Justia Civil Rights Opinion Summaries

At issue was whether the three-year statute of limitations in Iowa Code 822.3 applies where a postconviction relief (PCR) petitioner files an untimely second petition for PCR alleging that counsel for his timely filed first petition for PCR was ineffective.The district court concluded that the second petition’s allegations of ineffective assistance of postconviction counsel were not grounds to avoid the three-year statutory bar. The court of appeals affirmed, citing the Supreme Court’s decision in Dible v. State, 557 N.W.2d 881, 883, 886 (Iowa 1996).The Supreme Court qualified Dible and held that where a PCR petition alleging ineffective assistance of trial counsel has been timely filed per section 822.3 and there is a successive PCR petition alleging that postconvcition counsel was ineffective in presenting the ineffective-assistance-of-trial-counsel claim, the timing of the filing of the second PCR petition relates back to the timing of the filing of the original PCR petition for purposes of Iowa Code section 822.3 if the successive PCR petition is filed promptly after the conclusion of the first PCR petition. The Court therefore vacated the court of appeals and reversed the decision of the district court and remanded the case. View "Allison v. State" on Justia Law

The Supreme Court adopted a tighter legal framework for warrantless inventory searches and seizures of automobiles under Iowa Const. art. I, 8 than provided under the recent precedents of the United States Supreme Court.In his challenge to the search and seizure provision of article I, section 8 of the Iowa Constitution Defendant noted that a number of state courts have rejected the approach of the United States Supreme Court - which generally provides that warrantless inventory searches of automobiles are permissible if they are conducted pursuant to law enforcement policies that govern the decision to impound the vehicle and the nature and scope of any subsequent search - in favor of a more restrictive approach that sharply limits warrantless searches and seizures of automobiles.The Supreme Court ultimately held (1) the police should advise the owner or operator of the vehicle of the options to impoundment, and when impoundment is necessary, personal items may be retrieved from the vehicle, and if the vehicle is impounded, containers found within the vehicle will not be opened but stored for safekeeping as a unit unless the owner or operator directs otherwise; and (2) the impoundment and search in this case was outside the bounds of any constitutionally permissible local impoundment and inventory policy. View "State v. Ingram" on Justia Law

The Supreme Court declined to hold that the felony-murder rule violates due process under the Iowa or United States Constitution when it is applied to juvenile offenders pursuant to a theory of aiding and abetting.Defendant was a juvenile and unarmed when he participated in a marijuana robbery. A coparticipant, who had brought a gun to the crime, killed the robbery victim. Defendant was convicted of first-degree murder and sentenced to life imprisonment with immediate parole eligibility. The Supreme Court affirmed the conviction and sentence, holding (1) applying the felony-murder rule to juvenile offenders based on a theory of aiding and abetting is constitutional; (2) Defendant’s sentence did not constitute cruel and unusual punishment, either categorically or as applied to Defendant; (3) the trial court provided the jury with proper instructions regarding the types of assault required to establish the forcible felony robbery element of felony murder; and (4) the record was inadequate for the Court to address some of Defendant’s claims of ineffective assistance of counsel, and the remainder of Defendant’s ineffective assistance of counsel claims were without merit. View "State v. Harrison" on Justia Law

Under the Iowa Constitution, a community caretaking seizure of a vehicle must be undertaken for genuine community caretaking purposes. In this case, a law enforcement officer was justified under the “community caretaking function” exception to the warrant requirement of the Fourth Amendment and Iowa Const. art. I, 8 when he pulled behind a vehicle stopped by the side of a highway after 1 a.m. with its brake lights engaged and activated his emergency lights.Defendant was charged with operating while intoxicated, first offense. Defendant moved to suppress the evidence obtained as a result of the stop of his vehicle, arguing that the stop of his vehicle and person was unconstitutional. The trial court denied the motion. The Supreme Court affirmed, holding that the conduct of the deputy in this case was not unconstitutional because the officer acted out of a genuine community caretaking motivation. View "State v. Coffman" on Justia Law

Plaintiff could not prove the City discriminated against him because of his multiple sclerosis (MS) when the City was unaware he had MS.Plaintiff applied for a full-time job as a firefighter with the City of Marion. The City denied Plaintiff’s application after a physician reported that Plaintiff was not medically qualified for the position, but the physician did not inform the City that MS was the reason Plaintiff was found unfit for firefighting. Plaintiff later sued the City and the physician’s employer under the Iowa Civil Rights Act (ICRA) alleging disability discrimination. The district court granted summary judgment for all defendants. The Supreme Court affirmed, holding (1) without any requested accommodation by Plaintiff, the City had no duty to second-guess the physician that Plaintiff was medically unqualified for the position; and (2) the physician was not liable for aiding and abetting the discrimination without proof that the City intentionally discriminated against Plaintiff. View "Deeds v. City of Marion, Iowa" on Justia Law

