Justia Civil Rights Opinion Summaries

The State charged Defendant by way of trial information of "assault domestic abuse causing bodily injury - enhanced" and "assault domestic abuse by use or display of a weapon." At the close of evidence during the trial, the State moved to amend the trial information to add a habitual offender enhancement. Defendant's trial counsel did not object to the amendment, and the district court granted the State's motion. Defendant was subsequently convicted Defendant of the underlying charge in count I. After Defendant was sentenced, Defendant appealed, asserting that his trial counsel was ineffective for failing to object to the State's motion to amend the trial information. The court of appeals denied relief. The Supreme Court affirmed Defendant's conviction and sentence but vacated the court of appeals decision to reject Defendant's ineffective-assistance claim, holding (1) under certain circumstances, an amendment to add a habitual offender enhancement to a trial information should not be allowed after the close of the evidence; but (2) the record in this case was insufficient to resolve Defendant's ineffective assistance of counsel claim. View "State v. Brothern" on Justia Law

Defendant, a parolee, was charged with four drug-related crimes after a search of her house by narcotics police officers revealed firearms and marijuana. Defendant filed a motion to suppress the marijuana as evidence at trial, arguing that it was obtained in violation of her Fourth Amendment rights because she did not consent to the search. The district court found that Defendant gave advance consent to search her property without a warrant or probable cause by signing a parole agreement and that the search was justified under exigent circumstances and the community caretaking function. Defendant was then convicted as charged. The Supreme Court reversed, holding (1) three of Defendant's convictions must be dismissed for a lack of substantial evidence; and (2) the warrantless search of Defendant's home and seizure of the evidence violated the Iowa Constitution, as (i) Defendant's parole agreement did not justify the search of her home, and (ii) no exception to the warrant requirement justified the search. View "State v. Kern" on Justia Law

Appellant pleaded guilty to first-degree harassment. While Appellant was incarcerated for the offense, the State sought to have him committed as a sexually violent predator (SVP) under Iowa Code 229A. A jury found Appellant was an SVP, and Appellant was ordered for commitment. The Supreme Court remanded the case. On retrial, the jury against concluded Appellant was an SVP, and Appellant was again ordered committed. The Supreme Court affirmed, holding (1) Appellant failed to meet his burden to show by a preponderance of the evidence that he was prejudiced by his counsel's advise to sign a speedy trial waiver; (2) Appellant was not prejudiced by his trial counsel's failure to adequately argue the trial should have been bifurcated to protect Appellant's due process rights; and (3) the prosecution did not misstate the evidence during trial. View "In re Detention of Blaise" on Justia Law

Melissa and Heather Gartner were a married lesbian couple. Heather conceived a child using an anonymous sperm donor. The child was born during the spouses' marriage. The Gartners requested a birth certificate recognizing both Heather and Melissa as the child's parents. The Department of Public Health refused to place the name of the nonbirthing spouse in a lesbian marriage on the birth certificate without the spouse first adopting the child. The district court ordered the Department to issue the Gartners a birth certificate listing both spouses as parents but did not require the Department to extend the same practice to other married lesbian couples. The Supreme Court affirmed as modified, holding (1) Iowa Code 144.13(2), Iowa's presumption of parentage statute, violates the equal protection clause of the Iowa Constitution because it allows for only "the name of the husband" to appear on the birth certificate; and (2) accordingly, the Department must presumptively list on a child's birth certificate the nonbirthing spouse in a lesbian marriage when the child was born to one of the spouses during their marriage. View "Gartner v. Iowa Dep't of Pub. Health" on Justia Law

Defendant was convicted of operating a motor vehicle while intoxicated. Defendant appealed the denial of his motion to suppress, arguing that the police officer who stopped his vehicle lacked either reasonable suspicion or probable cause to justify the stop. The officer testified that he observed a violation of Iowa Code 321.37(3), which makes it unlawful for the owner of a vehicle to place a frame around the registration plate that does not permit full view of the license plate numbers and letters, and that violation was the basis for the stop. The Supreme Court reversed, holding that the officer did not have either probable cause or reasonable suspicion to stop Defendant's vehicle, and thus, all evidence obtained in the subsequent stop was inadmissible. Remanded. View "State v. Tyler" on Justia Law

