UPDATES & ANALYSIS
Deja Deja Vu at the Iowa Supreme Court
by Ryan Koopmans | June 24, 2015
By Ryan Koopmans
The Iowa Supreme Court’s 2014-2015 term ends on June 30, meaning that the justices will issue decisions in all remaining cases by that date or shortly after. Of the 105 cases submitted this year, two were dismissed (one voluntarily and one by the Supreme Court) and ten remain outstanding (and really only nine, as two cases involve the same criminal case). Of those ten, two involve the Iowa Constitution’s search-and-seizure clause (King and Gaskins) and two involve the constitutionality of juvenile sentencing (Louisell and Seats). That means that this year will end a lot like the last two years. And it probably won’t be harmonious. Those two issues–search and seizure and juvenile sentencing–have sharply divided the Cady Court and will almost surely do so again this year.
A list of the outstanding cases, prepared by Nyemaster Goode summer associates Amella Viso and Brad Novreske, is below the jump.
14-0175 State v. Louisell
The State appeals from the resentencing of Louisell who was convicted of first degree murder in 1988 (when she was 17) and sentenced to life without the possibility of parole. After the Iowa Supreme Court’s 2013 opinions in Ragland, Pearson, and Null, in which the Court ruled that mandatory life or near-life sentences for a juvenile amount to cruel and unusual punishment, the district court resentenced Louisell to a 25-year sentence that, in light of Louisell’s credit for time served, would result in her immediate release from prison. The State now argues the principles of cruel and unusual punishment allow a district court to strike down an unconstitutional sentence, but do not authorize it to create a determinate sentence.
13-1061 State v. King
The defendant appeals the district court’s overruling of a motion to suppress evidence and the judgment against him. The evidence in controversy was obtained after a search of the defendant’s home by his parole officer and a law enforcement officer while defendant was on parole. The officers were present in the home to determine whether the defendant’s GPS anklet was functioning properly. They subsequently searched his home. The defendant argues that the Court should require a warrant for searches unrelated to the initial reason for entering the home if the initial entry was premised on a parolee-oversight mission and not a law enforcement mission.
13-1960 State v Seats
The defendant challenges his sentence of life without parole for first degree murder committed as a juvenile, arguing that the district court failed to properly apply the test laid out in Miller v. Alabama to determine when it is appropriate to sentence juveniles to life without parole. The defendant seeks a categorical ban on juvenile life without parole sentences.
13-0588 State v. Tyler
The State appeals the Court of Appeals reversal of defendant’s conviction for second degree murder after the death of her newborn moments after delivery. The defendant at one point testified that she had drowned the baby in the bathtub, but recanted her testimony and claimed it was made under duress. During trial, the Medical Examiner testified that his conclusion that the newborn’s death was a homicide was based, in part, on the defendant’s testimony. The Court of Appeals ruled that this part of the Medical Examiner’s testimony should have been excluded, as his reliance on the defendant’s testimony amounts to a determination of the defendant’s credibility.
[Disclosure: Nyemaster Goode attorneys Ryan Koopmans and Randy Armentrout represent the Iowa Association of County Medical Examiners as amicus curiae. The brief is here.]
13-0830 State v. Tyler
The State seeks review of a Court of Appeals’ dismissal as moot of an appeal by the State questioning whether a district court can deny restitution reimbursements to grandparents where the grandparents did not have an opportunity to meet their grandson because he was murdered within minutes of birth. The determination of this appeal will hinge on the Court’s decision in 13-0588 which will determine whether defendant is entitled to a new trial.
13-1525 Sioux Pharm, Inc. v. Eagle Laboratories, Inc.
In this trade secrets misappropriation case, the issue is whether the district court abused its discretion when it denied Sioux Pharm’s protective motion by ordering Sioux Pharm to de-designate its standard operating procedures from attorney’s eyes only status to confidential and to produce documents in an un-redacted fashion during discovery. Eagle Labs contends that the denial of the protective motion should be affirmed as it needs the documentation to develop a defense. Sioux Pharms contends wider disclosure of the documents will result in trade secrets being available to a direct competitor.
