Justia Civil Rights Opinion Summaries

The State charged Anthony Rodriguez with second-degree sexual abuse, willful injury, and domestic abuse assault. Ultimately, the district court dismissed the case due to a speedy trial rights violation. The court of appeals reversed. At issue on appeal was whether the State was entitled to an independent psychiatric evaluation of Rodriguez, a request the district court had denied. The Supreme Court affirmed the court of appeals and reversed the district court, holding (1) when a defendant puts at issue his mental capacity to knowingly, intelligently, or voluntarily waive his Miranda rights, the State is entitled to obtain an independent psychiatric evaluation of the defendant; (2) in order to protect the defendant's constitutional right against self-incrimination in these cases, the safeguards found in State v. Craney regarding the expert's testimony following the evaluation are applicable; and (3) the expert should not disclose to the State the same matters about which Craney prohibits an expert from testifying. Remanded.

The State charged Daniel Rainsong with theft in the first degree, dependent adult abuse and habitual offender. The State alleged Rainsong stole $15,000 each from his mother, a dependent adult who passed away, and her husband, Loren Radford. The State later noticed the deposition of Radford, but Rainsong refused to attend the deposition. The State proceeded to take the deposition of Radford without participation by Rainsong. When the State attempted to introduce the deposition at trial, the district court denied the request. The Supreme Court granted interlocutory review and affirmed, holding that the district court correctly decided not to allow the State to introduce at trial the statement contained in Radford's noticed deposition because (1) Iowa R. Crim. P. 2.13 did not authorize the taking of the deposition; and (2) therefore, the noticed deposition was nothing more than a sworn affidavit, and its admission would violate Rainsong's right to confrontation as guaranteed by the Confrontation Clause.

Jose Aguilera was convicted of second-degree murder. In his second application for postconviction relief, Aguilera contended that he was denied due process when the prosecution failed to turn over an Iowa Division of Criminal Investigation file containing several witness statements prior to Aguilera's initial trial. The district court found the material was suppressed and that it was favorable but that it was not material to the issue of guilt and dismissed the application. The court of appeals affirmed. The Supreme Court vacated the court of appeals and reversed the district court, holding that because the suppressed, favorable statements that were not turned over by the State had a reasonable probability of impacting the outcome of the trial, a Brady violation occurred, and Aguilera's due process rights were violated. Remanded.

Matthew Elliott was found guilty by a jury of willful injury causing serious injury and child endangerment resulting in death. The court of appeals affirmed. At issue on appeal was whether the district court erred in allowing hearsay testimony from a detective when it allowed the detective to testify about a certain interview. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the district court, holding that the disputed testimony was hearsay, and the error was not harmless because the improper admission of the hearsay evidence was prejudicial to Elliott's substantive rights. Remanded for a new trial.

Following a jury trial, Robert Krogmann was convicted for attempted murder and willful injury. On appeal, Krogmann contended that (1) the district court erred in granting the State's pretrial request to freeze all his personal assets and requiring that he apply to the court for permission to use those assets for his legal defense, and (2) the prosecutor committed reversible misconduct by asking an inflammatory question at trial. The Supreme Court affirmed, holding (1) while the Court had concerns about the propriety of the asset freeze, Krogmann failed to preserve error on this issue; and (2) error was not preserved as to the incident of asserted prosecutorial misconduct, and this incident would not have amounted to reversible error in any event.

Defendant Carson Walker was charged with operating a motor vehicle while intoxicated (OWI). After he was arrested, Walker requested to speak to his lawyer. While consulting, Walker and his lawyer talked through an intercom in a booth separated by a glass partition and were monitored by a police video camera. After conferring with his lawyer, Walker took a breath test, which measured Walker's blood level at more than double the legal limit. At trial, Walker moved to suppress the breath-test results based on the alleged violation under Iowa Code 804.20 to "see and consult confidentially" with his attorney "alone and in private." The district court granted the motion. On interlocutory appeal, the court of appeals reversed. The Supreme Court vacated the court of appeals and affirmed the district court's ruling suppressing the breath-test results, holding that the police violated Walker's section 804.20 rights by restricting his attorney conference to the booth with the glass partition under videotaped surveillance.

Defendant Jesse Pearson, a seventeen-year-old, robbed and beat an elderly man. After he was apprehended, Pearson refused to waive his Miranda rights. The next morning, however, he confessed to his social worker, Marie Mahler, without his attorney present. The district court denied Pearson's motion to suppress his confession, concluding that Mahler's interview was not a custodial interrogation implicating Miranda safeguards. A jury convicted Pearson of first-degree robbery, willful injury, and going armed with intent. The court of appeals reversed Pearson's conviction on the going armed charge and otherwise affirmed. At issue on appeal was whether Pearson's confession to Mahler was admissible. The Supreme Court affirmed, holding that Mahler's interview of Pearson was not a custodial interrogation for Miranda purposes and that his confession to her was voluntary and admissible.

A jury found Defendant Robin Brubaker guilty of operating while intoxicated, fourth offense, and unlawful possession of a prescription drug. On appeal, Defendant contended that the district court erred by denying his motion to suppress evidence found in his car when officers searched it after his arrest and that his trial counsel was ineffective for failing to object specifically to the sufficiency of the evidence offered by the State regarding the charge of unlawful possession of a prescription drug. The Supreme Court reversed the judgment for unlawful possession of a prescription drug and remanded the case for dismissal of that charge, holding that trial counsel was ineffective and if counsel had made the proper object regarding the sufficiency of the evidence, the district court would have dismissed the unlawful possession charge.

Judith Utter was charged with supplying alcohol to a person under the legal age. Utter pled guilty to the charge. Subsequently, Utter appealed, arguing her trial counsel provided ineffective assistance by failing to file a motion to dismiss the charge based on the State's violation of Iowa's speedy indictment rule. The court of appeals affirmed after analyzing the issue and preserving Utter's claim for a postconviction relief proceeding. The Supreme Court vacated the court of appeals and reversed the district court, holding (1) the State violated the speedy indictment rule by failing to indict Utter with the forty-five day window mandated by Iowa R. Crim. P. 2.33(2)(a); (2) Utter's trial counsel failed to perform an essential duty by failing to file a motion to dismiss based on the State's violation of the speedy indictment rule; and (3) Utter did not enter the plea voluntarily or intelligently as she would not have pled guilty if she had known the court was required to dismiss the information under rule 2.33(2)(a) and the State could not charge her with any other violation of Iowa Code 123.47 arising out of the underage drinking party at her home. Remanded with directions to dismiss the information.

After a jury trial, Raymond Redmond was convicted of indecent exposure. Redmond appealed, contending that the district court abused its discretion by permitting the State to impeach Redmond with his prior first-degree harassment conviction under Iowa R. Evid. 5.609(a)(1). The court of appeals affirmed the district court's evidentiary ruling. The Supreme Court vacated the court of appeals and reversed the district court, holding (1) the district court abused its discretion by allowing the State to impeach Redmond with his prior conviction as the prior conviction's probative value did not outweigh its prejudicial effect, and (2) the error was not harmless. Remanded for a new trial.