Justia Civil Rights Opinion Summaries

Plaintiff was a construction supply business that entered into a dispute with City over a project upgrading City's wastewater treatment facility. After City excluded Plaintiff from its list of preapproved material suppliers, Plaintiff filed this action seeking a declaration that City's preapproval process violated Iowa's public construction bidding statute and constitutional guarantees of equal protection and due process. In addition, Plaintiff sought relief under the Open Records Act, claiming that City's significant delay in responding to Plaintiff's open records request violated the Open Records Act. The district court rejected each of Plaintiff's claims. The Supreme Court (1) affirmed the judgment dismissing Plaintiff's public biding and constitutional claims, as (i) Plaintiff lacked standing to challenge City's preapproval process, and (ii) Plaintiff's constitutional claims failed on the merits; and (2) reversed the district court's ruling denying Plaintiff relief under the open records law, as City's substantial and inadequately explained delay in responding to Plaintiff's open records request violated the law. View "Horsfield Materials, Inc. v. City of Dyersville" on Justia Law

Defendant was charged with and convicted of operating a motor vehicle while under the influence. Defendant appealed, contending that the district court erred in denying his motion to suppress the evidence obtained from the stop of his vehicle after the police received an anonymous tip reporting a drunk driver. The Supreme Court reversed and suppressed all evidence seized from the stop, holding that the investigatory stop of Defendant was illegal under the Fourth Amendment, as a bare assertion by an anonymous tipster reporting drunk driving, without relaying to the police a personal observation of erratic driving or other facts to establish the driver is intoxicated, does not provide reasonable suspicion to stop a vehicle. Remanded for a new trial. View "State v. Kooima" on Justia Law

Plaintiffs were employees of limited liability corporations located in Iowa. Plaintiffs filed lawsuits against the businesses and certain individuals affiliated with the businesses, alleging that Defendants violated the Iowa Civil Rights Act (ICRA) by engaging in sexual harassment, sex discrimination, and retaliation. The lawsuits demanded punitive damages. Defendants moved to strike the claim for punitive damages. The district court granted the motion, concluding that punitive damages were not available under the ICRA. Plaintiffs sought, and the Supreme Court granted, interlocutory appeal. The Court then affirmed the district court, holding that an award of punitive damages is not permitted under the ICRA. View "Ackelson v. Manley Toy Direct, LLC" on Justia Law

Defendant pleaded guilty to possession of marijuana. At the hearing on Defendant's plea and sentencing, the sentencing court threatened to convict Defendant, instead of deferring judgment, if Defendant's declined to answer the court's inquiry on whether he would test positive on a drug test. Defendant invoked his right to remain silent. The court deferred judgment but imposed 250 hours of community service and a $350 penalty. The Supreme Court vacated Defendant's sentence and remanded for resentencing, holding that the district court improperly penalized Defendant for invoking his right against self-incrimination by imposing 250 hours of community service unconnected to any legitimate penological goal related to the court's drug-test inquiry. Remanded for resentencing. View "State v. Washington" on Justia Law

After a jury trial, Defendant was convicted of five counts of sexual exploitation of a minor and three counts of sexual exploitation by a school employee. Defendant appealed, arguing, among other things, that he could not be convicted of sexual exploitation by a school employee because none of the students involved with Defendant at the time of the events charged in the trial information were in an existing teacher-student relationship with Defendant. The court of appeals affirmed Defendant's convictions. The Supreme Court affirmed, holding that the district court did not err in (1) concluding that a contemporaneous teacher-student relationship was not required for Defendant to be convicted of sexual exploitation by a school employee; (2) concluding that physical contact between a school employee and student was not required to support a conviction for sexual exploitation by a school employee; and (3) refusing to sever Defendant's charges into multiple trials. View "State v. Romer" on Justia Law

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