Articles Posted in Iowa Supreme Court

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The Supreme Court reversed the decision of the district court denying Employer’s motion for summary judgment on Employee’s lawsuit filed under the Iowa Civil Rights Act (ICRA) alleging that Employer discriminated against him based on his age, sex, and national origin. Matthew Jahnke, an employee of Deere & Co., worked as a factor manager at Harbin Works in Harbin, China under a contract with a Deere Chinese subsidiary. As discipline for Jahnke engaging in sexual relationships with two Chinese employees, Jahnke was ultimately removed as the factor manager, repatriated back to the United States, and assigned to a position of lesser authority and lower pay in Waterloo, Iowa. Jahnke filed suit under the ICRA. In its motion for summary judgment, Deere claimed that the ICRA did not apply extraterritorially and that Jahnke based his claims on allegations of discriminatory acts that occurred outside of Iowa. The district court denied the motion. The Supreme Court reversed, holding (1) the ICRA does not apply extraterritorially; and (2) because Jahnke failed to show that either he or Deere was located within Iowa for purposes of the alleged discriminatory act, Jahnke had no claim under the ICRA. View "Jahnke v. Deere & Co." on Justia Law

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At issue was whether the district court erred in not ordering a competency examination and in excluding evidence when Defendant’s lawyer moved midtrial for the examination of Defendant, who, among other things, stated that she wanted to stab her lawyer in the neck and wanted to kill him. Defendant was charged with willful injury causing bodily injury. During trial, the district court excluded evidence relating to the victim’s prior threatening behavior and her convictions for two assaults and an escape as more prejudicial than probative. Also during trial, Defendant’s attorney moved for a competency examination of Defendant, stating that Defendant was incapable of aiding him in her defense due to Defendant’s paranoid schizophrenia. The district court denied the motion, and Defendant was convicted. The Supreme Court reversed, holding (1) the district court was presented with sufficient reason to order a competency evaluation under Iowa Code 812.3; and (2) the district court properly excluded the challenged evidence about the victim as being substantially more prejudicial than probative. View "State v. Einfeldt" on Justia Law

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In this appeal, Appellant, who at age thirteen shot and killed his mother, raised challenges to Iowa’s youthful offender laws. Specifically, he argued (1) Iowa Code 232.45(7)(a) does not provide statutory authority to try a thirteen-year-old as a youthful offender, (2) Iowa Code 232.45(7) and Iowa Code 907.3A constitute unconstitutional cruel and unusual punishment, and (3) the sentencing court abused its discretion by incarcerating him. The Supreme Court affirmed Appellant’s conviction as a youthful offender and his fifty-year indeterminate sentence with immediate parole eligibility, holding that the district court did not abuse its discretion in sentencing Appellant to a prison term rather than releasing him on probation or placing him in a transitional facility based on an individualized assessment of Defendant under a constitutional statutory scheme. View "State v. Crooks" on Justia Law

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A corporation does not have family members and therefore cannot qualify for the family-member exception to the employee-numerosity requirement in the Iowa Civil Rights Act (ICRA). Plaintiff worked for Defendant, a small insurance agency, and alleged that she was sexually harassed by her supervisor, the sole owner’s husband. Defendant, a subchapter S corporation, employed the owner, the owner’s husband and two other family members, Plaintiff, and another nonfamily member. Defendant moved for summary judgment on the ICRA claims on the grounds that it employed fewer than four individuals, not counting the family members. The district court denied summary judgment, concluding that a corporate employer is ineligible for the family-member exception to the ICRA contained in Iowa Code 216.6(6)(a). The court of appeals affirmed. The Supreme Court affirmed, holding that Defendant could not avail itself of the family-member exception. View "Cote v. Derby Insurance Agency, Inc." on Justia Law

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After Defendant’s initial sentence was voided for illegality, the district court resentenced Defendant to a new term of imprisonment. The district court originally suspended Defendant’s prison sentence and instead ordered a five-year term of probation. Upon resentencing, the court refused to credit the time Defendant spent on probation pursuant to the initial sentence against the new term of imprisonment. The Supreme Court held that the failure to award credit for the time spent on probation violated Defendant’s constitutional right to be free from double jeopardy under the Fifth Amendment. The court held that all time Defendant spent on probation pursuant to the voided sentence must be fully credited against a corrected sentence of incarceration because, when an initial sentence is voided for illegality, any punishments already endured must be credited against the corrected sentence. The dissent disagreed, arguing that probation should not be equated with punishment in the same way incarceration is considered for double jeopardy purposes. View "State v. Jepsen" on Justia Law

