Supreme Court of Iowa

The court held that a traffic stop is constitutionally valid under both the Fourth Amendment and article I, section 8 of the Iowa Constitution when the officer has objectively reasonable grounds to believe a traffic violation occurred, regardless of the officer's subjective investigative motivation.

The court affirmed Albright’s convictions, holding that substantial evidence supported the confinement and torture elements of first-degree kidnapping and that submission of second-degree kidnapping as a lesser-included offense caused no prejudice because the jury convicted him of the greater offense.

The court held that the juvenile court abused its discretion by refusing to reopen the termination record after an approximately twenty-month delay, particularly because the mother sought to present current evidence directly relevant to sobriety, housing, and employment.

The court held that a claim alleging ineffective assistance of postconviction counsel, raised for the first time on appeal and unsupported by an adequate record, cannot be remanded to the postconviction court for development.

The court affirmed Wickes's conviction and sentence for sexual exploitation by a school employee. It held that hugs may constitute sexual conduct when considered in context and undertaken for sexual gratification, and that a single student and a forty-five-day period can support a statutory pattern, practice, or…

The court held that a knowing and voluntary guilty plea does not bar a freestanding actual-innocence claim under the Iowa Constitution when the claim relies on evidence extrinsic to the plea.

The Supreme Court of Iowa vacated the court of appeals’ decision and affirmed termination of the mother’s parental rights. It held that clear and convincing evidence showed the child could not be returned to the mother at the time of the termination hearing, and that the mother’s challenge to the adequacy of…

The court conditionally affirmed Plain's harassment conviction but remanded for development of the record on whether African-Americans were systematically underrepresented in the jury pool.

The court held that neither fraudulent passing or redeeming a lottery ticket nor tampering with lottery equipment was a continuing offense, and that the tampering prosecution was untimely because the State failed to establish due diligence under the fraud-based limitations extension.

The court held that sufficient circumstantial evidence supported Huser’s conviction for aiding and abetting Morningstar’s murder. It also held that the State improperly introduced backdoor hearsay through questioning of Mitrisin, but that the district court did not abuse its discretion by denying a mistrial, striking…

The court held that trial counsel provided ineffective assistance by failing to challenge the sufficiency of the evidence supporting one alternative theory of child endangerment.

The court vacated the court of appeals decision, reversed the district court judgment, and remanded for a new trial because the district court improperly submitted negligent training as a specification of negligence and gave a prejudicial instruction concerning private safety standards.

The court held that a statutory presumption favoring consecutive sentences does not eliminate the sentencing court’s duty to explain why it chose a consecutive term. Because the district court’s generalized reasons did not permit meaningful review of that separate discretionary choice, the court vacated the appellate…

The court held that Fisher could challenge his guilty plea on direct appeal because the plea materials did not substantially comply with the requirement to inform him that failing to file a motion in arrest of judgment would waive appellate challenges.

The court vacated the court of appeals decision and upheld Ary's convictions in all respects except for the district court's ruling on his motion for a new trial. It held that the voir dire statements of a prospective juror did not require presumed jury-panel prejudice, that the discovery ruling was not an abuse of…

The court held that the parents’ persistent inability to communicate and cooperate, including disputes over medical care, behavioral treatment, and extracurricular activities, constituted a substantial and permanent change in circumstances warranting modification of joint physical care.

The court affirmed the denial of Nguyen's postconviction-relief application. It held that postconviction counsel were not ineffective for failing to pursue a common-law retroactivity argument because the argument had already been considered and rejected when the court limited the retroactive application of the merger…

The court vacated the court of appeals’ spousal-support award and modified the district court’s judgment. Applying the statutory factors de novo, it awarded Carol lifetime support of $12,600 per month, reduced to $6,500 when she reaches age sixty-six years and six months and to $5,000 when Richard reaches that age or…

The court held that the prosecutor breached the plea agreement by introducing and emphasizing photographs of the child-victim’s injuries in a manner that undermined the agreed recommendation of a deferred judgment and probation.

