Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's convictions and sentences for eluding while speeding and several unrelated offenses, holding that trial counsel was not ineffective for failing to challenge Defendant's eluding charge on double jeopardy grounds based on his guilty plea to speeding in the same incident.At age seventeen, Defendant pled guilty to a speeding citation without pleading guilty to the accompanying charge of eluding. When Defendant turned eighteen, the State charged him by trial information with eluding while speeding. Defendant pled guilty to the eluding charge. The court of appeals affirmed. The Supreme Court affirmed, holding (1) speeding is a lesser included offense that at trial would merge into a conviction for eluding while speeding, but under the circumstances of this case, Defendant cannot use double jeopardy principles as a sword to defeat his conviction for eluding; and (2) therefore, Defendant's ineffective assistance of counsel claims fail. View "State v. Roby" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Plaintiff's claims for violations of a municipal civil rights ordinance and the Iowa Civil Rights Act (ICRA) and breach of contract, holding that the ICRA does not contain authorization for a municipality to enact law that would be binding between two private parties in state court.Plaintiff claimed that he was discriminated against in his education on the basis of age and disability. The district court dismissed all of Plaintiff's claims, concluding that it had no jurisdiction over the local ordinance claims, that the ICRA claims were barred because they were based on the same conduct, and that Plaintiff did not have a viable breach of contract claim. The Supreme Court affirmed, holding (1) the general assembly did not confer jurisdiction on Iowa state courts to hear claims by private parties arising under municipal civil rights ordinances; and (2) the district court did not err in its resolution of Plaintiff's ICRA and breach of contract claims. View "Petro v. Palmer College of Chiropractic" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court reversing the decision of the Iowa Department of Human Services (DHS) that a child-care provider must pay back benefits the provider received during agency review of her cancelled provider agreement, holding that DHS erred in refusing to consider the provider's unjust enrichment defense to the recoupment proceeding.At issue was whether the provider was given constitutionally sufficient notice of DHS's intent to recoup payments. DHS sent the provider a notice cancelling the provider agreement and noted that any benefits the provider got while her appeal was being decided "may have to be paid back if the Department's action is correct." DHS affirmed its decision to cancel the provider's agreement but did not find, until years later, that the provider had to pay back the $16,000. The district court reversed DHS's decision on recoupment and denied attorney fees under Iowa Code 625.29(1)(b). The Supreme Court reversed in part, holding (1) DHS's notice met procedural due process requirements, but the DHS should have been allowed an opportunity to raise unjust enrichment as an offset to DHS's effort to recoup overpayments; and (2) where DHS's role was primarily adjudicative, DHS was not liable for attorney fees. View "Endress v. Iowa Department of Human Services" on Justia Law

The Supreme Court affirmed Defendant's conviction for assault on a peace officer with a dangerous weapon, a felony, and several misdemeanors, holding that Defendant did not receive ineffective assistance of counsel.After Defendant pleaded guilty, he absconded. He was later returned to custody. On appeal, Defendant argued that he received ineffective assistance of counsel because the plea bargain contained an unlawful term. Specifically, Defendant argued that the plea bargain's provision that he would be released from jail for a forty-eight-hour furlough after pleading guilty was illegal and that his trial counsel committed ineffective assistance in obtaining the illegal benefit for him. The Supreme Court affirmed, holding that where Defendant entered into the plea agreement with the illegally lenient sentence, he could not benefit from that sentence and then attack the plea bargain. View "State v. Gordon" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder after declining Defendant's invitation to change constitutional precedent to further limit the admissibility of eyewitness identifications following police photo arrays, holding that the double-blind procedures used in this case were not unduly suggestive and that Defendant received effective assistance of counsel.On appeal, Defendant argued (1) because the police used unduly suggestive photographic identification procedures the district court erred by failing to grant his motion to suppress the resulting identification; and (2) trial counsel was ineffective for failing to request jury instructions on eyewitness identifications that reflect modern scientific research. The court of appeals affirmed the conviction while preserving for possible postconviction relief action Defendant's ineffective assistance of counsel claim. The Supreme Court affirmed in part and vacated in part the court of appeals' decision, holding (1) the eyewitness identification was not unduly suggestive; and (2) contrary to the decision of the court of appeals, the record was adequate to decide the ineffective assistance of counsel claim challenging the jury instruction on eyewitness identification, and this claim is rejected on the merits. View "State v. Booth-Harris" on Justia Law

