Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant Kenneth Madsen was convicted of two counts of sexual abuse in the second degree and one count of lascivious acts with a child. Madsen appealed, arguing (1) the district court erred in failing to suppress his confessions because his confessions were involuntary under the constitutional totality-of-the-circumstances test due to the detective's threat to make him late for work and promise that if Madsen confessed he could keep his name out of the newspaper and put the matter behind him; and (2) his counsel was ineffective for not attempting to suppress his confession under the common law evidentiary test for promises of leniency. The Supreme Court affirmed in part and reversed in part, holding (1) Madsen's trial counsel breached an essential duty by failing to move to suppress Madsen's confessions under the evidentiary test; (2) the interrogating officer made promises of leniency that required suppression of part of Madsen's confession, but Madsen's self-incriminating statements made before those promises remained admissible; and (3) Madsen was entitled to a new trial on one count of second-degree sexual abuse, but his two remaining convictions were affirmed based on lack of prejudice.

Plaintiffs, students or parents of students who attended Iowa public schools, filed a petition contending that Iowa's educational system was inadequate and urging the courts to impose additional public school standards, stating that such action was both constitutionally and statutorily required. Plaintiffs named as defendants the State, Governor, Department of Education, and Director of the Department. The district court dismissed Plaintiffs' petition, concluding (1) Plaintiffs had stated claims for relief under the equal protection and due process clauses, but their constitutional claims presented a nonjusticiable political question; and (2) their statutory claim under Iowa Code 256.37 failed because that provision did not afford a private right of action. The Supreme Court affirmed, holding (1) Plaintiffs' challenges were properly directed to Plaintiffs' elected representatives, rather than the courts; but (2) Plaintiffs did not state claims for relief under the Iowa Constitution or section 256.37.

Defendant Anthony Polk confessed in a jailhouse interview to firing his handgun at the scene of a gang-related shooting that left two men with gunshot wounds. Polk filed a motion to suppress his conviction, contending that the interrogating police officer baited him into talking after Polk had invoked his Fifth Amendment right to remain silent and made improper promises of leniency that suggested by talking to police Polk could get a better deal and spend less time away from his children. The district court denied Polk's motion and convicted Polk of several weapon-related crimes. The Supreme Court reversed Polk's convictions and sentences, holding that the interrogating officer's promises of leniency rendered Polk's confession inadmissible, and therefore, the district court erred in denying Polk's motion to suppress.

Petitioner, a juvenile offender whom the State tried as an adult, brought a postconviction relief action claiming that his conviction for first-degree murder should be overturned and that his sentence was illegal because it amounted to cruel and unusual punishment under the state and federal Constitutions. The district court dismissed both claims. The court of appeals affirmed, holding that Petitioner made the same claims in the past, and thus, the law of the case doctrine precluded the court from revisiting them. The Supreme Court vacated the decision of the court of appeals and reversed in part the judgment of the district court, holding (1) the law of the case doctrine precluded Petitioner from attacking his conviction for first-degree murder; but (2) the doctrine did not preclude Petitioner from attacking his sentence as illegal because the controlling authority regarding cruel and unusual punishment had changed since his original appeal regarding the issue, and the three-year limitation period for bringing a postconviction relief action did not prohibit a challenge to an illegal sentence. Remanded.

Charles Oliver was convicted a second time of third-degree sexual abuse, and Oliver stipulated that he had a prior conviction for third-degree sexual abuse. Because of his prior conviction, Oliver was guilty of a class A felony under the enhanced sentencing provisions of Iowa Code 902.14(1), and the district court accordingly sentenced Oliver to life in prison without the possibility of parole. The Supreme Court affirmed Oliver's sentence, holding (1) the sentence of life without parole did not constitute cruel and unusual punishment in violation of the state and federal Constitutions when considered in light of the particular facts of Oliver's case; and (2) section 902.14(1) was not unconstitutional either on its face or as applied to Oliver.

