Justia Civil Rights Opinion Summaries

A juvenile court terminated Father's parental rights to his two children. Father appealed, arguing, among other things, that the juvenile court violated his due process rights when it ordered him to provide a fingernail drug test after his termination trial. The court of appeals reversed, principally on the basis that there was no evidence in the record as to the reliability or the accuracy of the fingernail drug test, and that the record, including the fingernail test, lacked clear and convincing evidence to warrant termination of Father's parental rights. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment and order of the trial court, holding (1) the test did not violate Father's due process rights; (2) the evidence including the fingernail test was sufficient to warrant termination; and (3) termination was in the children's best interests.

After the State filed a child in need of assistance (CINA) petition, the juvenile court issued a temporary removal order removing Child from Mother's custody and placing her in foster care. Once the CINA proceeding was dismissed, Mother sued the State and two employees of the Iowa Department of Human Services (DHS) under 42 U.S.C. 1983 and the Iowa Tort Claims Act (ITCA), alleging the DHS social workers wrongfully removed Child from her custody and negligently failed to protect Child from abuse. The district court granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding (1) a social worker is entitled to absolute immunity when the social worker functions in the role of a prosecutor or ordinary witness; (2) a social worker is entitled to qualified immunity when acting in the role of a complaining witness, and for his or her investigatory acts; (3) alleged injured parties cannot maintain an action against a social worker under the ITCA where the alleged parties fail to exhaust the available administrative remedy prior to filing an action in court and where the basis of the complaint is that the social worker engaged in conduct functionally equivalent to misrepresentation or deceit.

Peter Long was convicted of third-degree sexual abuse. Based on two prior convictions for lascivious acts with a child, the district court found that Long had committed a class A felony and sentenced Long to life in prison without the possibility of parole. Long appealed, claiming the district court abused its discretion when it allowed the State to reopen the record after the State had rested and after the defense had made a motion for judgment of acquittal during the enhancement trial. The court of appeals vacated the judgment and remanded the case to the district court to render a verdict on the enhancement based solely on the evidence introduced prior to the reopening of the record. The Supreme Court vacated the court of appeals and affirmed the district court, holding that the district court did not abuse its discretion in reopening the record under the circumstances of this case.

Donald Clark was convicted of sexual abuse in the second degree for molesting a fifth-grade student while employed as a guidance counselor at the elementary school. Clark appealed, arguing that his constitutional rights to a fair trial and due process were violated when the trial court failed to grant his request for a continuance and to allow the retaking of depositions based on the late disclosure of an e-mail written by the student. The Supreme Court affirmed Clark's conviction and sentence, holding that the district court did not violate Clark's constitutional rights or abuse its discretion when it refused to allow redepositions or grant a continuance.

Sergio Perez pled guilty to a misdemeanor drug possession charge in 2000. Perez later filed an application for postconviction relief seeking to have his conviction set aside, claiming that he did not receive advice from his attorney regarding the risk of deportation before pleading guilty. The district court denied the application, and the court of appeals affirmed. At the center of this appeal was the U.S. Supreme Court's decision in Padilla v. Kentucky, which decided a criminal defendant has a right to receive advice from counsel regarding the risk of deportation before pleading guilty. The Supreme Court affirmed, holding (1) if Padilla establishes a new rule of constitutional criminal procedure, it does not apply retroactively, and Perez may not rely upon it to set aside an earlier conviction; and (2) if Padilla is not a new rule, Perez's application is time-barred because he could have filed it within three years of the date when his conviction became final and failed to do so.

This case presented the question of whether an officer is justified in activating his emergency lights and blocking a driver into a parking space under the "community caretaking function" exception to the warrant requirement of the Fourth Amendment based solely upon his knowledge that the vehicle has just struck an object in the roadway and suffered minor damage not affecting the drivability of the car. Here the district court denied Defendant driver's motion to suppress the evidence found after the warrantless seizure of Defendant's car, and Defendant was found guilty of OWI. The Supreme Court reversed the district court, concluding that under the circumstances of this case, the community caretaking exception was inapplicable, and the seizure was impermissible. Remanded.

At issue here was sex offenders serving prison time on a "revocation of release" from a "special sentence" under Iowa Code 903B.2 and whether the maximum time incarcerated was reduced by "earned-time credit" or "jail-time credit." Kris Kolzow began serving his ten-year special sentence released on parole. A parole violation prompted his detention for five and one-half months awaiting a parole-revocation hearing. The administrative parole judge ordered Kolzow to prison "to serve a period not greater than two years" as required by section 903B.2. The Iowa Department of Corrections (IDOC) refused to shorten Kolzow's prison time with earned-time credit or jail-time credit. The district court ruled that both credits applied to reduce the maximum two-year period served in prison on the revocation of release. The Supreme Court affirmed the ruling awarding Kolzow jail-time credit and reversed the ruling awarding him earned-time credit, holding (1) IDOC need not apply earned-time credit to shorten the period incarcerated on a revocation of release; and (2) an offender serving a special sentence under section 903B.2 is entitled to jail-time credit against the maximum periods for revocation of release for each day he is detained awaiting his parole-revocation hearing.

Roger Ennenga was arrested for failing to stop his vehicle when police attempted to pull him over and for possession of methamphetamine. The State failed to file a trial information within forty-five days, and Ennenga's counsel did not file a motion to dismiss. Thereafter, Ennenga's counsel allowed him to plead guilty. At issue before the Supreme Court on Ennenga's application for postconviction relief was whether an indictment must be filed in order to be "found" for the purposes of Iowa R. Crim. P. 2.33, which requires the court to dismiss a prosecution if an indictment or trial information is not "found" within forty-five days of the defendant's arrest, and whether failing to ensure an indictment is timely filed amounts to the breach of an essential duty by an accused's counsel. The Court reversed the district court, holding that counsel breached an essential duty in failing to file a motion to dismiss the untimely trial information, and that counsel's failure resulted in prejudice to Ennenga by his plea of guilty. Remanded.

After a jury trial, Defendant Kenneth Madsen was convicted of two counts of sexual abuse in the second degree and one count of lascivious acts with a child. Madsen appealed, arguing (1) the district court erred in failing to suppress his confessions because his confessions were involuntary under the constitutional totality-of-the-circumstances test due to the detective's threat to make him late for work and promise that if Madsen confessed he could keep his name out of the newspaper and put the matter behind him; and (2) his counsel was ineffective for not attempting to suppress his confession under the common law evidentiary test for promises of leniency. The Supreme Court affirmed in part and reversed in part, holding (1) Madsen's trial counsel breached an essential duty by failing to move to suppress Madsen's confessions under the evidentiary test; (2) the interrogating officer made promises of leniency that required suppression of part of Madsen's confession, but Madsen's self-incriminating statements made before those promises remained admissible; and (3) Madsen was entitled to a new trial on one count of second-degree sexual abuse, but his two remaining convictions were affirmed based on lack of prejudice.

Defendant Anthony Polk confessed in a jailhouse interview to firing his handgun at the scene of a gang-related shooting that left two men with gunshot wounds. Polk filed a motion to suppress his conviction, contending that the interrogating police officer baited him into talking after Polk had invoked his Fifth Amendment right to remain silent and made improper promises of leniency that suggested by talking to police Polk could get a better deal and spend less time away from his children. The district court denied Polk's motion and convicted Polk of several weapon-related crimes. The Supreme Court reversed Polk's convictions and sentences, holding that the interrogating officer's promises of leniency rendered Polk's confession inadmissible, and therefore, the district court erred in denying Polk's motion to suppress.