Justia Civil Rights Opinion Summaries

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.

Rachel Overbay, the driver of a vehicle, was involved in an accident and transferred to the hospital. A law enforcement officer requested a blood sample from Overbay. Overbay, however, was incorrectly informed that her refusal of the requested chemical test would automatically lead to revocation of her driving privileges. In fact, Overbay's refusal of the blood test would not have been deemed final but would have led to her being offered a different chemical test. Overbay agreed to provide the blood sample, and the results showed a blood alcohol content of more than twice the legal limit. The State subsequently charged Overbay with operating a motor vehicle while under the influence of alcohol. The district court granted Overbay's motion to suppress, finding that Overbay's consent to the blood test was not voluntary because it was based on misleading information. The court of appeals affirmed. The Supreme Court vacated the court of appeals and reversed the district court, holding that consistent with precedent, inaccurate information does not render a driver's consent involuntary when the record indicates that the inaccuracy did not affect the driver's decision. Remanded.

Defendant Jerin Mootz was convicted for assault on a police officer resulting in bodily injury. During voir dire, Mootz sought to use a peremptory challenge to remove a Hispanic juror. The district court found Mootz was using his strikes in a racially discriminatory manner, denied the strike, and seated the juror. The court of appeals affirmed the conviction, finding that the district court erred in refusing to allow the strike of the potential juror, but that Mootz had not shown that the error prejudiced him. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the district court, holding (1) the trial court erred when it prohibited Mootz from using his peremptory challenge to remove the juror; (2) Mootz, or any other similarly situated defendant, was not required to show actual prejudice in order to reverse his conviction; and (3) automatic reversal is required whenever a defendant is denied the use of a peremptory challenge based on an erroneous interpretation of Batson v. Kentucky and its progeny and the objectionable juror is improperly seated.

Robert Lowe was charged with several criminal counts related to Lowe's alleged manufacture of methamphetamine. Lowe moved to certain suppress statements he made to the police. The district court granted the motion, determining that because the statements had been made in response to a promise of leniency they were rendered involuntary. The Supreme Court affirmed, holding (1) the consent that led to the search of the premises was proper and the motion to suppress the physical evidence obtained as a result of the search was properly denied; and (2) when police reinitiated questioning of Lowe after he requested an attorney, they violated his constitutional rights under Miranda, and because there was not sufficient exigency to justify such questioning, the public safety exception to Miranda did not apply under the facts of this case. Therefore, Lowe's statements were properly suppressed.

After his vehicle collided with and killed a bicyclist, Defendant was convicted of homicide by vehicle, operating while intoxicated, and leaving the scene of an accident. The court of appeals affirmed his convictions but remanded for a sentencing correction. The Supreme Court granted further review to determine whether the State must prove in a prosecution under Iowa Code 707.6A(1) that Defendant's intoxication was a proximate cause of the victim's death and, if so, whether Defendant's trial counsel was ineffective for failing to raise the issue below. The Supreme Court affirmed the conviction, holding (1) the State must prove Defendant's intoxicated driving caused the victim's death to sustain a conviction for homicide by vehicle; and (2) the record was not adequate to determine whether Defendant's trial counsel was ineffective in failing to raise the causation issue, and therefore, the claim of ineffective assistance of counsel was preserved for postconviction proceedings.

Dennis Richards was convicted of second-degree murder and second-degree arson for strangling his ex-wife to death and setting her house on fire. The court of appeals reversed and remanded for a new trial after concluding that Richards should have been allowed to call a physical therapist in his defense even though the witness had been disclosed a day late. The Supreme Court vacated the decision of the court of appeals and affirmed Richards' convictions, holding that even if the district court erred in excluding the therapist, any error was harmless in light of the overwhelming evidence of Richards' guilt.

Lee Breuer was the apparent driver in a one-car accident. Breuer and the passenger were transported to the hospital, where a deputy sheriff asked Breuer to provide a breath test. Breuer refused. An officer then obtained a warrant authorizing withdrawal of a blood specimen from Breuer. Before the officer arrived at the hospital with the warrant, the deputy sheriff advised Bruer that his blood would be withdrawn by force if necessary, and Breuer acquiesced to a blood draw. The passenger in Breuer's vehicle subsequently died as a result of injuries sustained in the accident. The State charged Breuer with homicide by vehicle. Breuer filed a motion to suppress the results of the blood draw, which the district court denied. The court of appeals affirmed. The Supreme Court affirmed, holding that neither the state or federal constitution required the search warrant to be physically present before the search could begin.