On July 27, 2011, the Governor item vetoed several provisions in an appropriations bill passed in the General Assembly. Primarily at issue was $8.66 million the legislature appropriated in section 15 for the operation of Iowa Workforce Development (IWD) field offices. The Governor, without vetoing that appropriation, item vetoed (1) section 15(3)(c), prohibiting the closure of field offices; (2) section 15(5), defining "field office" to require the presence of a staff person; and (3) section 20, restricting use of IWD appropriations for the national certificate program. The district court upheld the item veto of section 20 but declared invalid the item veto of section 15(3)(c) and 15(5). The Supreme Court affirmed in part and reversed in part, holding (1) the Governor's item vetoes of section 15(5) and section 20 did not comply with the item-veto amendment of the state constitution because the Governor unconstitutionally item vetoed "conditions or restrictions" on the appropriations without vetoing the accompanying appropriations; and (2) when the Governor impermissibly item vetoes a condition on an appropriation during the pocket veto period, the appropriation item fails to become law. Remanded for entry of judgment invalidating sections 15 and 20 of the bill.

Defendant was convicted of possession of marijuana as an accommodation offense. Defendant was previously convicted of simple possession of marijuana. Defendant requested a sentencing hearing to determine whether he should be sentenced for a serious misdemeanor or an aggravated misdemeanor. The district court concluded the plain language of Iowa Code 124.410 and 124.401(5) provided Defendant be sentenced for a serious misdemeanor. The Supreme Court affirmed the judgment and sentence imposed by the district court, holding that the court did not misinterpret or misapply sections 124.401(5) and 124.410 when it sentenced Defendant for a serious misdemeanor under the circumstances presented here.

Police officers initiated an investigatory encounter with William DeWitt in Walmart based initially on information provided to them by a confidential informant. The officers decided to confront DeWitt and take him outside to his car to talk to him about their suspicion he was selling drugs. One or both of the officers took DeWitt by the arm. DeWitt broke free from their grasp, and the officers responded by taking him to the ground and handcuffing him. DeWitt was subsequently convicted of possession with intent to deliver, violation of the drug stamp act, and interference with official acts. The court of appeals affirmed the convictions. The Supreme Court affirmed, holding (1) the district court did not err in denying DeWitt's motion to suppress, as the officers' conduct in physically restraining DeWitt was not a violation of his right to be protected from unreasonable seizures under the state and federal constitutions; and (2) under the facts and circumstances of this case, the evidence was sufficient to support DeWitt's conviction.

In this case, the Supreme Court considered whether an internal audit created by Broadlawns Medical Center as a result of the theft of drugs by an employee was a public record under the Iowa Open Records Act. The district court concluded that, because the internal audit was provided to the Iowa Board of Pharmacy in order to assist in its investigation of licensing matters arising from the theft, the internal audit amounted to investigative materials in the hands of a licensing board under Iowa Code 272C.6(4) and was not subject to disclosure. The Supreme Court (1) reversed the judgment of the district court holding that the internal audit was not subject to disclosure, as the internal pharmacy audit was a public record, not a confidential record, and other statutory exceptions asserted to prevent public disclosure were inapplicable; and (2) affirmed the rulings of the district court that the plaintiff failed to establish the basis for nondisclosure under Iowa Code 22.7(61).

This case was remanded to the district court for determination of whether a class should be certified and for determination of what, if any, part of the City's franchise fees for gas and electricity services are related to its administrative expenses in exercising its police power. The district court certified a class, found the franchise fees cannot exceed $1,575,194 per year for the electric utility and $1,574,046 for the gas utility, entered judgment in favor of the certified class against the City in the amount by which such fees exceeded that amount for an approximately ten-year period, and retained jurisdiction to determine the amount of money to be refunded to members of the class. The Supreme Court affirmed the judgment as modified, concluding that certain amounts allocated or not allocated by the district court as proper components of the franchise fees should be modified. Remanded.