Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction of harassment in the first degree, holding that the district court did not err on remand in denying Defendant's motion challenging the representativeness of the jury pool under the fair-cross-section requirements under the Sixth Amendment.On appeal from his conviction, Defendant, an African-American, argued that his constitutional right to an impartial jury had been violated because his jury panel contained only one Africa-American out of forty-nine potential jurors that appeared at the courthouse for trial. The Supreme Court remanded the matter to give Defendant an opportunity to develop his impartial jury arguments, but the district court rejected Defendant's more developed claims on remand. The Supreme Court affirmed, holding that the district court did not err in holding on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury. View "State v. Plain" on Justia Law

The Supreme Court reversed Defendant's conviction for possession of cocaine and affirmed her conviction of interference with official acts, holding that the warrantless entry into Defendant's apartment to arrest her was unlawful.After Defendant was charged, she filed a motion to suppress, alleging that law enforcement officers made an illegal entry into her home and then used the information obtained from the legal entry to secure a search warrant. The motion to suppress was denied, and the trial court found Defendant guilty of the interference charge and possession of cocaine charge. The Supreme Court reversed in part, holding (1) evidence related to Defendant's conviction of possession of cocaine obtained from the unlawful warrantless entry into her apartment must be suppressed; and (2) Defendant's conviction of interference with official acts was sufficiently attenuated from the officers' unlawful entry to permit admission of Defendant's own illegal conduct under the "new crime exception" to the exclusionary rule. View "State v. Wilson" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Petitioners' applications for postconviction relief, holding that Petitioners' challenges to the State's allocation of its resources in the prison system were without merit.Petitioners were several male inmates serving time for sex-related offenses. Due to limits on resources, inmates were eligible for the sex offender treatment program, the completion of which was a requirement to be considered meaningfully for parole, only as the inmate neared his tentative discharge date. Petitioners brought applications for postconviction relief, arguing that this circumstance violated their constitutional due process rights. The district court denied relief. The Supreme Court affirmed, holding that the existing waiting list prioritizing admission to treatment based on tenantive discharge date, was a reasonable way to decide when an offender gets admitted to treatment and that the district court did not err in denying Petitioners' applications for postconviction relief. View "Bomgaars v. State" on Justia Law

The Supreme Court reversed Defendant's conviction of sexual abuse of a child, his granddaughter, holding that the district court erred by excluding evidence that another person, a teenager who testified for the State, sexually abused the victim.On appeal, Defendant argued (1) the Supreme Court should overrule State v. Pearson, 514 N.W.2d 452 (Iowa 1994), which would result in the reversal of his conviction; and (2) the district court erred in applying the "constitutional rights" exception to the rape shield law, Iowa R. Evid. 5.412(b)(1)(C). The Supreme Court reversed, holding (1) this Court declines to overrule Pearson; and (2) excluding Defendant's cross-examination of his granddaughter and the teenager about their relationship violated Defendant's rights under the Confrontation and Due Process Clauses and the constitutional rights exception to the rape shield law. View "State v. Montgomery" on Justia Law

The Supreme Court conditionally affirmed Defendant's convictions of three misdemeanor drug offenses and remanded this case for further proceedings, holding that remand was required for the district court to apply the standard set forth in State v. Wright, 961 N.W.2d 396 (Iowa 2021).Last term, in Wright, the Supreme Court held that law enforcement officers conducted an unconstitutional seizure and search when they seized and searched garbage bags left out for collection without first obtaining a warrant. In the instant case, Defendant argued that a sheriff's deputy violated his constitutional rights by seizing and searching his trash without first obtaining a warrant. The Supreme Court conditionally affirmed Defendant's convictions and remanded the case for the district court to hold a hearing on Defendant's motion to suppress evidence without consideration of the evidence obtained during the trash pull. View "State v. Kuuttila" on Justia Law

