Justia Civil Rights Opinion Summaries

The case involves two attorneys, Jeffrey Peterzalek and Molly Weber, who sought to quash subpoenas for their depositions in a civil rights case brought by Charis Paulson against her employers, the State of Iowa and the Iowa Department of Public Safety (DPS). Paulson alleged gender-motivated discrimination and retaliation. Weber had represented DPS in its response to Paulson's civil rights complaint before the Iowa Civil Rights Commission (ICRC), while Peterzalek had represented DPS and its leaders in various other matters over the years. The district court declined to quash the subpoenas but ordered that the depositions be sealed. The attorneys then filed a petition for writ of certiorari with the Supreme Court of Iowa.The Supreme Court of Iowa granted the writ and retained the case. The attorneys argued that the court should adopt the Shelton test, which narrowly limits the circumstances in which opposing counsel may be deposed. They also argued that they should not be deposed or, alternatively, that substantial limitations should be imposed if their depositions were allowed.The Supreme Court of Iowa agreed with the attorneys' argument to adopt the Shelton test. Applying the test, the court concluded that Weber's deposition should be quashed as she was opposing counsel in the ongoing dispute and the information sought could be obtained by other means and was protected by the work-product doctrine. However, the court affirmed the district court's refusal to quash the subpoena for Peterzalek's deposition, as he was not opposing counsel in the ongoing dispute. The court remanded the case for further proceedings, including the entry of an order quashing the subpoena for Weber's deposition. View "Peterzalek v. Iowa District Court for Polk County" on Justia Law

The Supreme Court of Iowa ruled in a case involving an individual, Faron Alan Starr, who was arrested and denied his request to call a family member to get an attorney. Starr was suspected of an assault and stealing two firearms. After his arrest, he was taken to a police station where he initially equivocated about speaking to the police without an attorney. However, he later requested to call his father to obtain a lawyer, which was refused by the police officer. The officer proceeded to question Starr about his actions and whereabouts of the stolen firearms.Starr was charged with multiple offenses, and he subsequently filed a motion to suppress his statements and any evidence derived from them, asserting violations of his constitutional and statutory rights. The district court granted the motion, finding a violation of Starr's rights under Iowa Code section 804.20, which mandates that an arrested person be allowed to call and consult a family member or an attorney without unnecessary delay upon arrival at the place of detention.The Supreme Court of Iowa affirmed the lower court's decision, holding that while public safety concerns could potentially justify a delay in honoring an arrested person's rights under Iowa Code section 804.20, the circumstances of this case did not warrant such a delay. The court noted that the police did not address the issue of the missing firearms until nearly two hours after Starr was taken into custody for questioning at the police station. Therefore, the delay in permitting Starr to call a family member was deemed unnecessary. View "State of Iowa v. Starr" on Justia Law

The Supreme Court of Iowa affirmed the decision of the Court of Appeals and the District Court in favor of the City of Des Moines, in a case brought by Lime Lounge, LLC. Lime Lounge, a bar, challenged a city ordinance requiring it to obtain a conditional use permit (CUP) to operate. After receiving noise complaints, the City revoked Lime Lounge's CUP, which was upheld in a prior appeal. Lime Lounge then challenged the ordinance arguing it was preempted by Iowa Code, violated equal protection and spot zoning prohibitions. The trial court dismissed Lime Lounge's claims and this decision was affirmed by the Court of Appeals.The Supreme Court of Iowa found that the city's ordinance was not preempted by state law. Rather, it was a proper exercise of the city's zoning authority and did not create a separate local alcohol license. The Court also rejected Lime Lounge's equal protection claim, holding that the city had a legitimate purpose in imposing a CUP on specific businesses selling alcohol. Finally, the Court dismissed the claim of illegal spot zoning, as Lime Lounge failed to prove that the city had engaged in such activity. The Court thus affirmed the dismissal of Lime Lounge's challenge to the ordinance. View "Lime Lounge, Inc. v. City of Des Moines, Iowa" on Justia Law

The case concerns Sandra Selden, an employee at the Des Moines Area Community College (DMACC), who alleged that she was a victim of illegal wage discrimination based on sex and wrongful retaliation. Selden discovered that a male colleague was receiving a higher salary for the same job. When her employer did not act on her complaint, attributing the pay gap to the male employee's greater seniority and initial higher salary because of his relevant experience, Selden filed a civil rights complaint. She also applied for a supervisory position, but her application was screened out due to her lack of required educational qualifications. The case went to trial and the jury awarded damages to Selden on both claims. DMACC appealed the decision.The Supreme Court of Iowa reversed the lower court's decision, holding that the record did not contain substantial evidence of an illegal pay practice. The court found that the pay gap was due to gender-neutral factors, specifically a neutral seniority system, and the decision to hire the male employee at a higher rate due to market conditions and his significant experience. The court also found that the retaliation claim was not supported by substantial evidence, as the employer consistently screened out all applicants who lacked the required qualifications. The court concluded that the lower court should have directed a verdict in favor of the defendants and remanded the case for that purpose. View "Selden v. Des Moines Area Community College" on Justia Law

