Justia Civil Rights Opinion Summaries
Articles Posted in Iowa Supreme Court
State v. DeSimone
After a jury trial, Defendant was convicted of third-degree sexual abuse. Six years later, the Supreme Court overturned Defendant's conviction and sentence and remanded for a new trial. The second trial resulted in Defendant's acquittal. Defendant subsequently filed an application to be declared a wrongfully imprisoned individual pursuant to Iowa Code 663A.1. The district court granted the application. The State appealed. The Supreme Court reversed and remanded, holding (1) Defendant was eligible to bring a wrongful imprisonment claim when he was acquitted on retrial; (2) the district court erred by failing to consider testimony that had been presented at Defendant's two criminal trials in making the wrongful imprisonment determination, even though the State did not show the witnesses were no longer available; and (3) while substantial evidence supported the district court's finding of innocence on the existing record, a remand was necessary for the court to consider the full record, including the prior testimony. View "State v. DeSimone" on Justia Law
Iowa Supreme Court Attorney Disciplinary Bd. v. Attorney Doe No. 762
The Iowa Supreme Court Attorney Disciplinary Board filed a complaint against Attorney Doe based on sexual misconduct allegations by the attorney's client, Jane Doe. The Grievance Commission of the Iowa Supreme Court scheduled a hearing on the matter. Jane's attorney requested a continuance of the scheduled hearing so that she could be present when Jane testified before the Commission. The Commission President quashed Jane's attorney's appearance and denied her request for a continuance, stating that witnesses testifying before the Commission were not entitled to have an attorney present during the proceedings and that that absence of Jane's attorney from the hearing would cause no unfairness to Jane. The Supreme Court reversed the Commission's order, holding that a person called upon to be a witness before the Commission may be represented by counsel for the limited purpose of protecting rights personal to the witness in the proceeding. View "Iowa Supreme Court Attorney Disciplinary Bd. v. Attorney Doe No. 762" on Justia Law
State v. Thompson
After a jury trial, Defendant was convicted of the second-degree murder of his live-in girlfriend. The Supreme Court affirmed, holding that the district court did not reversibly err by (1) failing to submit an instruction on the lesser included offense of voluntary manslaughter, as the evidence of provocation was insufficient to support admission; (2) excluding hearsay evidence relevant to Defendant's diminished-capacity defense based on his posttraumatic stress disorder, as Defendant failed to lay a foundation supporting any exception to the hearsay rule; (3) declining to obtain and review the victim's mental health records for exculpatory information; and (4) denying Defendant's motion for a new trial. View "State v. Thompson" on Justia Law
State v. Neiderbach
After a jury trial, Defendant was convicted of six counts of child endangerment and sentenced to fifty years in prison. The victim was Defendant's seven-week-old son. The baby suffered fifteen rib fractures, a broken arm, and a permanent brain injury over a three-week period. The victim's mother (Mother) pled guilty to child endangerment. On appeal, the Supreme Court (1) vacated Defendant's convictions as to two counts for the baby's broken ribs, holding that the evidence was insufficient to sustain the convictions; (2) reversed the trial court's denial of Defendant's motion for an in camera review of Mother's mental health records under Iowa Code 622.10(4), a statute the Court upheld as constitutional; and (3) otherwise affirmed. View "State v. Neiderbach" on Justia Law
Jones v. Univ. of Iowa
Plaintiff was terminated from his employment as dean of students and vice president of student services at the University of Iowa by the University's president, Sally Mason, after a report from the Stolar Partnership (Stolar), a law firm retained by the Board of Regents (Regents) to investigate the University's response to a sexual assault of a student athlete by other student athletes, came out highly critical of Plaintiff. Plaintiff sued the University, Mason, the Regents, and Stolar for wrongful termination and related causes of action. The district court granted summary judgment for Defendants on all claims. The Supreme Court affirmed, holding that the district court did not err (1) in denying Plaintiff's motion to compel discovery of written communications between Stolar and the Regents based on its finding that the attorney-client privilege protected the communications from disclosure; and (2) in granting summary judgment to Defendants on Plaintiff's various claims. View "Jones v. Univ. of Iowa" on Justia Law
