Articles Posted in Iowa Supreme Court

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In this employment discrimination case, prejudicial errors in four jury instructions required a new trial. Plaintiff filed claims against her former employer, alleging sexual harassment and retaliation under the Iowa Civil Rights Act (ICRA). The jury returned a verdict for Plaintiff on both counts and awarded damages in the amount of $1.4 million. Employer then filed a motion for new trial, which the district court denied. The Supreme Court reversed, holding (1) workers may bring a direct-liability negligence claim under the ICRA against an employer for supervisor harassment, but the plaintiff must prove that the employe knew or should have known of the harassment and failed to take prompt and appropriate remedial action to end it; (2) the district court did not abuse its discretion in admitting expert testimony on legal standards; but (3) the district court misinstructed the jury in four jury instructions, necessitating a new trial. View "Haskenhoff v. Homeland Energy Solutions, LLC" on Justia Law

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Defendant did not have a right to counsel under Iowa Const. art. I, section 10 when he voluntarily participated in a noncustodial police interview under the supervision of an Iowa county attorney even though the State’s criminal investigation was focusing on Defendant as the primary suspect at the time. Defendant was found guilty of murder in the first degree. During trial, the district court instructed the jury that it could infer Defendant acted with malice aforethought from his use of a baseball bat. The jury found Defendant killed the victim without justification and with malice aforethought. The court of appeals affirmed the judgment and sentence. The Supreme Court affirmed, holding (1) the level of prosecutorial involvement at the time of the interview did not create a prosecution or case that would trigger the right to counsel under article I, section 10; and (2) the jury could properly infer malice aforethought from Defendant’s use of a deadly weapon even though Defendant did not bring the weapon to the encounter. View "State v. Green" on Justia Law

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The Supreme Court reversed Defendant’s conviction for domestic abuse assault, third offense, and remanded this case for a new trial, holding that Defendant received ineffective assistance of counsel because his trial counsel failed to request a jury instruction defining “household member.” The court thus vacated the decision of the court of appeals, which affirmed the conviction over a dissent. The majority concluded that defense counsel had breached an essential duty by failing to request the definition instruction but that Defendant failed to show prejudice because the State had presented sufficient evidence of cohabitation. The Supreme Court held (1) because the central issue at trial was whether Defendant and the victim had been cohabitating, the jury should have been given the definition instruction, which accurately set forth the factors bearing on that issue; and (2) therefore, defense counsel’s failure to request the instruction was prejudicial, necessitating a new trial. View "State v. Virgil" on Justia Law

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Appellant pled guilty to one count of third-degree sexual abuse as the result of a sex act that occurred involving Appellant, who was seventeen years old, and T.C., who was thirteen years old. On appeal, Appellant argued that his lifetime special sentence of parole and the lifetime requirement that he register as a sex offender violated the cruel and unusual punishment and due process clauses of the United States and Iowa Constitutions. The court of appeals affirmed. The Supreme Court affirmed, holding that Appellant’s lifetime special sentence and lifetime registration requirement were not cruel and unusual punishment because a juvenile offender can petition the Iowa Department of Corrections for discharge from both the special sentence and the registration requirement. View "State v. Graham" on Justia Law

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A Dubuque civil rights ordinance exempts “any employer who regularly employs less than four individuals.” The former employee of Appellant, a landscaper whose hiring needs fluctuate seasonally, filed a complaint with the Dubuque Human Rights Commission (DHRC) alleging discrimination in violation of the ordinance. The DHRC found in favor of the employee. Appellant filed a petition for judicial review arguing that it did not employ the requisite number of employees to be subject to the ordinance. The district court affirmed the DHRC’s decision and upheld the damages awarded to the employee. The Supreme Court affirmed, holding (1) the DHRC correctly determined that Appellant “regularly employed” the requisite four or more individuals during its landscaping season; (2) the DHRC properly used a payroll approach and rejected Appellant’s proposed twenty-week test; and (3) substantial evidence supported the DHRC’s findings. View "Simon Seeding & Sod, Inc. v. Dubuque Human Rights Commission" on Justia Law