The court held that the medical examiner’s opinions that the newborn died by drowning and that the death was a homicide were inadmissible because they rested primarily on Tyler’s inconsistent and uncorroborated statements rather than objective medical evidence and indirectly vouched for her credibility.

The court vacated Seats's juvenile life-without-parole sentence and remanded for a new individualized resentencing hearing. It held that juvenile homicide sentencing begins with a presumption favoring life with parole and requires consideration of youth-related mitigating circumstances, the offender's background, the…

The court held that the mother's approximately seventy-mile relocation with the children did not constitute a substantial change in circumstances warranting modification of the dissolution decree.

The court held that Dempsey failed to prove prejudice from counsel's allegedly inaccurate advice about the terms and sentencing consequences of an earlier, more favorable plea offer.

The court affirmed Hopkins's resentencing on the five convictions that remained after one conviction was reversed, holding that the district court did not abuse its discretion by imposing concurrent terms that were otherwise identical to the original sentence.

The court limited further review to whether trial counsel was ineffective for failing to object to an unsupported alternative in the lascivious-acts jury instruction. It affirmed because, even assuming counsel should have objected, Thorndike did not prove a reasonable probability that the verdict would have been…

The court affirmed an indefinite spousal-support award of $1,400 per month while child support continues and $2,000 per month thereafter. It held that the award was equitable because the marriage lasted nearly twenty-seven years, Linda had substantially lower earning capacity after years outside the workforce, and…

The court affirmed Ambrose's convictions and sentences, holding that he failed to preserve his challenge to the acquittal-first lesser-included-offense instruction and could not establish ineffective-assistance prejudice from it.

The court held that a sentencing judge must state the reasons for a sentence either orally on the record or in the written sentencing order, and a defendant who waived reporting of the sentencing hearing did not waive appellate review when the order omitted those reasons.

The court held that the State did not breach the conditional plea offer because Dudley took the polygraph only after the offer had expired and did not detrimentally rely on it before withdrawal.

The court held that article I, section 17 of the Iowa Constitution categorically prohibits mandatory minimum imprisonment schemes for offenses committed by juveniles because they prevent sentencing courts from considering youth and its attendant circumstances as mitigating factors.

The court affirmed Putman’s conviction, holding that limited evidence concerning two video titles found among child pornography on his electronic devices was admissible to prove the identity of the perpetrator.

The court held that Rhoades's guilty plea lacked a factual basis because the plea record did not establish the statutory intimate-contact requirements of intentional exposure to bodily fluid in a manner that could reasonably result in HIV transmission.

The court held that a parent's methamphetamine addiction, without additional evidence of circumstances creating an imminent likelihood of nonaccidental physical injury, does not support a CINA adjudication under Iowa Code section 232.2(6)(b).

On further review, the Supreme Court of Iowa vacated the court of appeals' reversal and reinstated the juvenile court's termination of both parents' rights to their one-year-old daughter under Iowa Code section 232.116(1)(h).

The court held that absence from custody is a lesser included offense of escape when the escape conviction is based on the charged and instructed theory that the defendant intentionally left a community-based correctional facility without consent.

The court affirmed Thompson’s second-degree murder conviction, holding that the evidence did not support a voluntary-manslaughter instruction, the challenged hearsay was properly excluded or harmless, and the defendant failed to satisfy the statutory threshold for access to the victim’s mental-health records.

The court held that the rule prohibiting mandatory life-without-parole sentences for juvenile homicide offenders applies retroactively on collateral review. It further held that Ragland's commuted sentence requiring sixty years before parole eligibility was the functional equivalent of life without parole and…

The court affirmed Null’s convictions and rejected his ineffective-assistance challenges concerning the plea colloquy and withdrawal of his juvenile-transfer motion. It held that the Iowa Constitution requires individualized consideration of youth before imposing a lengthy term-of-years sentence that requires a…

The court held that Finney's ineffective-assistance challenge to his guilty plea failed because the entire record, particularly the minutes of testimony, supplied an objective factual basis for attempted murder even though the plea colloquy did not identify that evidence.

The court held that the warrantless search of Kern's home violated article I, section 8 of the Iowa Constitution because her parole agreement did not establish consent and no recognized exception to the warrant requirement applied.