Justia Constitutional Law Opinion Summaries

Defendant Carson Walker was charged with operating a motor vehicle while intoxicated (OWI). After he was arrested, Walker requested to speak to his lawyer. While consulting, Walker and his lawyer talked through an intercom in a booth separated by a glass partition and were monitored by a police video camera. After conferring with his lawyer, Walker took a breath test, which measured Walker's blood level at more than double the legal limit. At trial, Walker moved to suppress the breath-test results based on the alleged violation under Iowa Code 804.20 to "see and consult confidentially" with his attorney "alone and in private." The district court granted the motion. On interlocutory appeal, the court of appeals reversed. The Supreme Court vacated the court of appeals and affirmed the district court's ruling suppressing the breath-test results, holding that the police violated Walker's section 804.20 rights by restricting his attorney conference to the booth with the glass partition under videotaped surveillance.

Defendant Jesse Pearson, a seventeen-year-old, robbed and beat an elderly man. After he was apprehended, Pearson refused to waive his Miranda rights. The next morning, however, he confessed to his social worker, Marie Mahler, without his attorney present. The district court denied Pearson's motion to suppress his confession, concluding that Mahler's interview was not a custodial interrogation implicating Miranda safeguards. A jury convicted Pearson of first-degree robbery, willful injury, and going armed with intent. The court of appeals reversed Pearson's conviction on the going armed charge and otherwise affirmed. At issue on appeal was whether Pearson's confession to Mahler was admissible. The Supreme Court affirmed, holding that Mahler's interview of Pearson was not a custodial interrogation for Miranda purposes and that his confession to her was voluntary and admissible.

A jury found Defendant Robin Brubaker guilty of operating while intoxicated, fourth offense, and unlawful possession of a prescription drug. On appeal, Defendant contended that the district court erred by denying his motion to suppress evidence found in his car when officers searched it after his arrest and that his trial counsel was ineffective for failing to object specifically to the sufficiency of the evidence offered by the State regarding the charge of unlawful possession of a prescription drug. The Supreme Court reversed the judgment for unlawful possession of a prescription drug and remanded the case for dismissal of that charge, holding that trial counsel was ineffective and if counsel had made the proper object regarding the sufficiency of the evidence, the district court would have dismissed the unlawful possession charge.

Judith Utter was charged with supplying alcohol to a person under the legal age. Utter pled guilty to the charge. Subsequently, Utter appealed, arguing her trial counsel provided ineffective assistance by failing to file a motion to dismiss the charge based on the State's violation of Iowa's speedy indictment rule. The court of appeals affirmed after analyzing the issue and preserving Utter's claim for a postconviction relief proceeding. The Supreme Court vacated the court of appeals and reversed the district court, holding (1) the State violated the speedy indictment rule by failing to indict Utter with the forty-five day window mandated by Iowa R. Crim. P. 2.33(2)(a); (2) Utter's trial counsel failed to perform an essential duty by failing to file a motion to dismiss based on the State's violation of the speedy indictment rule; and (3) Utter did not enter the plea voluntarily or intelligently as she would not have pled guilty if she had known the court was required to dismiss the information under rule 2.33(2)(a) and the State could not charge her with any other violation of Iowa Code 123.47 arising out of the underage drinking party at her home. Remanded with directions to dismiss the information.

After a jury trial, Raymond Redmond was convicted of indecent exposure. Redmond appealed, contending that the district court abused its discretion by permitting the State to impeach Redmond with his prior first-degree harassment conviction under Iowa R. Evid. 5.609(a)(1). The court of appeals affirmed the district court's evidentiary ruling. The Supreme Court vacated the court of appeals and reversed the district court, holding (1) the district court abused its discretion by allowing the State to impeach Redmond with his prior conviction as the prior conviction's probative value did not outweigh its prejudicial effect, and (2) the error was not harmless. Remanded for a new trial.

