Justia Civil Rights Opinion Summaries

Articles Posted in Iowa Supreme Court
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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

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The Supreme Court vacated Defendant's sentence in connection with her Alford plea to four counts of child endangerment entered pursuant to a plea agreement, holding that the State breached the plea agreement with Defendant and that Defendant's original counsel was ineffective for failing to object. On appeal, Defendant argued that, pursuant to the plea agreement between the parties, the State was obligated to jointly recommend a deferred judgment. Instead, at the sentencing hearing, the State recommended, and the court imposed, a two-year suspended prison sentence without objection from defense counsel. The court of appeals affirmed Defendant's conviction and sentence. Thereafter, amendments to Iowa Code 814.6 and 814.7, enacted in Senate File 589, were signed into law and became effective. The State argued before the Supreme Court that Senate File 589 foreclosed relief in this appeal. The Supreme Court held (1) sections 814.6 and 814.7, as amended, do not apply to a direct appeal from a judgment and sentence entered before July 1, 2019; and (2) the State breached the plea agreement and Defendant's counsel was ineffective. The Supreme Court remanded the case for the State's specific performance of the plea agreement and resentencing by a different judge. View "State v. Macke" on Justia Law

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In this civil action filed against the police investigator, the prosecutors, and the municipalities that investigated and prosecuted a criminal case in which Plaintiff was eventually acquitted the Supreme Court affirmed in part and reversed in part the judgment of the district court denying Defendants' motions to dismiss, holding that the district court erred in concluding that Baldwin v. City of Estherville, 951 N.W.2d 259 (Iowa 2018), displaced the judicial process immunity. Specifically, the Court held (1) the district court erred in part in denying the prosecutor defendants' motion to dismiss because the judicial process immunity barred all claims in the petition against the prosecutors and the county except for a claim relating to an ethics complaint; and (2) the district court correctly denied the motion to dismiss with respect to the police defendants' argument regarding the judicial process immunity but erred in denying the police defendants' motion to dismiss Plaintiff's defamation claim. View "Venckus v. City of Iowa City" on Justia Law

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The Supreme Court affirmed in part and reversed in part the order of the district court granting summary judgment to Defendants on all claims in this employment case, holding (1) Plaintiff's direct civil action under Iowa Code 70A.28(5), the whistleblower statute, is not precluded by the availability of an administrative remedy; and (2) the district court correctly granted summary judgment on Plaintiff's claims of age discrimination and intentional infliction of emotional distress. Specifically, the Court held (1) section 70A.28(5) expressly creates an independent cause of action in the alternative to administrative remedies under Iowa Code chapter 17A, and therefore, the district court erred when it determined that judicial review following the administrative process was the exclusive means to seek redress for alleged retaliation against a whistleblower; (2) the district court did not err in determining that Plaintiff failed to present sufficient evidence from which a reasonable jury could infer age discrimination was the real reason for Plaintiff's termination; and (3) the district court did not err in granting summary judgment on Plaintiff's intentional infliction of emotional distress claim because none of Defendants' conduct was sufficiently egregious to satisfy the "outrageousness" prong. View "Hedlund v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence discovered by law enforcement after a stop of Defendant's automobile that resulted in her arrest for driving while barred, holding that the district court did not err in denying Defendant's motion to suppress. Specifically, the Court held (1) Defendant was not subject to an impermissible pretextual seizure because the subjective motivations of an individual officer in making a traffic stop are irrelevant as long as the officer has objectively reasonable cause to believe the motorist violated a traffic law; (2) Defendant's stop was supported by reasonable suspicion; and (3) Defendant's claim that her trial court provided ineffective assistance for declining to challenge whether the vehicle's license plate was malfunctioning failed on the merits. View "State v. Haas" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress all evidence obtained after a stop of his vehicle, holding that the subjective motivations of an individual officer for making a traffic stop are irrelevant as long as the officer has objectively reasonable cause to believe the motorist violated a traffic law. A police officer observed Defendant making an improper turn and, after following Defendant, noticed Defendant's vehicle had an improperly functioning license plate light. The vehicle information for the registered owner - who was not Defendant - revealed the registered owner's affiliation to gang activity. The officer pulled Defendant over and discovered Defendant's open beer container in the center cupholder. Defendant filed a motion to suppress, arguing that the stop was unconstitutional because the officer's reasons for the stop were not the traffic violations themselves. The Supreme Court affirmed, holding that traffic stops for traffic violations are reasonable regardless of the officer's subjective motivation. View "State v. Brown" on Justia Law