The Supreme Court vacated in part and affirmed in part the decision of the court of appeals declining relief on Defendant's claims that his trial counsel provided ineffective assistance for failing to object to the crime victim's first-time, in-court identification of Defendant, holding that Defendant's trial counsel did not provide constitutionally deficient representation for failing to object to the victim's trial testimony.The court of appeals affirmed Defendant's conviction, concluding that the record was inadequate to decide Defendant's ineffective-assistance-of-counsel claims but preserved those claims for post conviction proceedings. The Supreme Court vacated the judgment in part, holding (1) the record was adequate to decide Defendant's ineffective-assistance-of-counsel claim, but the claim is rejected because precedent permits first-time, in-court identifications; and (2) the court of appeals decision stands on the remaining issues. View "State v. Doolin" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder in the second degree, holding that Defendant's Fifth Amendment rights were invaded when the trial judge instructed the jury that Defendant was required to notify law enforcement of his use of deadly force, but the error was harmless.During trial, Defendant asserted the defense of justification in his shooting of the victim. At issue on appeal was whether the district court abused its discretion by giving a jury instruction incorporating the terms of Iowa Code 704.2B. The instruction included a statement that a person using deadly force is required to notify law enforcement about his use of deadly force. Defendant argued before the Supreme Court that both section 704.2B and the jury instruction incorporating that section violated his Fifth Amendment rights. The Supreme Court affirmed, holding (1) instructing the jury that a homicide defendant is required to notify a law enforcement agency of his use of deadly force violates the defendant's Fifth Amendment rights; but (2) any error in this case was harmless beyond a reasonable doubt. View "State v. Gibbs" on Justia Law

The Supreme Court vacated Defendant's guilty plea to possessing a tool with the intent to use it in the unlawful removal of a theft detection device under Iowa Code 714.7B(3), holding that there was no factual basis to support Defendant's guilty plea to this charge.Defendant's conviction arose from his act of using bolt cutters to cut the padlock off of a steel cable wrapped around a riding lawn mower on display outside of a Mills Fleet Farm. Defendant pled guilty violating section 714.7B(3). On appeal, Defendant argued that the padlock-steel cable combination device he cut with bolt cutters was not a "theft detective device" under section 714.7B, and therefore, his trial counsel was ineffective for allowing him to plead guilty to this charge.The Supreme Court agreed and vacated Defendant's guilty plea, holding (1) the padlock-steel cable combination did not constitute a "theft detective device" under the statute, and therefore, there was no factual basis to support Defendant's guilty plea; and (2) Defendant's counsel was ineffective for allowing Defendant to plead guilty. View "State v. Ross" on Justia Law

The Supreme Court affirmed the judgment of the district court imposing a seventeen and one-half year mandatory minimum prison term before parole eligibility on Defendant's second resentencing for attempted murder during a home invasion after considering the youth sentencing factors under State v. Roby, 897 N.W.2d 127 (Iowa 2017), holding that there was no error in the sentence and that counsel was not constitutionally ineffective.Defendant was seventeen years old at the time of the crime and was since resentenced twice, once in 2014 and once in 2018, as caselaw on juvenile sentencing evolved. In this appeal from his latest resentencing, Defendant argued that the district court failed to follow the Supreme Court's 2017 mandate to apply Roby and that his counsel was constitutionally ineffective for failing to retain a defense expert on the youth sentencing factors. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in applying the Miller/Lyle/Roby factors and deciding to impose the mandatory minimum sentence; and (2) Defendant's defense counsel had no duty to present a defense expert to testify regarding the Roby factors where Defendant decided to forgo retaining a defense expert. View "State v. Majors" on Justia Law

The Supreme Court vacated in part and affirmed in part the decision of the court of appeals affirming Defendant's conviction of voluntary manslaughter, holding that the court of appeals correctly found that the district court correctly determined that Defendant was not justified in his use of deadly force because he continued the incident which resulted in the victim's death.On appeal from his conviction of voluntary manslaughter Defendant argued that he was justified in his use of deadly force. The district court rejected the argument, finding that Defendant continued the incident with the victim and could have pursued an alternative course of action by retreating. The court of appeals affirmed, concluding that, while Defendant did not continue the incident with the victim, Defendant was not justified in his use of self-defense because he had an alternative course of action available. The Supreme Court held (1) Defendant continued the incident that resulted in the victim's death, and therefore, substantial evidence supported the district court's finding that Defendant was not justified in his use of deadly force; and (2) Defendant was not entitled to relief on his due process and equal protection claims. View "State v. Fordyce" on Justia Law