Articles Posted in Iowa Supreme Court

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The Supreme Court answered questions certified to it by the United States District Court for the Northern District of Iowa, holding, among other things, that a municipality can assert qualified immunity to a claim for damages for violation of the Iowa Constitution based on its officers' exercise of "all due care." Specifically, the Supreme Court held (1) the due care exemption under Iowa Code 670.4(1)(c) could provide the City immunity; (2) section 670.4(1)(e) precludes an award of punitive damages against the municipality that employed the constitutional tortfeasor; (3) in a Godfrey v. State, 898 N.W.2d (Iowa 2017), action a court cannot award attorney fees against the municipal employer of the constitutional tortfeasor unless there is a statute expressly allowing such an award; and (4) it is appropriate to retroactively apply this Court's conclusion that in a Godfrey action, common law attorney fees may be available against the municipal employer of the constitutional tortfeasor. View "Baldwin v. City of Estherville, Iowa" on Justia Law

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The Supreme Court reversed the judgment of the district court summary judgment for the State on Appellant's application for postconviction relief (PCR) after denying Appellant's request to appoint an expert, holding that the district court abused its discretion in denying the expert and that the summary disposition was erroneous. After a jury trial, Appellant was found guilty of first-degree murder. Appellant was sentenced to life imprisonment. In her petition for postconviction relief Appellant asserted, among other claims, that her trial counsel was ineffective for failing to raise battered woman syndrome (BWS) in her trial and for not adducing BWS evidence. To prove her claim, Appellant sought a court-appointed BWS expert. The district court denied Appellant's request to appoint an expert and, simultaneously, cited Appellant's failure to provide an expert in granting summary judgment. The Supreme Court reversed, holding that the summary disposition was erroneous where the court, among other errors, concluded that the record did not show facts to support Appellant's claim that BWS should have been raised at her trial. View "Linn v. State" on Justia Law

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In this case brought by a former employee alleging discrimination and retaliation, the Supreme Court reversed the judgment of the district court entering judgment on a jury verdict for Plaintiff, awarding him back pay, emotional distress damages, front pay and attorney fees, holding that the district court erred in admitting hearsay, and the hearsay was not harmless. Plaintiff, a terminated employee, brought this action against his former employer and the employer's agents under the Iowa Civil Rights Ac, alleging that Defendants discriminated against him because of his age and his status as a cancer patient and retaliated against him due to his refusal to retire or quit. The jury entered a verdict for Plaintiff. The Supreme Court reversed and remanded the case for a new trial, holding that the district court erred in admitting hearsay and the record failed to rebut the presumption of prejudice associated with the admitted hearsay evidence. View "Hawkins v. Grinnell Regional Medical Center" on Justia Law

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The Supreme Court vacated the decision of the court of appeals reversing Defendant's conviction of second-degree murder, holding that Defendant was not entitled to a new trial on any of his allegations of error. After trial, Defendant filed a motion for a new trial alleging, among other things, that the trial court erred in refusing to disqualify a juror who allegedly made out-of-court statements regarding Defendant's guilt and misconduct and bias related to extraneous information reaching the jury about a possible riot if a certain verdict was not returned. The district court denied the motions for a new trial and entered judgment. The court of appeals reversed, concluding that juror misconduct and bias warranted a new trial. The Supreme Court vacated the decision of the court of appeals and affirmed the district court judgment, holding that Defendant was not entitled to a new trial under the facts of this case. View "State v. Christensen" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals affirming in part and reversed in part the judgment and sentence of the district court convicting Defendant of operating while intoxicated (OWI) second offense, holding that the clause of the OWI statutes that makes it unlawful for a person to operate a motor vehicle with any amount of a controlled substance in his or her person does not violate the Due Process Clause of either the United States or Iowa Constitution as applied to the facts of this case. The court of appeals found Iowa Code 321J.2(a)(c), which makes it unlawful for a person to operate a motor vehicle "[w]hile any amount of a controlled substance is present in the person," does not violate due process guarantees but reversed the judgment and sentence after concluding that the district court failed to engage in a proper colloquy before accepting a stipulation relating to the prior conviction for OWI. The Supreme Court only addressed the due process claim and affirmed the court of appeals as to the remaining issues, holding that section 321J.2(1)(c) does not violate the requirements of due process under the federal or state Constitutions as applied to this case. View "State v. Newton" on Justia Law

