Justia Civil Rights Opinion Summaries

In this criminal action, the Supreme Court affirmed the ruling of the district court on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury, holding that Defendant's conviction of two counts of murder in the first degree and one count of attempted murder stands.On appeal, Defendant, an African-American, argued that his right to an impartial jury under the United States Constitution had been violated because, although his jury pool contained five African-Americans, the jury that decided his case contained no African-Americans. The Supreme Court made refinements to how a defendant must prove a fair-cross-section constitutional violation and remanded the case to give Defendant an opportunity to develop his impartial-jury arguments. On remand, the district court rejected Defendant's further-developed claims. The Supreme Court affirmed, holding that the district court did not err in ruling on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury. View "State v. Veal" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court denying Employer's motion for a new trial and motion for judgment notwithstanding the verdict following a jury trial on Employee's claims of sex and gender identity discrimination and dismissing Employee's claims against a third-party administrator on summary judgment, holding that the court erred in part.Specifically, the Supreme Court (1) reversed the district court's denial of Employer's motion for judgment notwithstanding the verdict and dismissed the jury's verdict as to Employee's sex discrimination claims, holding that the district court erred in submitting the sex discrimination claim to the jury; (2) affirmed the jury's verdicts as to employee's gender identity discrimination claims; (3) affirmed the jury's damages award in favor of Employee in the full amounts that the jury entered; and (4) affirmed the district court's grant of summary judgment in favor of Employer. View "Vroegh v. Iowa Department of Corrections" on Justia Law

The Supreme Court affirmed Defendant's conviction, rendered after a second jury trial, of second-degree murder, holding that Defendant was not entitled to relief on her allegations of error.Over twenty-five years after the murder in this case, a woman told a cold-case investigator about a murder confession she witnessed as a girl from Defendant. Defendant was ultimately charged with and convicted of murder. The Supreme Court affirmed, holding (1) as to Defendant's argument that the prosecution failed to timely disclose that certain evidence had been determined unsuitable for standard DNA testing, Defendant could have sought DNA testing prior to trial but chose not to do so, and Defendant may still pursue specialized DNA testing in a postconviction proceeding; (2) the twenty-six year delay in prosecution did not prejudice Defendant's ability to make her case, and there was no bad faith on the part of the prosecution; (3) the district court did not err in allowing the jury to scrutinize the credibility of witnesses; and (4) there was sufficient evidence for the jury to find Defendant guilty of second-degree murder. View "State v. Cahill" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court convicting Defendant of various drug-related crimes and sentencing him to a total of forty-two years in prison, holding that the district court did not err in denying Defendant's motion to suppress.At issue on appeal was whether the grant of a search warrant to search Defendant's residence and vehicles for evidence of drug dealing had a substantial basis under the totality of the circumstances, as disclosed in the warrant application. The Supreme Court held that the magistrate's determination that the information was sufficient to justify a search warrant for the house had a substantial basis, and therefore, the district court did not err in denying Defendant's motion to suppress. View "State v. Bracy" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court convicting Defendant, following a guilty plea, of lascivious acts with a child, holding that Defendant was not entitled to relief.On appeal, Defendant argued (1) his plea counsel provided ineffective assistance in allowing him to plead guilty without first requesting a competency hearing; and (2) the district court erred by failing, sua sponte, to order a competency hearing. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Defendant's claim of ineffective assistance of counsel was not a legally sufficient reason that could serve as "good cause" to establish a statutory right to appeal; and (2) the district court did not err by failing, sua sponte, to order a competency hearing. View "State v. Newman" on Justia Law

The Supreme Court affirmed Defendant's plea-based conviction for a drug offense, a class "C" felony, holding that Defendant's challenges to the validity of his plea were unavailing.At issue was this Court's supervisory orders promulgated in response to the COVID-19 global pandemic temporarily allowing written pleas. On appeal, Defendant argued that the rules of criminal procedure, precedent, and due process required an in-person plea colloquy in open court and that the supervisory orders violated due process and separation of powers principles. The Supreme Court affirmed, holding (1) Defendant met the good cause requirement by presenting questions of first impression as the the validity of this Court's supervisory orders and Defendant's written guilty plea to a felony; but (2) this Court's supervisory orders are lawful exercises of this Court's constitutional and inherent authority during the pandemic. View "State v. Basquin" on Justia Law

The Supreme Court reversed the ruling of the district court denying Defendant's motion to dismiss the trial information filed against her, holding that the State violated the speedy indictment rule.On July 5, 2020, Defendant was issued citations in lieu of arrest for several misdemeanors. Defendant's initial appearance happened on September 21, and the State filed its trial information on October 6. Defendant subsequently filed her motion to dismiss, arguing that a citation in lieu of arrest triggers the speedy indictment rule, and the State failed timely to file the trial information within forty-five days of the citations issued against her or even within a sixty-day extended deadline under the Supreme Court's supervisory order. The district court denied the motion to dismiss. The Supreme Court reversed, holding (1) the district court should have counted the forty-five days from the date the citations issued rather than Defendant's initial appearance; (2) the district court erred by ruling that the COVID-19 pandemic provided good cause for the delay in indicting Defendant; and (3) Defendant was entitled to dismissal under Iowa R. Crim. P. 2.33(2)(a). View "State v. Watson" on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's motion to suppress evidence of methamphetamine found in his coat pocket during a traffic stop, holding that the search was unconstitutional, and therefore, the district court erred in denying Defendant's motion to suppress.Defendant was a backseat passenger in a car driven by his brother that was pulled over for a traffic violation. On appeal, Defendant argued that the officer who found methamphetamine in his coat pocket lacked probable cause to search him after a canine indicated drugs were present in the car. The Supreme Court agreed and reversed the denial of Defendant's motion to suppress and vacated his conviction, holding (1) the officers lacked probable cause to arrest Defendant before they searched his person; and (2) therefore, the district court erred by denying Defendant's motion to suppress the evidence found from the unconstitutional search. View "State v. Stevens" on Justia Law

The Supreme Court affirmed Defendant's conviction that arose from the search of her backpack after police officers encountered a stolen car parked with the engine running, holding that the district court did not err in denying Defendant's motion to suppress.Defendant was one of the three backseat passengers in the parked car at issue. The officers observed an open bottle of liquor on the driver's seat and another open container of liquor standing on the rear seat floorboard. When the passengers were directed to exit the vehicle Defendant took her backpack with her. An officer took the backpack, noticed a bag of marijuana, and discovered illicit drugs in a subsequent search. The district court denied Defendant's motion to suppress the results of the search of her backpack on the basis of the automobile exception. The Supreme Court affirmed, holding that the district court properly denied Defendant's motion to suppress. View "State v. Rincon" on Justia Law

The Supreme Court affirmed Defendant's conviction for aiding and abetting a robbery, holding that the district court did not err in holding that Defendant failed to prove that his constitutional right to an impartial jury had been violated.On appeal, Defendant, an African-American, argued that his right to an impartial jury under both the United States and Iowa Constitutions was violated because his jury, and even the jury panel, did not contain any African-Americans. The Supreme Court remanded the case to allow Defendant to develop his impartial-jury claims, but the district court ultimately rejected Defendant's arguments. The Supreme Court affirmed, holding that the district court did not err in holding on remand that Defendant failed to prove that his right to an impartial jury had been violated in the proceedings below. View "State v. Lilly" on Justia Law