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The Supreme Court affirmed Defendant’s conviction for failure to comply with the sex offender registry but vacated the district court sentence, which included sentencing enhancements, and remanded for further sentencing proceedings. The court held (1) despite the legislature’s ambiguous language in Iowa Code 692A.105, the legislature intended for registered sex offenders to provide notification of a change to temporary lodgings within five business days of that change; (2) the evidence was sufficient to show Defendant failed to comply with section 692A.105; (3) the district court properly instructed the jury regarding the applicable law; (4) any alleged prosecutorial misconduct did not prejudice Defendant; (5) Defendant’s stipulations to the sentencing enhancements were meaningless without a factual basis establishing whether he was represented by counsel for his prior convictions, and therefore, the case should be remanded to establish a factual basis on this sentencing issue; and (6) Defendant’s remaining claims of ineffective assistance of counsel failed. View "State v. Coleman" on Justia Law

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Law enforcement officers executing a search warrant violated Defendant’s rights under Iowa Const. art. I, 8 by searching her purse while she was a visitor present at the premises to be searched but where the search warrant made no motion of her. Prior to trial, Defendant filed a motion to suppress, which the district court denied. Defendant was subsequently found guilty of possessing marijuana. The Supreme Court reversed the district court’s ruling on the motion to suppress and remanded the case to the district court, holding (1) a search of the possessions of a third party at a residence is unconstitutional when the warrant does not support probable cause to search that particular person; and (2) under this court’s applicable caselaw, the search of Defendant’s purse could not be supported based on any of the State’s theories independent of the search warrant. View "State v. Brown" on Justia Law

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The Supreme Court reversed the judgment of the district court dismissing Appellant’s amended application for postconviction relief. In his application for postconviction relief, Appellant alleged that, pursuant to Iowa Code 822.2(1)(a), his sentence violated several of his civil rights under the United States and Iowa Constitutions. Specifically, Appellant asserted that the Iowa Department of Corrections (IDOC) violated his liberty interest in obtaining parole by failing to provide the sex offender treatment program (SOTP) in a timely manner. The district court found, as a matter of law, that Appellant had not stated a claim for postconviction relief under section 822.2(1)(a). The Supreme Court remanded the case, holding that Appellant should be given an opportunity to amend his application to seek relief under Iowa Code 822.2(1)(e). View "Belk v. State" on Justia Law

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The Supreme Court reversed the judgment of the district court denying Defendant’s motion to suppress evidence obtained after an officer stopped his vehicle for being on a county access road after hours. The district court determined that Defendant violated Iowa Code 350.5 by entering the county access area after hours, regardless of whether there was a sign posted to identify the county access area or the park hours. The Supreme Court disagreed, holding (1) the officer did not have probable cause or reasonable suspicion to stop Defendant’s vehicle when it was on the county access road after hours because, without a proper posting of the closing time, the officer did not have probable cause or reasonable suspicion to stop Defendant; and (2) therefore, the district court should have suppressed any drug evidence found in Defendant’s vehicle. View "State v. Scheffert" on Justia Law

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Iowa may constitutionally deny an inheritance tax exemption for bequests to stepchildren when the marriage between parent and stepparent was dissolved before the stepparent’s death, while granting an exemption when the marriage was not dissolved. The Supreme Court affirmed the judgment of the district court affirming the administrative ruling of the Iowa Department of Revenue denying an estate’s request for a tax refund. An administrative law judge rejected the decedent’s stepchildren’s protest challenging the denial of the tax refund on the ground that Iowa Code 450.1(1)(e)’s classification of stepchildren violated their equal protection rights under Iowa Const. art. I, 6. The district court affirmed the Department’s decision. The Supreme Court affirmed, holding that section 450.1(1)(e) does not violate article I, section 6 of the Iowa Constitution because a rational basis exists for the legislature to exclude stepchildren postdivorce from the inheritance tax exemption for surviving spouses lineal descendants, lineal ascendants, and other stepchildren. View "Tyler v. Iowa Department of Revenue" on Justia Law