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The Supreme Court conditionally affirmed Defendant's conviction and sentence for first-degree murder but remanded for further proceedings consistent with decisions it also filed today in State v. Lilly, __ N.W.2d __ (Iowa 2019), and State v. Veal, __ N.W.2d __ (Iowa 2019), and this opinion, holding that further consideration of Defendant's claim that his jury was not drawn from a fair cross section of the community, in violation of the Sixth Amendment to the United States Constitution and article I, section 10 of the Iowa Constitution, was warranted. Defendant, an African-American, was charged with first-degree murder in a county that was approximately 2.3 percent African-American in population. The jury pool of unexcused jurors, however, contained only one African-American. The Supreme Court held (1) as in Lilly and Veal, the appropriate course of action is to remand the case to offer Defendant a further opportunity to develop his arguments that his Sixth Amendment right to an impartial jury was violated; and (2) Defendant's remaining claims of error did not warrant a new trial. View "State v. Williams" on Justia Law

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The Supreme Court conditionally affirmed Defendant's conviction for aiding and abetting a bank robbery and remanded for further consideration of Defendant's claim that his jury was not drawn from a fair cross section of the community, in violation of the Sixth Amendment to the United States Constitution and article I, section 10 of the Iowa Constitution, holding that further consideration of this claim was warranted. Defendant, an African-American, was convicted following a trial by a jury that contained no African-Americans. Further, there were no African-Americans in the jury venire that reported that day. On appeal, Defendant argued that the racial composition of the jury pool violated his rights to an impartial jury under both the federal and the state constitution. The Supreme Court held that the typical jury management practices can support a systematic exclusion claim under the framework established in State v. Plain, 898 N.W.2d 801 (Iowa 2017), and Duren v. Missouri, 439 U.S. 357 (1979), where the evidence shows one or more of those practices have produced underrepresentation of a minority group, and this case will be remanded to give Defendant a further opportunity to develop his fair-cross-section claim. View "State v. Lilly" on Justia Law

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The Supreme Court conditionally affirmed Defendant's conviction of two counts of first-degree murder while remanding the case for further proceedings consistent with State v. Lilly, __ N.W.2d __ (Iowa 2019), also decided today, holding that further consideration of Defendant's claim of violation of his right to an impartial jury drawn from a fair cross section of the community was warranted. Defendant was an African-American. Although the jury venire contained five African-Americans, no African-American was seated on the jury that heard Defendant's case. On appeal, Defendant asserted a number of trial-related issues, including the claim that his jury was not drawn from a fair cross section of the community in violation of the Sixth Amendment. The Supreme Court held (1) as in Lilly, the appropriate course of action is to remand the case to offer Defendant a further opportunity to develop his arguments that his Sixth Amendment right to an impartial jury was violated; and (2) Defendant's remaining claims did not warrant reversal. View "State v. Veal" on Justia Law

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The Supreme Court affirmed the district court's grant of summary judgment in favor of Defendants on Plaintiffs' claim that the 2017 amendments to Iowa Code chapter 20, the Public Employment Relations Act (PERA), violate the equal protection clause of the Iowa Constitution, holding that the 2017 amendments withstood the constitutional challenges. The 2017 amendments resulted in new classifications that made many public employees lose significant statutory bargaining rights compared to other public employees with ostensibly similar jobs. A public employee union and some of its members filed this action against the State and the Public Employment Relations Board (PERB) seeking injunctive and declaratory relief alleging that the amendments violated the equal protection clause of the Iowa Constitution and their right to freedom of association. The district court dismissed the action on summary judgment. The Supreme Court affirmed, holding that the legislative classifications are not so overinclusive or underinclusive as to be unconstitutional and that the amendments do not violate constitutional rights of freedom of association. View "AFSCME Iowa Council 61 v. State" on Justia Law

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The Supreme Court affirmed the district court's summary judgment in favor of Defendants on Plaintiffs' claim that the 2017 amendments to Iowa Code chapter 20, the Public Employment Relations Act (PERA), violate the equal protection clause of the Iowa Constitution, holding that the 2017 amendments withstood the constitutional challenges. The 2017 amendments resulted in new classifications that made many public employees lose significant statutory bargaining rights compared to other public employees with ostensibly similar jobs. Two unions representing public school employees filed this action seeking injunctive and declaratory relief against the State, the Iowa Public Employment Relations Board (PERB), and three PERB board members, alleging that the amendments violated the equal protection clause of the Iowa Constitution. The district court dismissed the action on summary judgment. The Supreme Court affirmed, holding that the legislative classifications are not so overinclusive or underinclusive as to be unconstitutional under this Court's rational basis test. View "Iowa State Education Ass'n v. State, Iowa Public Employment Relations Board" on Justia Law