After Appellant was granted parole, Appellant and his parole officer signed a parole agreement that contained standard and special terms of parole. One standard condition authorized any parole officer of law enforcement officer to conduct a warrantless, suspicionless search of Appellant and the home, vehicle, and belongings of Appellant. During one such parolee search, a police officer took Appellant's car keys and searched Appellant's car, where the officer discovered a large quantity of marijuana. The State subsequently charged Appellant with drug possession. Appellant moved to suppress the marijuana seized from the search of his vehicle, asserting that the search was unconstitutional because the condition authorizing the search constituted involuntary consent. The district court denied Appellant's motion and found him guilty of the charges. The Supreme Court reversed, concluding that a parole agreement does not satisfy the consent exception to the reasonableness and warrant requirements of the search and seizure clause of the Iowa Constitution. Remanded for a new trial. View "State v. Baldon" on Justia Law

Defendant was charged with one count of robbery and one count of willful injury causing serious injury. The charges both stemmed from a single incident involving a single victim. Pursuant to a plea agreement, Defendant pleaded guilty to two counts of willful injury causing serious injury. Defendant appealed, arguing that his trial counsel was ineffective for allowing him to enter a guilty plea without a factual basis. The court of appeals vacated one of the willful injury convictions, finding that there was not a sufficient factual basis in the record to support a second independent charge of willful injury causing serious injury. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding that the record established an independent factual basis for the factual charge, and thus, counsel was not ineffective in allowing Defendant to enter guilty pleas to two separate counts of willful injury causing serious injury. View "State v. Velez" on Justia Law

In 2006, the Iowa Department of Revenue assessed the value of Qwest Corporation's Iowa operating property. Qwest protested the assessment by challenging the general assembly's previous decision to tax the personal property of incumbent local exchange carriers (ILECs) but not competitive long distance telephone companies (CLDTCs) or wireless providers operating in Iowa. Specifically, Qwest argued that the tax scheme which taxed ILECs for the value of their personal property but not CLDTCs and wireless providers violated Qwest's equal protection rights. The State Board of Tax Review (Board) concluded that Qwest's constitutional rights were not violated. The district court reversed. The Supreme Court reversed the district court and upheld the Board's assessment on Qwest, holding that imposing a tax on Iowa-based personal property of ILECs but not on that of CLDTCs or wireless service providers did not violate the Iowa Constitution, as the differential tax treatment of these enterprises is rationally related to legitimate state interests in encouraging the development of new competitive telecommunications infrastructure while raising revenue from those providers that historically had a regulated monopoly and continue to enjoy some advantages of that monopoly. View "Qwest Corp. v. State Bd. of Tax Review" on Justia Law

In 1999, Appellant was convicted of first-degree murder and sentenced to life in prison without parole. In 2002, Appellant unsuccessfully sought postconviction relief. In 2006, the Supreme Court issued its decision in State v. Heemstra, in which the Court held that if the act causing willful injury is the same act that causes the victim's death, the former is merged into the murder and therefore cannot serve as the predicate felony for felony-murder purposes. In 2009, Appellant filed another application for postconviction relief, arguing that, under Heemstra, he would not have been convicted of felony-murder, and Heemstra should be applied retroactively. The application was filed after the statute of limitations had expired but within three years of the Court's decision in Heemstra. The district court granted the State's motion for summary disposition, finding that the three-year limitations bar applied. The Supreme Court reversed because Appellant raised a ground of fact or law that could not have been raised within the applicable time period. Remanded. View "Nguyen v. State" on Justia Law

Appellant pled guilty in 2000 to attempted burglary in the third degree. In 2011, Appellant filed an application for postconviction relief, arguing that, pursuant to the U.S. Supreme Court's decision in Padilla v. Kentucky, he had received ineffective assistance of counsel because his counsel had failed to advise him that pleading guilty would result in his removal from the United States. The district court granted summary judgment on Appellant's application, finding it to be untimely. The Supreme Court affirmed, holding that, based on the U.S. Supreme Court's decision in Chaidez v. United States, because Padilla announced a new rule of constitutional criminal procedure, it did not apply retroactively to convictions like Appellant's that became final before the Padilla decision. View "Nguyen v. State" on Justia Law