Justia Civil Rights Opinion Summaries

Articles Posted in Iowa Supreme Court
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The Supreme Court dismissed Defendant's appeal challenging the factual basis supporting his guilty plea to a drug offense, holding that Defendant failed to establish good cause to pursue a direct appeal as a matter of right.Defendant pled guilty to three drug-related offenses and was sentenced to an indeterminate term of incarceration. On appeal, Defendant argued (1) there was not a factual basis supporting one of his convictions; (2) his counsel provided constitutionally ineffective assistance; and (3) Iowa Code section 814.6 and 814.7 are unconstitutional. The Supreme Court dismissed the appeal, holding (1) section 814.6(1)(a)(3) is constitutional and governs this appeal; and (2) Defendant did not establish good cause to pursue this appeal as a matter of right. View "State v. Treptow" on Justia Law

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The Supreme Court reversed Defendant's conviction of operating while intoxicated (OWI), holding that Mitchell v. Wisconsin, 588 U.S. __, __, 139 S. Ct. 2525 (2019) (plurality opinion), applies to cases of suspected driving while under the influence of controlled substances, in addition to alcohol-related cases.Defendant caused an accident while driving recklessly. Defendant, who was injured, was taken to the hospital strongly smelling of marijuana. A police officer dispatched to the hospital performed a blood test of Defendant, who was sedated, after a medical professional certified that Defendant was unable to consent or refuse blood testing. Defendant filed a motion to suppress the testing, but the motion was overruled. Defendant appealed, arguing that the warrantless blood draw violated Iowa Code 321J.7, the Fourth Amendment to the federal Constitution, and Iowa Const. art. I, 8. The Supreme Court reversed, holding (1) the State complied with section 321J.7; (2) because the parties did not have an opportunity to make a record under the Mitchell standard, the case must be remanded; and (3) article I, section 8 does not provide greater protection from warrantless blood draws than the Mitchell standard. View "State v. McGee" on Justia Law

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The Supreme Court dismissed Defendant's appeal challenging his guilty plea to theft in the second degree, holding that Defendant's challenge to the constitutionality of new legislation limiting his ability to appeal was unavailing.The legislation at issue limits the ability of a defendant to appeal as a matter of right from a conviction following a guilty plea and directs that ineffective assistance of counsel claims be presented and resolved in the first instance in postconviction relief proceedings. On appeal from his conviction of theft in the second degree Defendant argued that the new legislation violated his right to equal protection of then laws and the separation of powers doctrine. The Supreme Court affirmed, holding that Defendant's constitutional challenges failed. View "State v. Tucker" on Justia Law

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In this interlocutory appeal, the Supreme Court affirmed the order of the district court prohibiting Defendant from filing any additional pro se supplemental documents in a postconviction relief proceeding, holding that the district court did not err.Under Iowa Code 822.3A, postconviction relief applicants are prohibited from filing "any pro se document, including an application, brief, reply brief, or motion, in any Iowa court." At issue was the constitutionality of the law, which was passed in the spring of 2019 and effective July 1, 2019, to pending postconviction relief proceedings and postconviction relief appeals. Defendant in this case argued that section 822.3A violated his constitutional rights. The Supreme Court rejected the argument, holding that there is no constitutional right to file pro se supplemental documents in postconviction relief proceedings and postconviction appeals. View "Hrbek v. State" on Justia Law

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The Supreme Court reversed the judgment of the district court dismissing the trial information in this case, holding that the State's delay in arresting and formally charging Defendant did not amount to a due process violation.By late 2017, law enforcement had focused on Defendant as the suspected perpetrator of a robbery. However, the police did not file a criminal complaint against Defendant until August 2018 and did not serve an arrest warrant until September 2019. In October 2019, after it was finally filed, the district court dismissed the trial information, concluding that Defendant's due process rights under the Fifth Amendment were violated. The Supreme Court reversed, holding that the State's delay in arresting and charging Defendant did not violate the speedy indictment rule or violate due process where Defendant failed to show actual prejudice. View "State v. Smith" on Justia Law

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The Supreme Court reversed the judgment of the district court granting Defendant's motion to suppress physical evidence and statements based on a police officer's alleged promise of leniency, holding that there was no improper promise of leniency.The officer at issue initiated a Terry stop on a public stop after observing Defendant make a possible drug buy. The officer told Defendant if he cooperated he would not be arrested that day but may be arrested later. Three months after Defendant handed over crack cocaine and marijuana the officer charged him with possession. The trial court granted Defendant's motion to suppress, concluding that the evidence obtained after the officer promised leniency was fruit of the poisonous tree. The Supreme Court reversed, holding that the officer did not improperly promise leniency. View "State v. Hillery" on Justia Law

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The Supreme Court affirmed Defendant's conviction of driving while intoxicated (OWI), holding that defense counsel was not ineffective in declining to seek suppression of certain evidence on the basis that Defendant was subjected to an unconstitutional seizure.An officer observed Defendant illegally park her vehicle and stopped her to enforce the parking violation. Upon smelling marijuana and observing signs of Defendant's intoxication the officer inquired about her intoxication. The officer asked Defendant for her registration and insurance and discovered that her driver's license was revoked. Defendant was convicted of second-offense OWI and driving while license was revoked. The Supreme Court affirmed, holding (1) there was sufficient evidence to support Defendant's OWI conviction; and (2) Defendant's counsel was not ineffective in failing to seek suppression of the evidence because the officer had probable cause to seize Defendant based upon his observation of her traffic violation. View "State v. Warren" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress, holding that observations of a driver holding a phone in front of his face and actively manipulating the screen for at least ten seconds justified stopping the driver to resolve any ambiguity about whether the driver was violating Iowa Code 321.276.Section 321.276 allows drivers to use cell phones for some limited purposes while prohibiting most others. Defendant was stopped when officers believed he might be violating the statute. In his motion to suppress, Defendant argued that the officers lacked reasonable suspicion that Defendant was committing a traffic violation. The district court denied the motion. The Supreme Court affirmed, holding that the officers had reasonable suspicion Defendant was violating section 321.276 to support an investigatory stop. View "State v. Struve" on Justia Law

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The Supreme Court affirmed Defendant's conviction and sentence for operating while intoxicated first offense, holding that a peace officer does not violate a duty under Iowa Code 321J.11(2) by agreeing to a detainee's request for a retest on the machine that has already tested the detainee's blood alcohol level without also informing the detainee of the statutory right to an independent test at the detainee's expense.Specifically, the Supreme Court held (1) an officer must inform the detainee of the right to an independent test only in circumstances when the detainee has reasonably asked about that right or when a failure to disclose that right could be misleading; and (2) because neither of those circumstances were present in this case, the district court did not err in denying Defendant's motion to suppress. View "State v. Casper" on Justia Law

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The Supreme Court affirmed Defendant's convictions and sentences for eluding while speeding and several unrelated offenses, holding that trial counsel was not ineffective for failing to challenge Defendant's eluding charge on double jeopardy grounds based on his guilty plea to speeding in the same incident.At age seventeen, Defendant pled guilty to a speeding citation without pleading guilty to the accompanying charge of eluding. When Defendant turned eighteen, the State charged him by trial information with eluding while speeding. Defendant pled guilty to the eluding charge. The court of appeals affirmed. The Supreme Court affirmed, holding (1) speeding is a lesser included offense that at trial would merge into a conviction for eluding while speeding, but under the circumstances of this case, Defendant cannot use double jeopardy principles as a sword to defeat his conviction for eluding; and (2) therefore, Defendant's ineffective assistance of counsel claims fail. View "State v. Roby" on Justia Law