Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed the judgment of the district court granting summary judgment to a police detective and his city employer in this case alleging defamation, abuse of process, and malicious prosecution, holding that there was no error.Plaintiff, who was acquitted of a sexual assault charge, sued county prosecutors and city police for allegedly pursuing the case against him. The Supreme Court held that the county prosecutors were entitled to dismissal from the case but rejected the investigating detective's arguments for dismissal on the pleadings. The district court ultimately granted summary judgment to the detective and the city. The Supreme Court affirmed, holding that the district court (1) properly granted summary judgment to the city defendants on Plaintiff's continuing malicious prosecution claim; and (2) did not err in dismissing Plaintiff's direct claims for damages under the Iowa Constitution. View "Venckus v. City of Iowa City" on Justia Law

The Supreme Court dismissed this direct appeal brought by the Iowa Department of Human Services (HDS) from a district court ruling requiring Iowa's Medicaid program to pay for sex reassignment surgery for two transgender adults and affirmed the denial of fees on cross-appeal, holding that the appeal was moot.Petitioners, adult transgender Iowans who were denied preauthorization for sex reassignment surgeries through the Medicaid program, appealed their managed care organization's denial of coverage to DHS. DHS affirmed the denials. The district court reversed, concluding that Iowa Code 216.7(3), an amendment to the Iowa Civil Rights Act (ICRA) violated the guarantee of equal protection under the Iowa Constitution. DHS appealed, but, thereafter, agreed to pay for Petitioners' surgeries. The Supreme Court dismissed the direct appeal as moot and affirmed the district court's order denying any fee award, holding that the court erred in denying Petitioners' request for attorney fees. View "Vasquez v. Iowa Dep't of Human Services" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment to Defendants and dismissing Plaintiff's various legal theories of direct damages liability under the Iowa Constitution, holding that Godfrey v. State, 898 N.W.2d 844 (Iowa 2017), is hereby overruled.Plaintiff, a garbage truck driver, was stopped on a busy high by a Iowa Department of Transportation (IDOT) officer for a cracked windshield. During the interaction, Plaintiff was arrested and later charged with interference with legal acts. He was later acquitted of the charge, and subsequently sued the State and the IDOT officer, arguing that his passive noncooperation did not give the officer probable cause to arrest him. The district court granted summary judgment for the defendants. Plaintiff appealed and asked the Court to endorse his constitutional tort claim under Godfrey. The Supreme Court affirmed, holding (1) this Court overrules Godfrey and restores the law as it existed before 2017; and (2) this Court no longer recognizes a standalone cause of action for money damages. View "Burnett v. Smith" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of sexual abuse in the third degree, holding that Defendant was not entitled to reversal of his convictions on his allegations of error.The court of appeals affirmed Defendant's convictions but concluded that the trial court lacked jurisdiction to enter a nunc pro tunc order attempting to correct Defendant's sentence and remanding the case for the district court to correct the sentence. The Supreme Court affirmed, holding (1) the State presented sufficient evidence to support the jury's finding that Defendant was previously convicted of an act of sexual abuse for purposes of the sentencing enhancement; (2) the district court did not err in overruling Defendant's challenge brought under Batson v. Kentucky, 476 U.S. 79 (1986); and (3) any error in the court's decision to excuse a juror for cause did not prejudice Defendant. View "State v. Booker" on Justia Law

The Supreme Court affirmed Defendant's convictions for two counts of possession of a controlled substance with intent to deliver and two counts of failure to possess a tax stamp, holding that the district court did not err in denying Defendant's motion to suppress.Officers entered Defendant's apartment without a warrant over the objections of the occupants. They then obtained a search warrant, finding evidence resulting in criminal charges. Defendant filed a motion to suppress, arguing that the initial warrantless entry was unconstitutional. The district court denied the motion, concluding that the search was justified under the emergency aid doctrine. The Supreme Court affirmed, holding that the emergency aid doctrine permitted the police officers' entry into the residents to render emergency aid to a possible shooting victim hidden inside. View "State v. Youm" on Justia Law

The Supreme Court reversed the judgment of the district court concluding that Defendants discriminated against prospective tenants in violation of municipal law by steering prospective tenants of a protected religion or national origin away from their rental properties, holding that there was insufficient evidence against Defendants under the proper jury instruction.The Des Moines Civil and Human Rights Commission brought this action alleging that Defendants, a husband and wife who owned rental properties together, engaged in housing discrimination. The jury found the husband was liable for steering and imposed a civil penalty of $50,000 against him. The Supreme Court reversed and remanded for dismissal of the steering charge against the husband, holding that the district court's instructions misled the jury to the husband's detriment. View "Des Moines Civil & Human Rights Comm'n v. Knueven" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of operating a motor vehicle while intoxicated, second offense, harassment of a public official, and interference with official acts, holding that the district court did not err in denying Defendant's motion to suppress.Defendant was out drinking when his wife called him. When Defendant arrived home, his wife had been arrested for child endangerment and was handcuffed in a squad car. Knowing Defendant was agitated, the followed him inside his home where a social worker was interviewing three children in her investigation of child endangerment. At issue was whether the police needed a warrant to enter the home to protect the social worker. The Supreme Court affirmed, holding that the officers' warrantless entry under these exigent circumstances did not violate Defendant's rights pursuant to the Fourth Amendment or Iowa Const. I, 8. View "State v. Torres" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder in the first degree, holding that Defendant was not entitled to relief on his allegations of error.In 2019, police charged Defendant with murder in the first degree for a murder committed in 1979. The charges were based on the results of a DNA test that was performed on a drinking straw that the police retrieved from an eating establishment where Defendant had eaten. A jury found Defendant guilty and sentenced him to prison. The Supreme Court affirmed, holding (1) the district court did not err by denying Defendant's motion to suppress evidence about DNA that police found on the straw that Defendant discarded or to analyze DNA attached to the straw; (2) the district court did not abuse its discretion by declining to give an instruction regarding federal sentencing law; and (3) the evidence was sufficient to support Defendant's conviction. View "State v. Burns" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment in favor of Defendant and dismissing Plaintiff's claim that Iowa's tax-sale statute violates due process because it doesn't require personal service of a written notice that the taxpayer will lose his or her land, holding that the court did not err.Plaintiff stopped paying property taxes on a parcel of farm land he obtained, and the parcel was sold at a tax sale. Defendant paid Defendant's overdue taxes and received a certificate of purchase. When Plaintiff did not redeem the parcel Defendant sent Plaintiff notice by regular mail and certified mail to the parcel itself and to Plaintiff's last known address. After ninety days the county treasurer issued a tax sale deed to Defendant. Plaintiff brought this action claiming he did not timely receive actual notice of the tax sale proceedings and that Iowa Code 447 violates constitutional due process guarantees because it does not require effective notice. The district court granted summary judgment for Defendant. The Supreme Court affirmed, holding that Plaintiff failed to show a due process violation in this case. View "Kluender v. Plum Grove Investments, Inc." on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for voluntary manslaughter, holding that the circuit court committed no instructional error or constitutional violation in the underlying proceedings.On appeal, Defendant argued, among other things, that the district court erred in instructing the jury on a "stand your ground" defense, which confused the jury about his actual justification defense. The Supreme Court affirmed, holding (1) Defendant was not entitled to relief on his argument that the stand-your-ground defense wasn't in play, and thus that the stand-your-ground instruction was erroneously given; and (2) including the term "illegal activity" in the instructions did not violate Defendant's right to due process. View "State v. Ellison" on Justia Law