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The Supreme Court answered questions certified to it by the United States District Court for the Northern District of Iowa, holding, among other things, that a municipality can assert qualified immunity to a claim for damages for violation of the Iowa Constitution based on its officers' exercise of "all due care." Specifically, the Supreme Court held (1) the due care exemption under Iowa Code 670.4(1)(c) could provide the City immunity; (2) section 670.4(1)(e) precludes an award of punitive damages against the municipality that employed the constitutional tortfeasor; (3) in a Godfrey v. State, 898 N.W.2d (Iowa 2017), action a court cannot award attorney fees against the municipal employer of the constitutional tortfeasor unless there is a statute expressly allowing such an award; and (4) it is appropriate to retroactively apply this Court's conclusion that in a Godfrey action, common law attorney fees may be available against the municipal employer of the constitutional tortfeasor. View "Baldwin v. City of Estherville, Iowa" on Justia Law

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The Supreme Court reversed the judgment of the district court summary judgment for the State on Appellant's application for postconviction relief (PCR) after denying Appellant's request to appoint an expert, holding that the district court abused its discretion in denying the expert and that the summary disposition was erroneous. After a jury trial, Appellant was found guilty of first-degree murder. Appellant was sentenced to life imprisonment. In her petition for postconviction relief Appellant asserted, among other claims, that her trial counsel was ineffective for failing to raise battered woman syndrome (BWS) in her trial and for not adducing BWS evidence. To prove her claim, Appellant sought a court-appointed BWS expert. The district court denied Appellant's request to appoint an expert and, simultaneously, cited Appellant's failure to provide an expert in granting summary judgment. The Supreme Court reversed, holding that the summary disposition was erroneous where the court, among other errors, concluded that the record did not show facts to support Appellant's claim that BWS should have been raised at her trial. View "Linn v. State" on Justia Law

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In this case brought by a former employee alleging discrimination and retaliation, the Supreme Court reversed the judgment of the district court entering judgment on a jury verdict for Plaintiff, awarding him back pay, emotional distress damages, front pay and attorney fees, holding that the district court erred in admitting hearsay, and the hearsay was not harmless. Plaintiff, a terminated employee, brought this action against his former employer and the employer's agents under the Iowa Civil Rights Ac, alleging that Defendants discriminated against him because of his age and his status as a cancer patient and retaliated against him due to his refusal to retire or quit. The jury entered a verdict for Plaintiff. The Supreme Court reversed and remanded the case for a new trial, holding that the district court erred in admitting hearsay and the record failed to rebut the presumption of prejudice associated with the admitted hearsay evidence. View "Hawkins v. Grinnell Regional Medical Center" on Justia Law

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The Supreme Court vacated the decision of the court of appeals reversing Defendant's conviction of second-degree murder, holding that Defendant was not entitled to a new trial on any of his allegations of error. After trial, Defendant filed a motion for a new trial alleging, among other things, that the trial court erred in refusing to disqualify a juror who allegedly made out-of-court statements regarding Defendant's guilt and misconduct and bias related to extraneous information reaching the jury about a possible riot if a certain verdict was not returned. The district court denied the motions for a new trial and entered judgment. The court of appeals reversed, concluding that juror misconduct and bias warranted a new trial. The Supreme Court vacated the decision of the court of appeals and affirmed the district court judgment, holding that Defendant was not entitled to a new trial under the facts of this case. View "State v. Christensen" on Justia Law