In this case, the Supreme Court of Iowa addressed whether the district court erred in ordering the placement of a sexually violent predator in a transitional release program over the State’s objection. The State argued that the offender was ineligible for that program without a relapse prevention plan (RPP) accepted by his treatment provider at the Civil Commitment Unit for Sexual Offenders (CCUSO) as required by Iowa Code section 229A.8A(2)(d) (2022). The district court determined that the offender’s plan, approved by the offender’s expert, satisfied that statutory requirement. The State appealed, asserting that the court erred by substituting its judgment for that of CCUSO’s staff.The Supreme Court of Iowa held that a writ of certiorari is the proper form of appellate review, and granted the petition. On the merits, the court held that the district court erred by substituting its judgment for that of CCUSO’s staff. The court agreed with the State that the offender was ineligible for placement in the transitional release program because his treatment provider at CCUSO had not accepted his proposed RPP. The court also rejected the offender's substantive due process claims. Consequently, the court sustained the writ and vacated the district court’s ruling. View "In Re Detention of Schuman" on Justia Law

In a case before the Supreme Court of Iowa, the defendant, Robert Clark Geddes, was charged with trespass as a hate crime. The defendant had trespassed onto various properties, leaving behind anonymous notes that urged the residents to "Burn that gay flag." The homes targeted by the defendant were displaying LGBTQ+ flags or decals. Geddes appealed his conviction, arguing that the evidence was insufficient and that his convictions violated his rights to free speech and due process.The court rejected the defendant's arguments and affirmed his convictions. The court ruled that Geddes was not being punished for his speech, but rather for his conduct—trespassing onto properties with the intent to commit a hate crime. The court found that the statute under which Geddes was convicted does not criminalize speech, but rather conduct with a specific intent—namely, trespassing on property because of the property owner or possessor's association with persons of a certain sexual orientation. The court also found that there was sufficient evidence to support Geddes's conviction.The court held that the defendant's conduct of surreptitiously entering onto properties to post his harassing notes was not protected under the First Amendment rights. The court noted that hate crime laws are designed to punish conduct, not expression, and Geddes's motive or intent led to the more serious criminal consequence. The court also rejected the defendant's argument that the trespass law was vague or overbroad, finding that it provides sufficient guidance to those enforcing it and does not intrude on protected freedoms. View "State of Iowa v. Geddes" on Justia Law

The Supreme Court affirmed Defendant's conviction for operating while intoxicated (OWI) and eluding, holding that the district court did not abuse its discretion in admitting evidence about a preliminary breath test (PBT) and that the evidence was sufficient to support the convictions.During the underlying jury trial, the district court admitted a portion of an officer body cam video showing Defendant agreeing to a PBT, after which the edited video jumped to Defendant's arrest for OWI. The Supreme Court held (1) this juxtaposition of the PBT and arrest violated Iowa R. Evid. 5.403 because it had minimal probative value while strongly implying that Defendant had failed the PBT, but the error was harmless; and (2) there was sufficient evidence to sustain Defendant's eluding conviction. View "State v. Amisi" on Justia Law

The Supreme Court held that the district court and court of appeals did not err in finding that Defendant was not seized before the law enforcement officer who eventually arrested him discovered his probable intoxication and that Defendant was lawfully detained on grounds of probable intoxication.In his motion to suppress, Defendant argued that he had been seized when the officers partially blocked him in while he was parked in a parking lot, trained a spotlight on him, and shined flashlights into his car from both sides. The trial court concluded that Defendant had not been "seized" before the police discovered his intoxication. The court of appeals affirmed, concluding that the officers' actions were not "sufficiently coercive" to constitute a seizure. The Supreme Court affirmed, holding that Defendant was lawfully detained because the officers did not seize him before his intoxication was observed. View "State v. Wittenberg" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the trial court denying Defendant's motion to suppress and convicting him of firearm violations, holding that the law enforcement officer who arrested Defendant did not unlawfully seize Defendant.After a woman called the police to report a suspicion car parked in front of her home an officer responded in a patrol car and pulled alongside the parked car. The officer walked over to talk to the driver, smelled a strong odor of burnt marijuana, and searched Defendant and the car. In his suppression motion, Defendant argued that the officer did not unlawfully seize him. The court of appeals concluded that the trial court did not err in denying the motion to suppress. The Supreme Court affirmed, holding that the officer's conduct in this case did not constitute a seizure, and once the officer detected the odor of burnt marijuana he had a lawful ground to detain and search Defendant and the car. View "State v. Cyrus" on Justia Law

The Supreme Court reversed the judgment of the district court granting Defendant's motion to suppress evidence obtained during a traffic stop, holding that because Defendant's license plate cover violated Iowa Code 321.37 it was reasonable for Iowa State Patrol troopers to stop his SUV, the stop was not unconstitutional, the exclusionary rule did not apply, and there were no grounds to suppress evidence from the stop.Because Defendant's rear license plate was shrouded with a tinted plastic cover troopers found it difficult to read the plate. The troopers stopped Defendant to warn him that the cover violated Iowa law and during the stop uncovered evidence leading to Defendant's charges for operating while intoxicated and child endangerment. The district court granted Defendant's motion to suppress, concluding that the traffic stop was unconstitutional. The Supreme Court reversed, holding (1) the traffic stop was constitutional because the license plate cover violated an Iowa traffic statute; and (2) therefore, the district court erred in suppressing evidence from the stop. View "State v. Griffin" on Justia Law