by the district court. The court then ordered additional documents produced, in some instances with redactions. The University appealed that order in part. The Supreme Court reversed the district court's judgment in part, holding that the Federal Educational Rights and Privacy Act prohibited the disclosure of the remaining documents, including even redacted versions of "education records" where the identity of the student was known to the recipient.

Following his sentencing to consecutive prison terms totaling thirty-five years, Defendant asked the Supreme Court to review the district court's determinations that the written entry of the verdict was proper, that a fork is a dangerous weapon, and that the State did not commit a Brady violation or fail to disclose newly discovered evidence, among others. The court of appeals affirmed. The Supreme Court affirmed in part and vacated in part the court of appeals, holding (1) the State did not commit a Brady violation; and (2) Iowa R. Crim. P. 2.17(2) requires a trial court to announce the verdict in a recorded proceeding in open court following a bench trial, and the district court in this case erred by not announcing the verdict in a recorded proceeding in open court. The Court found, however, that the district court cured its error and substantially complied with Rule 2.17(2) such that no remand was required.

Defendant Dontay Sanford was convicted for first-degree burglary for entering the car of a victim who later died from injuries received during the encounter. Sanford was sentenced to an indeterminate term in prison not to exceed twenty-five years. Sanford appealed, claiming there was insufficient evidence that the victim's automobile was an "occupied structure," which is one of the elements of burglary. The Supreme Court affirmed the conviction, holding (1) the State produced sufficient evidence that the victim's vehicle, under the facts of this case, was an occupied structure as that term is defined under the burglary statute; and (2) Sanford's pro se claims on appeal failed.