After a jury trial, David DeSimone was convicted of sexual abuse in the third degree. DeSimone's conviction was affirmed on appeal. DeSimone subsequently filed an application for postconviction relief, asserting that the State committed a Brady violation when it failed to turn over a witness's timecard showing that the witness could not possibly have seen the events to which she testified. The district court denied relief, and the court of appeals affirmed. The Supreme Court vacated the court of appeals and reversed the judgment of the district court, holding that the State's failure to disclose the timecard was a Brady violation because (1) the State suppressed the evidence, (2) DeSimone met his burden of proof that the evidence was favorable to his guilt or innocence, and (3) the evidence was material to the issue of guilt. Remanded.

While investigating a death by shooting, state police spoke with Justin Marshall, whom the police believed to have information relating to the crime. Because of Marshall's apparent plan to leave the area, the State filed a material witness complaint against him and obtained an arrest warrant for him. After Marshall's arrest, another man was charged with murder in connection to the death. Marshall filed a motion to dismiss the material witness complaint, alleging his continued detention violated due process, equal protection, and cruel and unusual punishment. The district court ordered Marshall's release, concluding that the authority of the State to detain a material witness is extinguished when a trial date is set for the underlying crime and the material witness is served with a subpoena. At issue on review was the proper interpretation of Iowa Code 804.11, which provides for the arrest of a material witness when the witness might be unavailable for service of a subpoena. The Supreme Court affirmed the order of the district court, concluding that section 804.11 authorizes the arrest and detention of material witnesses to felonies only for the purpose of ensuring that a valid subpoena may be served upon the witness.

Daniel Lado pleaded guilty to dependent adult abuse. Later, Lado filed a pro se petition for postconviction relief that contained a request for appointment of counsel. The district court appointed Lado counsel. After no action was taken on Lado's application, the district court dismissed Lado's petition pursuant to Iowa R. Civ. P. 1.944. Lado filed a pro se notice of appeal, alleging dismissal under rule 1.944 resulted from ineffective assistance of counsel. The court of appeals (1) affirmed the dismissal, and (2) found Lado's counsel was ineffective but preserved his claim for postconviction relief because it found the record was insufficient to determine whether the district court would have granted Lado's postconviction relief application if his counsel had acted competently. The Supreme Court vacated the court of appeals and reversed the district court, holding (1) Lado's counsel committed structural error in failing to seek a continuance to prevent dismissal under rule 1.944 or to make application to the court for the reinstatement of his case after it was dismissed by operation of the rule; and (2) the error constructively denied Lado the right to counsel. Remanded to district court for adjudication on the merits.

Alan Watts was convicted of possession with the intent to deliver, drug stamp tax violations, and possession of drug paraphernalia. Watts appealed, contending that the district court erred in denying his motion to suppress evidence obtained from searching his apartment. The Supreme Court affirmed Watts' convictions and sentence, holding that although the initial warrantless sweep of Watts' apartment was unlawful due to a lack of exigent circumstances, the district court did not err in denying Watts' motion to suppress because (1) the officers later procured a warrant to conduct a full search of the apartment, (2) the evidence in question was located during that search, and (3) the State demonstrated that the warrant would have been sought and granted even without the information from the earlier improper sweep.

While an inmate at a correctional facility, Kevin Walker was assaulted by another inmate and was seriously injured. Walker brought a tort claim against the State, a correctional officer, and two activity specialists, claiming they negligently failed to ensure his safety. The State sought summary judgment based upon the discretionary function and intentional tort exceptions to the Iowa Tort Claims Act (ITCA). The district court denied the motion, concluding a genuine issue of material fact existed as to whether the prison staff involved had knowledge of a history of prior trouble involving Walker. The Supreme Court granted the State's application for interlocutory appeal and affirmed the decision of the district court, holding that the district court did not err in denying the State's motion for summary judgment where (1) because the decisions made by the correctional staff in the supervision of the inmates, in this instance, did not involve the evaluation of broad public policy factors, the State was not entitled to the discretionary function exception; and (2) as long as a claimant can show the State is negligent in performing a duty to protect a person from an assault, the intentional tort exception to the ITCA is not applicable.