Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the evidentiary ruling of the district court and grant of summary judgment in favor of Medical School on Student's complaint that Medical School failed to accommodate her mental disability under the Iowa Civil Rights Act, Iowa Code chapter 216, holding that the district court properly declined to impute a staff psychotherapist's knowledge of Student's depression to Medical School's academic decision-makers and that the failure-to-accommodate claim failed as a matter of law.Student was treated for depression by the psychotherapist during the school year but did not consent to allow the psychotherpiast to discuss her depression with the faculty. Medical School eventually expelled Student based on her failing grades and lack of academic promise. In this complaint, Student filed an evidentiary motion to impute her psychotherapist's knowledge of her depression to the school's academic decision-makers. The district court denied the motion after applying statutory confidentiality requirements for mental health information. The court then granted Medical School summary judgment on Student's failure-to-accommodate claim. The Supreme Court affirmed, holding (1) the district court correctly ruled that confidential information the psychotherapist learned while treating Student was not imputed to Medical School; and (2) Medical School adequately engaged in the interactive process. View "Slaughter v. Des Moines University College of Osteopathic Medicine" on Justia Law

The Supreme Court affirmed Defendant’s convictions but vacated certain portions of Defendant’s sentences, holding that the imposition of a surcharge violated the Ex Post Facto Clauses of the state and federal constitutions and that the district court erroneously ordered restitution without determining Defendant’s reasonable ability to pay.Defendant pled guilty to lascivious acts with a child and sexual exploitation of a minor. On appeal, Defendant argued that the district court failed to comply with Iowa R. Crim. P. 2.8(2)(b) in accepting his guilty pleas, did not adequately inquire into an alleged communication breakdown in the attorney-client relationship, violated the Ex Post Facto Clauses by imposing a surcharge, and erred in ordering restitution without first determining his reasonable ability to pay. The Supreme Court held (1) Defendant did not preserve error on his guilty pleas challenge; (2) the record on appeal was insufficient to conduct an ineffective assistance of counsel analysis and to determine whether the district court adequately inquired into the alleged communication breakdown; and (3) the surcharge and restitution were erroneously imposed. View "State v. Petty" on Justia Law

The Supreme Court affirmed Defendant’s convictions for willful injury causing bodily injury and kidnapping in the first degree but vacated the restitution portion of the sentencing order and remanded the case to the district court to order restitution in a manner consistent with this opinion, holding that the restitution order did not comply with restitution law.Specifically, the Court held (1) substantial evidence supported Defendant’s conviction for first-degree kidnapping; (2) Defendant was not prejudiced when the court instructed the jury on a lesser included charge of kidnapping in the second degree; (3) this Court cannot reach Defendant’s ineffective assistance of counsel claims; and (4) the lower court’s finding that Defendant had the reasonable ability to pay and ordering restitution for certain items without having the amount of each item of restitution before it was contrary to the statutory scheme as outlined in this opinion. View "State v. Albright" on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that challenged portions of Iowa Administrative Code rule 441-78.1(4) violate the Iowa Civil Rights Act (ICRA) and determining that the Iowa Department of Human Services’ (DHS) denial of Medicaid coverage for gender-affirming surgeries was reversible, holding that the rule violates the ICRA’s prohibition against gender-identity discrimination.At issue was the language of rule 441-78.1(4) pertaining to the exclusion of Iowa Medicaid coverage of surgical procedures related to “gender identity disorders” violated the ICRA or the Iowa Constitution’s equal protection clause. The district court concluded that the challenged portions of the rule violated both the ICRA and the Constitution and that the DHS’s denial of Medicaid coverage for gender-affirming surgeries would result in a disproportionate negative impact on private rights and that the decision was unreasonable, arbitrary, and capricious. The Supreme Court affirmed, holding (1) rule 441-78.1(4)’s exclusion of Medicaid coverage for gender-affirming surgery violates the ICRA as amended by the legislature in 2007; and (2) under the doctrine of constitutional avoidance the Court did not address the constitutional claim. View "Good v. Iowa Department of Human Services" on Justia Law

The Supreme Court affirmed the judgment of the district court vacating an award of fees incurred during agency proceedings under a fee-shifting provision in Division II of the Davenport Civil Rights Ordinance for a housing discrimination violation charged under Division III that lacked a corresponding fee-shifting remedy, holding that that the district court correctly denied an award of attorney fees.A tenant filed a complaint with the Davenport Civil Rights Commission alleging discrimination based on familial status in violation of the Davenport Civil Rights Ordinance and the Federal Fair Housing Act (FHA). An administrative law judge found that the landlord committed a Division III fair housing violation and award the tenant both damages and attorney fees and costs. The Commission approved the ALJ’s decision. The district court reversed the damages award and vacated the fee award. The court of appeals reinstated the fee award. The Supreme Court held that the court of appeals erred in awarding attorney fees because (1) the fee-shifting provision in Division II of the Ordinance was inapplicable to the fair housing violation in Division III; and (2) the Commission could not award fees under the FHA. View "Seeberger v. Davenport Civil Rights Commission" on Justia Law