14-0194 Rivera v. Woodward Resource Center
In this case, the justices are deciding how a jury should be instructed on the elements of a wrongful discharge claim. Under Iowa law, an employer is liable for wrongful discharge if the employee’s engagement in “protected conduct” (e.g., filing a worker’s compensation complaint) was the “determining factor” in firing the employee. Here, the court instructed the the jury that the plaintiff’s protected conduct (reporting improper conduct by another employee) was not the determining fact if the employer “had an overriding business reason for terminating” the plaintiff’s employment. The plaintiff says that the “overriding business reason” language should not have been included in the instruction.
13-1915 State v. Gaskins
Another search and seizure case. During a traffic stop, the police looked through a locked safe that was under the defendant’s seat; they didn’t have a warrant. The defendant now argues that the fact that the safe was located in a vehicle was not alone a sufficiently exigent circumstance to allow the officer to conduct a warrantless search where the vehicle was not capable of being driven away by the defendant, the officer’s safety was not at issue, and the officer could prevent the possible destruction of evidence by confiscating the safe without opening it.
13-1438 Sanon v. City of Pella
This case involves the drowning of two teen age boys while on a youth camp outing at the Pella Aquatic Center operated by the City of Pella . Plaintiffs alleged two sets of claims: (1) common law tort claims against the City and the the Fellowship of Christian Athletes (the camp host), and (2) constitutional due process violations against the City. The district court dismissed Plaintiffs’ due process violations by the City because Plaintiffs could not make the necessary showing to support such a claim. Second, the district court held the immunity statute found at Iowa Code section 670.4(12) applied and immunized the City from liability as to Plaintiffs’ tort claims to the extent they were based on alleged violations of administrative rules promulgated pursuant to Iowa Code chapter 1351. Plaintiffs argued the “criminal offense” exception to immunity found in section 670.4(12) applied because the City’s alleged violations of administrative rules constituted a criminal offense. Based upon a prior decision of the Iowa Court of Appeals and its own analysis of the issue, the district court ruled that such violations of administrative rules do not constitute a criminal offense within the meaning of the exception to the immunity statute. Plaintiffs appeal these rulings. The district court further held the “criminal offense” exception to the immunity statute did apply to Plaintiffs’ claims against the City to the extent the conduct could constitute the offense of involuntary manslaughter. The court issued this holding despite the absence of a criminal proceeding to obtain a criminal conviction, or even the possibility that such a proceeding could ever occur. The City cross-appeals this ruling.
14-0413 McQuistion v. City of Clinton
When Karen McQuistion became aware that she was pregnant, she notified her supervisors at the Fire Department and requested light duty. That request was eventually denied by the City Attorney and City Administrator. McQuistion later stopped working on the recommendation of her doctor. When she returned to work six months later, she was at the same rank and pay. She then brought suit against the City claiming discrimination and a violation of the Iowa Constitution because she was not given light-duty work as a result of her pregnancy. The lower court ruled on three different claims in favor the City. In one count, the judge ruled that McQuistion’s case was not similar to Clinton Police Officers who had been given light-duty when pregnant because the police bargaining unit contract calls for light duty in those situations and the fire department contract did not. In another count, McQuistion claimed it was a violation of equal protection under the constitution. The judge wrote that the plaintiff could not identify any other city employees, except the two Clinton Police Officers, who were treated more favorably. Referring to a previous section of the order the judge recalled the difference in union contracts and denied that claim. The City’s policies were cited by the district court for denying a claim that McQuistion was denied due process and holding that her employer was not obligated to provide her with her certain advantages for rights to become pregnant. He said the policies do not discriminate against her rights. Plaintiff appeals the lower court’s ruling.
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- Iowa Supreme Court Opinion and/or Further Review Conference
- Iowa Court of Appeals Oral Arguments
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