Justia Civil Rights Opinion Summaries

Articles Posted in Iowa Supreme Court
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The Supreme Court affirmed Defendant's conviction of boating while intoxicated in violation of Iowa Code 462A.14(1), holding that Iowa Department of Natural Resources (DNR) officers had probable cause to stop Defendant's vessel. Two DNR officers were patrolling Lake Panorama, a recreational lake that was created by damming the Middle Raccoon River, when they stopped Defendant's pontoon boat for displaying blue lights in violation of Iowa Code 462A.12(4). The stop revealed that Defendant, the operator of the boat, appeared to be intoxicated. Defendant was charged with boating while intoxicated. Defendant filed a motion to suppress, arguing section 462A.12(4) did not apply because Lake Panorama was not "waters of this state under the jurisdiction of the conservation commission" and there was no probable cause for the stop. The district court denied the motion to suppress. The Supreme Court affirmed, holding that the officers had probable cause to stop the boat because Lake Panorama belongs to the people of Iowa and is not a privately owned lake as defined in section 462A.2(31). View "State v. Meyers" on Justia Law

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The Supreme Court affirmed the decision of the district court dismissing Appellant's application for postconviction relief (PCR) claiming a violation of his constitutional right to an impartial jury drawn from a fair cross section of the community, basing his claim on State v. Plain, 898 N.W.2d 801 (Iowa 2017), holding that the holding in Plain does not apply retroactively to cases on collateral review. In 1984, Appellant was convicted of first-degree murder. In 2017, the Supreme Court decided Plain, which addressed the Duren three-part test for evaluating Sixth Amendment fair-cross-section claims and overruled precedent adopting the absolute-disparity method as the exclusive indicator of representativeness under the second prong of Duren. In 2018, Appellant filed the instant PCR application, alleging that he was denied his rights to due process, equal protection, and a fair and impartial trial under the state and federal constitutions. Appellant based his claim on Plain. The district court granted the State's motion to dismiss, concluding that Plain is not retroactive. The Supreme Court affirmed, holding (1) Appellant's Plain claim is time-barred by Iowa Code 822.3; and (2) because Plain's holding is not a watershed rule of criminal procedure, it does not apply retroactively to cases on collateral review. View "Thongvanh v. State" on Justia Law

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The Supreme Court affirmed the decision of the postconviction relief (PCR) court dismissing Appellant's fourth PCR application, holding that under this Court's holding today in Thongvanh v. State, __ N.W.2d __ (Iowa 2020), Defendant's claims based on State v. Plain, 898 N.W.2d 801 (Iowa 2017), failed because Plain is not retroactive. In his PCR application Appellant alleged violations of his rights to equal protection and due process and his right to an impartial jury drawn from a fair cross section of the community. Appellant based his claims on Plain. The trial court granted the State's motion to dismiss, concluding that Plain does not apply retroactively. The Supreme Court affirmed, holding (1) the trial court improperly dismissed Appellant's application based upon a ground neither party raised; and (2) because the new law of criminal procedure announced in Plain does not apply retroactively to cases on collateral review Appellant's PCR application was properly dismissed. View "Jones v. State" on Justia Law

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The Supreme Court vacated the decision of the court of appeals reversing Defendant's conviction on the basis that the district court inadequately instructed the jury on Defendant's justification defense, holding that the court's failure to include "lack of justification" in the marshaling instruction was not prejudicial for ineffective assistance purposes. On appeal, Defendant argued that his trial counsel provided ineffective assistance for failing to object to the marshaling instruction, which did not mention that the State needed to prove the act was done without justification. The Supreme Court disagreed, holding that, in light of the evidence and the instructions as a whole, there was not a reasonable probability of a different outcome if justification had been covered in the marshaling instruction along with the other instructions. View "State v. Kuhse" on Justia Law