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Deputy Dan Furlong prepared a warrant application to search a residence. The detective brought the application before a judicial officer and, without signing the application, orally swore to the trust of the application in the presence of the judicial officer. The judicial officer approved and signed the warrant. After the warrant was executed Defendants were charged with several drug charges. Defendants moved to suppress the results of the search based on the detective’s failure to sign the warrant application. The district court granted the motions to suppress. The Supreme Court reversed, holding (1) Iowa Code 808.3 permits the warrant applicant to swear to the truth of the warrant application in the presence of the judicial officer even if, inadvertently, the applicant fails to sign it; and (2) in this case, the issuance of the warrant complied with section 808.3. View "State v. Angel" on Justia Law

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Defendant appealed his convictions and sentences following two bench trials, challenging the underlying searches in each of the two cases. Specifically, Defendant argued that the district court erred in denying his motions to suppress firearms and drugs seized by his stepfather, a police officer with the Davenport Police Department, while his stepfather was off duty. Defendant argued that the searches were unconstitutional because his stepfather conducted the searches while exercising state action as a law enforcement official. The district court denied each motion to suppress. After bench trials, Defendant was found guilty of the charges. The Supreme Court affirmed the denial of the motions to suppress, holding that Defendant’s off-duty police officer stepfather was acting in his private capacity, and not in his governmental capacity as a law enforcement officer, when he conducted the searches of Defendant’s person and vehicle. View "State v. Brown" on Justia Law

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After a jury trial, Defendant was convicted of going armed with intent and willful injury causing bodily injury. Defendant appealed, arguing that defense counsel provided ineffective assistance by failing to challenge the sufficiency of the evidence supporting submission of the going-armed-with-intent charge to the jury and failing to object to the jury instruction on going armed with intent on the ground that it omitted an element of the charged offense. The Supreme Court reversed, holding (1) defense counsel was not ineffective in failing to challenge the sufficiency of the evidence; but (2) defense counsel breached a duty in failing to object to the marshaling instruction for the going-armed-with-intent offense, and Defendant suffered prejudice as a result. Remanded. View "State v. Harris" on Justia Law

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In 2004, Gary Pettit pled guilty to third-degree sexual abuse and third-degree kidnapping, Pettit was incarcerated at the Anamosa State Penitentiary. In 2015, the Iowa Department of Corrections (IDOC) informed Pettit that he would be required to complete sex offender treatment. After a sex offender treatment program (SOTP) classification hearing, an administrative law judge (ALJ) affirmed the classification decision, concluding that Pettit was required to complete the SOTP. Pettit filed a petition for judicial review, claiming that the IDOC violated his due process rights by refusing to allow him access to counsel during the classification hearing. The district court determined that Pettit was entitled to counsel at the hearing. The Supreme Court vacated the judgment of the district court and remanded, holding that the district court did not have authority to review the classification hearing under Iowa Code chapter 17A. Remanded for dismissal of Pettit’s petition for judicial review. View "Pettit v. Iowa Department of Corrections" on Justia Law

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Defendant was charged with driving while barred. Defendant filed a motion to suppress, which the district court denied. Defendant was subsequently convicted. Defendant appealed the denial of his motion to suppress, arguing that a law enforcement officer, after making a valid traffic stop supported by reasonable suspicion that an offense may being committed, must terminate the stop when the underlying reason for the stop is no longer present. The Supreme Court agreed with Defendant and reversed, holding (1) when the reason for a traffic stop is resolved and there is no other basis for reasonable suspicion, Iowa Const. art. I, 8 requires that the stop must end; and (2) consequently, the law enforcement officer that stopped Defendant in this case violated Defendant’s rights under the Iowa Constitution. View "State v. Coleman" on Justia Law