Justia Civil Rights Opinion Summaries

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

Assertion of the Fifth Amendment privilege against self-incrimination excuses compliance with forfeiture threshold pleading requirements in Iowa Code 809A.13(4)(d), such as identifying the source of cash.Claimants’ property was seized after a drug interdiction traffic stop. The State sought forfeiture of the impounded vehicle and money discovered in a hidden compartment after issuance of a search warrant. Claimants sought return of the cash and vehicle but their pleadings omitted information required by section 809A.13(4)(d). The district court dismissed the driver’s claims for noncompliance with the statute’s pleading requirements. Following months of litigation, the State consented to return of the vehicle to the owner. The district court denied the owner’s claim for attorney fees. The Supreme Court remanded, holding (1) the district court erred by failing to rule on Claimants’ motions to suppress before adjudicating the forfeiture claims and erred by overruling Fifth Amendment objections to the pleading requirements; and (2) the vehicle owner was a prevailing party entitled to recover his reasonable attorney fees under the forfeiture statute. View "In re Property Seized from Jean Carlos Herrera and Fernando Rodriguez" on Justia Law

The Supreme Court reversed the district court’s decision granting postconviction relief to Defendant on his claim that he had received ineffective assistance of counsel from an immigration attorney when he tried to get a driver’s license, holding that no right to counsel had attached when Defendant went to the driver’s license station.Defendant’s visit to the driver’s license station triggered a criminal investigation and ultimately a conviction for a previously committed fraudulent practice. The district court set aside Defendant’s guilty plea and sentence, holding that Defendant’s counsel, who was representing Defendant in a pending federal immigration case, breached his essential duty to provide necessary advice to Defendant. The Supreme Court reversed, holding that neither the right to counsel under Iowa Const. art. I, 10, nor the United States Constitution Sixth Amendment right to counsel had attached at the time Defendant’s attorney advised Defendant regarding getting a driver’s license, as this was before any investigation or criminal proceedings had begun. View "Hernandez-Ruiz v. State" on Justia Law

The Supreme Court reversed the decision of the district court denying Employer’s motion for summary judgment on Employee’s lawsuit filed under the Iowa Civil Rights Act (ICRA) alleging that Employer discriminated against him based on his age, sex, and national origin.Matthew Jahnke, an employee of Deere & Co., worked as a factor manager at Harbin Works in Harbin, China under a contract with a Deere Chinese subsidiary. As discipline for Jahnke engaging in sexual relationships with two Chinese employees, Jahnke was ultimately removed as the factor manager, repatriated back to the United States, and assigned to a position of lesser authority and lower pay in Waterloo, Iowa. Jahnke filed suit under the ICRA. In its motion for summary judgment, Deere claimed that the ICRA did not apply extraterritorially and that Jahnke based his claims on allegations of discriminatory acts that occurred outside of Iowa. The district court denied the motion. The Supreme Court reversed, holding (1) the ICRA does not apply extraterritorially; and (2) because Jahnke failed to show that either he or Deere was located within Iowa for purposes of the alleged discriminatory act, Jahnke had no claim under the ICRA. View "Jahnke v. Deere & Co." on Justia Law

At issue was whether the district court erred in not ordering a competency examination and in excluding evidence when Defendant’s lawyer moved midtrial for the examination of Defendant, who, among other things, stated that she wanted to stab her lawyer in the neck and wanted to kill him.Defendant was charged with willful injury causing bodily injury. During trial, the district court excluded evidence relating to the victim’s prior threatening behavior and her convictions for two assaults and an escape as more prejudicial than probative. Also during trial, Defendant’s attorney moved for a competency examination of Defendant, stating that Defendant was incapable of aiding him in her defense due to Defendant’s paranoid schizophrenia. The district court denied the motion, and Defendant was convicted. The Supreme Court reversed, holding (1) the district court was presented with sufficient reason to order a competency evaluation under Iowa Code 812.3; and (2) the district court properly excluded the challenged evidence about the victim as being substantially more prejudicial than probative. View "State v. Einfeldt" on Justia Law

In this appeal, Appellant, who at age thirteen shot and killed his mother, raised challenges to Iowa’s youthful offender laws. Specifically, he argued (1) Iowa Code 232.45(7)(a) does not provide statutory authority to try a thirteen-year-old as a youthful offender, (2) Iowa Code 232.45(7) and Iowa Code 907.3A constitute unconstitutional cruel and unusual punishment, and (3) the sentencing court abused its discretion by incarcerating him. The Supreme Court affirmed Appellant’s conviction as a youthful offender and his fifty-year indeterminate sentence with immediate parole eligibility, holding that the district court did not abuse its discretion in sentencing Appellant to a prison term rather than releasing him on probation or placing him in a transitional facility based on an individualized assessment of Defendant under a constitutional statutory scheme. View "State v. Crooks" on Justia Law