The Supreme Court affirmed Defendant’s conviction of operating while intoxicated (OUI), second offense, holding that Defendant’s rights under Iowa Code 804.20 were not violated when a law enforcement officer denied Defendant’s request to call his wife until after sobriety testing occurred.Defendant was driving a motor vehicle when he was involved in an accident in the midst of a snowstorm. Because of the weather conditions, the law enforcement officer that responded to the scene transported Defendant to a protected location - the sally port of the nearby law enforcement center - for the completion of field sobriety testing. Before leaving the scene, Defendant asked to talk to his wife, but the request was denied. Defendant subsequently failed field sobriety tests. Defendant was later convicted of OUI. Defendant appealed, arguing that his rights were violated because he had been “restrained of his liberty” within the meaning of section 804.20 at the sally port. The Supreme Court affirmed, holding that Defendant’s rights under section 804.20 were not violated when the officer refused to allow Defendant the opportunity to speak with his wife until after field sobriety testing had been completed at the sally port because the sally port was a location for testing, not a “place of detention” within the meaning of section 804.20. View "State v. Davis" on Justia Law

The Supreme Court affirmed the judgment of the district court sentencing Defendant to prison for a maximum of ten years for theft in the first degree, to be served consecutively with five years for theft in the second degree, holding that Defendant failed to preserve his due process claim for direct appeal and that this Court could not reach Defendant’s ineffective assistance of counsel due process claim on direct appeal for the reasons stated in State v. Gordon, __ N.W.2d __ (Iowa 2018), also decided today.On appeal, Defendant argued that the district court violated his due process rights by using an Iowa Risk Revised assessment report (IRR) in sentencing. In the alternative, Defendant argued that the court abused its discretion by considering the IRR without understanding the contours of the IRR. Defendant further asserted an ineffective assistance of counsel claim. The Supreme Court affirmed for the reasons set forth in Gordon. View "State v. Buesing" on Justia Law

The Supreme Court vacated the decision of the court of appeals finding that there is no legislative authority supporting the use of the Iowa Risk Revised risk assessment tool (IRR) at sentencing and affirmed the decision of the district court, holding that the court’s use of the IRR in sentencing Defendant did not violate his due process rights.Defendant pled guilty to burglary in the second degree as part of a plea agreement. Defendant later violated the conditions of release and pled guilty to the additional charge of interference with official acts. The presentence investigation report stated that the interviewer completed an IRR, which recommended that Defendant be supervised at an intensive level. The district court sentenced Defendant to prison for an indeterminate term, not to exceed ten years plus ninety days in jail, to be served concurrently with the burglary sentence. The court of appeals vacated the sentence. The Supreme Court vacated the court of appeals and affirmed the judgment of the district court, holding (1) the court did not infringe on Defendant’s due process rights based on its use of the IRR at sentencing; and (2) the court did not abuse its discretion by discussing an unproven or unprosecuted offense. View "State v. Guise" on Justia Law

The Supreme Court vacated the decision of the court of appeals reversing Defendant’s sentence and affirmed the judgment of the district court, holding that Defendant failed to preserve error on his due process claim and that the district court did not use an unproven or unprosecuted offense when it sentenced Defendant.Defendant pled guilty to third-degree sexual abuse. As part of the presentence investigation, Defendant underwent a psychosexual evaluation, resulting in a psychosexual assessment report. The district court ultimately sentenced Defendant to a prison term not to exceed ten years. The court of appeals reversed, holding the the legislature has not deemed sex offender risk assessment tools relevant in imposing prison sentences. The Supreme Court vacated the court of appeals and affirmed the district court’s sentence, holding (1) the district court did not violate Defendant’s due process rights by consideration of and reliance on the sex offender risk assessment tools in imposing its sentence; and (2) the district court did not abuse its discretion by relying on an unproven or unprosecuted offense. View "State v. Gordon" on Justia Law

The Supreme Court affirmed the decision of the district court denying Appellant’s application for postconviction relief (PCR), holding that Appellant’s requested remand for a new hearing was not available and that Appellant’s claim that his postconviction counsel was ineffective must be brought in a separate application for PCR.In his application for PCR Appellant sought to vacate his conviction based on newly discovered evidence. The district court denied the PCR application and rejected Appellant’s ineffective assistance of counsel claim. On appeal, Appellant argued that the district court improperly dismissed his PCR application because his postconviction counsel failed to present physical evidence at the PCR hearing to support his claim. Therefore, Appellant asked that his PCR application be remanded to the district court for a new hearing. The Supreme Court affirmed, holding that no error occurred, that the request made to remand the case failed, and that Appellant must raise his claim of ineffective assistance of postconviction counsel in a separate application for PCR. View "Goode v. State" on Justia Law