Justia Civil Rights Opinion Summaries

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.

Petitioner, a juvenile offender whom the State tried as an adult, brought a postconviction relief action claiming that his conviction for first-degree murder should be overturned and that his sentence was illegal because it amounted to cruel and unusual punishment under the state and federal Constitutions. The district court dismissed both claims. The court of appeals affirmed, holding that Petitioner made the same claims in the past, and thus, the law of the case doctrine precluded the court from revisiting them. The Supreme Court vacated the decision of the court of appeals and reversed in part the judgment of the district court, holding (1) the law of the case doctrine precluded Petitioner from attacking his conviction for first-degree murder; but (2) the doctrine did not preclude Petitioner from attacking his sentence as illegal because the controlling authority regarding cruel and unusual punishment had changed since his original appeal regarding the issue, and the three-year limitation period for bringing a postconviction relief action did not prohibit a challenge to an illegal sentence. Remanded.

Charles Oliver was convicted a second time of third-degree sexual abuse, and Oliver stipulated that he had a prior conviction for third-degree sexual abuse. Because of his prior conviction, Oliver was guilty of a class A felony under the enhanced sentencing provisions of Iowa Code 902.14(1), and the district court accordingly sentenced Oliver to life in prison without the possibility of parole. The Supreme Court affirmed Oliver's sentence, holding (1) the sentence of life without parole did not constitute cruel and unusual punishment in violation of the state and federal Constitutions when considered in light of the particular facts of Oliver's case; and (2) section 902.14(1) was not unconstitutional either on its face or as applied to Oliver.

Defendant was convicted of possession of marijuana as an accommodation offense. Defendant was previously convicted of simple possession of marijuana. Defendant requested a sentencing hearing to determine whether he should be sentenced for a serious misdemeanor or an aggravated misdemeanor. The district court concluded the plain language of Iowa Code 124.410 and 124.401(5) provided Defendant be sentenced for a serious misdemeanor. The Supreme Court affirmed the judgment and sentence imposed by the district court, holding that the court did not misinterpret or misapply sections 124.401(5) and 124.410 when it sentenced Defendant for a serious misdemeanor under the circumstances presented here.

Police officers initiated an investigatory encounter with William DeWitt in Walmart based initially on information provided to them by a confidential informant. The officers decided to confront DeWitt and take him outside to his car to talk to him about their suspicion he was selling drugs. One or both of the officers took DeWitt by the arm. DeWitt broke free from their grasp, and the officers responded by taking him to the ground and handcuffing him. DeWitt was subsequently convicted of possession with intent to deliver, violation of the drug stamp act, and interference with official acts. The court of appeals affirmed the convictions. The Supreme Court affirmed, holding (1) the district court did not err in denying DeWitt's motion to suppress, as the officers' conduct in physically restraining DeWitt was not a violation of his right to be protected from unreasonable seizures under the state and federal constitutions; and (2) under the facts and circumstances of this case, the evidence was sufficient to support DeWitt's conviction.