The Supreme Court reversed the order of the district court striking down sections 99 and 100 of House File 766, which added funding conditions prohibiting abortion providers from participating in two federally funded educational grant programs directed at reducing teenage pregnancy and promoting abstinence, holding that any conditions premised on providing abortions cannot be considered unconstitutional.Planned Parenthood of the Heartland (PPH) was a former grantee of both grants and, upon the passage of sections 99 and 100, became ineligible to receive funding. PPH brought a declaratory judgment action arguing that the Act violated its rights to equal protection, due process, free speech, and free association under the Iowa Constitution. The district court granted summary judgment for PPH and enjoined enforcement of the legislative enactments. The Supreme Court affirmed, holding (1) the conditions were rationally related to the classification selected by the general assembly; and (2) where abortion providers have no constitutional right to perform abortions, the unconstitutional conditions doctrine did not prohibit the State form barring abortion providers from receiving the funding at issue. View "Planned Parenthood of the Heartland, Inc. v. Reynolds" on Justia Law

The Supreme Court reversed the judgment of the district court concluding that Employer discriminated against Employee by firing him when he sought a reasonable accommodation for a disability, holding that Defendants were entitled to judgment as a matter of law on each of Employee's disability discrimination claims except his claims for failure to accommodate and retaliation based on his request for a sign language interpreter.Employee, who had a preexisting hearing impairment, continued to work while rehabilitating from a workplace injury, and Employer assisted the rehabilitation by providing light-duty work. When a disagreement arose as to whether Employee was entitled to a specific work restriction, Employee was fired. A jury awarded Employee damages after finding that Employer discriminated against him when Employee sought a reasonable accommodation for a disability. The Supreme Court reversed, holding (1) to the extent Plaintiff's disability claims were based on the workplace injury, Plaintiff's failure to identify a job he could perform apart from the temporary light-duty work defeated his claims; and (2) Employer was entitled to a new trial on Employee's disability claims stemming from his request for a sign language interpreter. View "Rumsey v. Woodgrain Millwork, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court and the decision of the court of appeals rejecting a sex offender's challenge to two aspects of his lifetime special parole sentence, holding that there was no error.Defendant pled guilty to one count each of sexual abuse in the third degree, lascivious acts with a child, and indecent contact with a child. Following the revocation of his parole, Defendant returned to prison and filed this application for post conviction relief claiming that his plea counsel his ineffectively for failing adequately to inform him of the rules and requirements of his special sentence. The district court denied the application. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Defendant's plea counsel was not constitutionally ineffective; and (2) Defendant's claim that the parole and ex-offender-treatment-program rules were unconstitutional as applied to him was unavailing. View "Doss v. State" on Justia Law

The Supreme Court conditionally affirmed Defendant's drug-related convictions, second offense, holding that, consistent with this Court's opinion in State v. Wright, __ N.W.2d __ (Iowa 2021), filed today, law enforcement officers conducted an unreasonable seizure and search when they seized and searched garbage bags left out for collection without first obtaining a warrant.On appeal, Defendant argued that two sheriff's deputies violated his federal and state constitutional rights to be free from unreasonable searches and seizures when they seized and searched a trash bag outside Defendant's residence without first obtaining a warrant. The Supreme Court agreed, holding that remand was required in order for the district court to hold a hearing on Defendant's motion to suppress evidence without consideration of the evidence and information obtained during a trash pull used to support their warrant application. View "State v. Hahn" on Justia Law

The Supreme Court rejected Defendant's constitutional challenge to Iowa Code 321J.16 and joining the majority of courts holding that it is not an unconstitutional penalty to admit into evidence Defendant's refusal to submit to a breath test, holding that the best course is to overrule State v. Pettijohn, 899 N.W.2d 1, 38-39 (Iowa 2017).After denying Defendant's motion in liming to exclude evidence of her refusal to submit to a breathalyzer test Defendant was convicted of driving while intoxicated. On appeal, Defendant challenged the constitutionality of section 321J.16, which allows into evidence a defendant's test refusal. Specifically, Defendant argued that Pettijohn, which held that a search warrant was required for a breathalyzer test of an intoxicated boater, should be extended to drunken driving cases. The Supreme Court (1) overruled Pettijohn and held that search warrants are not required for breathalyzer tests of either boaters or drivers when law enforcement has probable cause to believe that intoxicated boating or driving has occurred; and (2) it is not an unconstitutional penalty to admit into evidence a defendant's refusal to submit to a breath test. View "State v. Kilby" on Justia Law