Defendant was entitled to a new trial after the State limited his access to his personal funds by freezing his assets prior to trial.Defendant was convicted of attempted murder and willful injury causing serious injury. Before trial, the trial court granted the State’s application for an order freezing all of Defendant’s assets. The order granting the freeze did not cite any authority or legal basis for the asset freeze. After Defendant’s convictions were affirmed on appeal he filed a postconviction relief (PCR) application arguing that the order freezing his assets was illegal and imposed for an improper purpose. Defendant also argued that the asset freeze adversely impacted his ability to defend himself by, among other things, inhibiting his ability to select his counsel of choice. The PCR court denied relief, and the court of appeals affirmed. The Supreme Court reversed and remanded for a new trial, holding (1) the asset freeze was unlawful; (2) defense counsel’s failure to properly challenge the freeze breached an essential duty; and (3) the consequences of the asset freeze violated Defendant’s constitutional right to be master of his defense, a structural error. View "Krogmann v. State" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court granting summary judgment in favor of Defendants on Plaintiff’s claims challenging his termination.Plaintiff, a former chief administrative law judge of the Unemployment Insurance Appeals Bureau in Iowa Workforce Development (IWD), alleged retaliation under the whistleblower protection provisions of Iowa Code 70A.28 and that Defendants continued to retaliate against him when he sought other positions in state government. Plaintiff further alleged wrongful termination in violation of public policy based upon the same conduct. The district court granted summary judgment for Defendants, concluding that Plaintiff could not bring his claims because he failed to exhaust his administrative remedies available to merit employees. The Supreme Court reversed in part, holding (1) Plaintiff’s ability to bring a direct claim under section 71A.28 is not precluded by the availability of an administrative remedy under Iowa Code 8A.415; and (2) the district court correctly granted summary judgment on Plaintiff’s wrongful termination claim. View "Walsh v. Wahlert" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court granting summary judgment in favor of Defendants on Plaintiff’s claims challenging his termination.Plaintiff, a former chief administrative law judge of the Unemployment Insurance Appeals Bureau in Iowa Workforce Development (IWD), alleged retaliation under the whistleblower protection provisions of Iowa Code 70A.28 and that Defendants continued to retaliate against him when he sought other positions in state government. Plaintiff further alleged wrongful termination in violation of public policy based upon the same conduct. The district court granted summary judgment for Defendants, concluding that Plaintiff could not bring his claims because he failed to exhaust his administrative remedies available to merit employees. The Supreme Court reversed in part, holding (1) Plaintiff’s ability to bring a direct claim under section 71A.28 is not precluded by the availability of an administrative remedy under Iowa Code 8A.415; and (2) the district court correctly granted summary judgment on Plaintiff’s wrongful termination claim. View "Walsh v. Wahlert" on Justia Law

The equitable tolling doctrines of the discovery rule and equitable estoppel are available with respect to the 300-day filing limitation in the Iowa Civil Rights Act (ICRA).Plaintiff, an applicant for the position of Deputy Workers’ Compensation Commissioner at Iowa Workforce Development (IWD), brought a failure-to-hire claim against the IWD. The district court dismissed the claim, concluding that Plaintiff could not escape the 300-day filing requirement in the ICRA through application of the discovery rule or equitable estoppel. The Supreme Court affirmed, holding (1) the discovery rule and equitable estoppel apply to the 300-day filing limitation in the ICRA; but (2) Plaintiff was not entitled to toll the filing limitation through application of either the discovery rule or equitable estoppel. View "Mormann v. Iowa Workforce Development" on Justia Law

The equitable tolling doctrines of the discovery rule and equitable estoppel are available with respect to the 300-day filing limitation in the Iowa Civil Rights Act (ICRA).Plaintiff, an applicant for the position of Deputy Workers’ Compensation Commissioner at Iowa Workforce Development (IWD), brought a failure-to-hire claim against the IWD. The district court dismissed the claim, concluding that Plaintiff could not escape the 300-day filing requirement in the ICRA through application of the discovery rule or equitable estoppel. The Supreme Court affirmed, holding (1) the discovery rule and equitable estoppel apply to the 300-day filing limitation in the ICRA; but (2) Plaintiff was not entitled to toll the filing limitation through application of either the discovery rule or equitable estoppel. View "Mormann v. Iowa Workforce Development" on Justia Law