State v. Ragland
Following a jury trial, Defendant, a juvenile, was convicted of first-degree murder and mandatorily sentenced to life without parole. Defendant subsequently pursued numerous postconviction relief actions, including an application to correct his sentence. After the Supreme Court remanded the case to the district court to consider the constitutionality of Defendant's sentence, the U.S. Supreme Court decided Miller v. Alabama, which held that the constitution prohibited a sentencing scheme mandating life in prison without possibility of parole for juvenile offenders. Before Defendant's hearing, the Governor commuted Defendant's sentence to life with no possibility for parole for sixty years. At the hearing before the district court, Defendant argued he should still be resentenced under Miller. The district court (1) concluded that the Governor exceeded his authority by commuting Defendant's sentence because the commutation circumvented the individualized sentencing required under Miller, and (2) resentenced Defendant to life in prison with the possibility of parole after twenty-five years. The Supreme Court affirmed, holding (1) Defendant's commuted sentence still amounted to cruel and unusual punishment; and (2) consequently, the district court properly resentenced Defendant in light of Miller. View "State v. Ragland" on Justia Law
State v. Pearson
After a jury trial, seventeen-year-old Defendant was convicted of two counts of first-degree robbery and two counts of first-degree burglary. The district court imposed a fifty-year sentence, of which Defendant was required to serve thirty-five years, at which point she would become eligible for parole. The Supreme Court vacated Defendant's sentence, holding (1) Defendant's sentence of a minimum of thirty-five years without the possibility of parole for the crimes involved in this case violated the core teachings of Miller v. Alabama; and (2) an individualized sentencing hearing was required in this case. Remanded.
View "State v. Pearson" on Justia Law
State v. Null
Pursuant to a plea agreement, Defendant pleaded guilty to second-degree murder and first-degree robbery. Defendant was sixteen years old at the time he committed the offenses. The district court imposed a seventy-five-year aggregate sentence, of which Defendant was required to serve 52.5 years. Defendant's alleged actions took place before the Supreme Court's decision in Miller v. Alabama. On appeal, the Supreme Court affirmed Defendant's convictions but vacated his sentence, holding (1) Defendant's 52.5-year minimum prison term triggered the protections to be afforded under Miller - namely, an individualized sentencing hearing to determine the issue of parole eligibility; and (2) a district court must recognize and apply the core teachings of Roper v. Simmons, Graham v. Florida, and Miller in making sentencing decisions for long prison terms involving juveniles. Remanded. View "State v. Null" on Justia Law
Nelson v. Knight
Dentist fired his long-time female dental assistant (Employee) at the request of his wife after she discovered Dentist and Employee had been texting. Wife claimed Employee "was a big threat" to the marriage. Employee subsequently brought this action against Dentist, alleging that he discriminated against her on the basis of sex. The district court granted summary judgment for Dentist, concluding that Employee was not fired because of her gender but because she was a threat to Dentist's marriage. The Supreme Court affirmed, holding that Dentist did not engage in unlawful gender discrimination in violation of the Iowa Civil Rights Act when he fired Employee at the request of his wife. View "Nelson v. Knight" on Justia Law
State v. Finney
Defendant pleaded guilty to attempted murder and was sentenced to twenty-five years in prison. Defendant appealed, claiming his counsel provided ineffective assistance because counsel permitted him to plead guilty without an established factual basis for each element of the crime. The court of appeals vacated Defendant's conviction and sentence and remanded the case, concluding that the guilty plea colloquy failed to establish a factual basis for the underlying charge. The Supreme Court vacated the court of appeals' decision and affirmed the conviction and sentence of the district court, holding that the minutes of testimony provided an adequate factual basis to support Defendant's guilty plea. View "State v. Finney" on Justia Law