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The Supreme Court reversed the judgment of the district court granting Plaintiff's petition for mandamus and ordering the City of Ottumwa to disclose names of all persons who had and had not been issued automated traffic enforcement (ATE) citations by the City after their vehicles were detected as speeding by an ATE camera, holding that the district court erred in ordering the production of records whose disclosure was prohibited by the Driver's Privacy Protection Act of 1994 (DPPA), 18 U.S.C. 2721-2725, and a corresponding Iowa state law, Iowa Code 321.11. In denying the request for names, the City argued that the DPPA and section 321.11 prohibited disclosure of the requested information. The district court disagreed, concluding that the names of speed regulation violators was information on driving violations and therefore was not confidential information under the DPPA or section 321.11. The Supreme Court reversed, holding that where the personal identifying information sought by Petitioner came from a vehicle registration and driver's license database, its public disclosure was presumptively prohibited under the DPPA and section 321.11. View "Milligan v. Ottumwa Police Department" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court convicting Defendant of driving while intoxicated, holding that Defendant was not seized for purposes of the Fourth Amendment or Iowa Const. art. I, 8 when the officer approached Defendant on foot the evening of her arrest. An officer watched a vehicle driving suspiciously for several minutes in a residential neighborhood at night. When the vehicle entered a one-lane alley and did not emerge from the alley, the officer approached the stopped vehicle without activating flashers. The officer walked up to Defendant, the driver, to engage in a conversation, which resulted in the officer learning that Defendant was under the influence of alcohol. Defendant was convicted of driving while intoxicated. Defendant appealed, arguing that she was seized in violation of her rights under the Fourth Amendment and article I, section 8. The court of appeals affirmed, concluding that Defendant was not subjected to a seizure in the constitutional sense. The Supreme Court affirmed, holding that no seizure occurred under either the state or federal constitution. View "State v. Fogg" on Justia Law

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The Supreme Court affirmed in part and vacated in part the decision of the court of appeals reversing Defendant's conviction and remanding the case for a new trial, holding that trial counsel was not ineffective for failing to object to a jury instruction on the outdated version of the "stand your ground" justification and that the district court did not abuse its discretion in excluding character evidence of the victim. A jury found Defendant guilty of murder. During trial, Defendant asserted the justification of self-defense and defense of others. On appeal, the court of appeals held (1) the district court did not abuse its discretion in excluding certain character evidence of the victim, (2) there was sufficient evidence to support the conviction, but (3) the outdated justification instruction was prejudicial. The Supreme Court vacated the court of appeals' decision in part and affirmed the judgment of the district court, holding (1) trial counsel was not ineffective for not objecting to the instruction because engaging in an illegal activity disqualified Defendant from asserting stand-your-ground justification; and (2) the character evidence at issue was properly excluded because Defendant was unaware of the victim's specific conduct. View "State v. Baltazar" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction for sexual abuse in the second degree and lascivious acts with a child, holding that there was no error in the trial court's evidentiary rulings. Specifically, the Supreme Court held (1) the district court did not abuse its discretion in excluding certain evidence proffered by Defendant; (2) the district court did not err in admitting certain hearsay testimony under the medical diagnosis or treatment exception to the general rule; and (3) even if defense counsel breached an essential duty in failing to object to certain hearsay testimony the admission of the testimony did not amount to constitutional prejudice. View "State v. Walker" on Justia Law

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The Supreme Court reversed the judgment of the district court denying Defendant's motion to suppress all evidence stemming from a stop of his vehicle, holding that the district court erred in finding that the deputy developed reasonable suspicion of other criminal activity before unreasonably prolonging the stop. After Defendant was stopped for violating Iowa Code 321.297(2) the deputy asked Defendant and his passenger questions. Finding the answers suspicious, the deputy sought permission for a consent search. Defendant consented. After a search of the car, the deputy located more than eighty pounds of marijuana in the trunk. Defendant filed a motion to suppress the evidence, which the district court denied. The Supreme Court reversed, holding that the delay of Defendant's stop was measurable, unreasonable, and in violation of Defendant's Fourth Amendment rights. View "State v. Salcedo" on Justia Law

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The Supreme Court affirmed the district court's judgment convicting Defendant of first-degree murder, holding that Defendant's Sixth Amendment rights of confrontation or compulsory process were not violated when the district court refused to permit Defendant during trial to call a witness who intended to invoke his Fifth Amendment privilege against self-incrimination on all questions. In his retrial for murder, Defendant sought to call a witness so that the jury could him him "take the Fifth" and thus infer the witness's guilt. The district court refused to permit Defendant to call the witness because, pursuant to State v. Bedwell, 417 N.W.2d 66 (Iowa 1987), the jury is not entitled to draw inferences favorable to the defense from a witness's decision to exercise his constitutional privilege. The court of appeals reversed, distinguishing Bedwell on grounds that the witness had testified in Defendant's prior trial and the district court failed to ascertain the scope of his privilege question by question. The Supreme Court vacated the court of appeals' decision and affirmed the district court, holding (1) under the circumstances, Bedwell provides a categorical rule against compelling the witness to assert his Fifth Amendment privilege in front of the jury; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "State v. Heard" on Justia Law