James H. Andreasen

In State v. Carter, the defendant was convicted of first-degree sexual abuse and attempted murder after evidence showed he abducted a woman, committed sexual acts against her, and inflicted life-threatening injuries including cutting her trachea nearly in half during a continuous sequence of events. On appeal, he claimed ineffective assistance of trial counsel for failing to object to the court's response to a jury question about when sexual abuse ends and for not moving for acquittal on the sexual abuse charge due to insufficient proof of serious injury. The Iowa Court of Appeals affirmed the convictions, holding that a serious injury under Iowa Code section 709.2 need not occur simultaneously with the sexual acts if it is part of an unbroken chain of events, and that the court's jury response was consistent with this standard. The court found no breach of duty by counsel and sufficient evidence to support the verdict.

criminal lawprocedure

In State v. Randle, the defendant was charged with felony offenses, released on bail after agreeing to court orders, and then failed to appear for the second day of his trial, leading to his conviction in absentia under Iowa Rule of Criminal Procedure 25(2) after the court found his absence voluntary. The State later charged him with failure to appear under Iowa Code section 811.2(8), but the district court dismissed the charge on the ground that the defendant had waived his right to be present. The appellate court reversed the dismissal, holding that a defendant's waiver of the constitutional right to presence under Rule 25 does not create a corresponding right to be absent or bar prosecution for failure to appear. The court reasoned that defendants have a separate duty to appear, reinforced by bail bond conditions, and that statutes and rules allowing trials to proceed without the defendant do not equate to permission to absent oneself without consequence.

criminal lawprocedure

The case involved a challenge by David M. Stanley and Iowans For Tax Relief against the Iowa State Treasurer's issuance of tax and revenue anticipation notes (TRANs), claiming that the use of these notes, combined with delayed payments and accounting practices, created unconstitutional debt under article VII, section 2 of the Iowa Constitution beyond the $250,000 limit, and that GAAP should be used for compliance. The district court dismissed the petition, and the Iowa Supreme Court affirmed the decision. The court reasoned that the TRANs were short-term instruments repaid within the same fiscal year from anticipated revenues, consistent with statutory intent, did not create a "core" of prohibited debt, and the reimbursement agreements were limited to current fiscal year funds, with the state's budget basis accounting deemed reasonable.

taxes

In State v. Schutz, the defendant was convicted of first- and second-degree robbery based solely on eyewitness identifications from McDonald's employees after a 1996 armed robbery; the trial court denied his request for expert testimony on the reliability of such identifications, following the per se exclusion rule from State v. Galloway. The Iowa Supreme Court reversed the convictions and remanded for a new trial. It held that Iowa Rule of Evidence 702 governs admissibility of expert opinion evidence on a case-by-case basis when the testimony would assist the jury, rejecting the prior categorical bar on eyewitness-identification experts. The court noted that no other state maintained a per se exclusion and that trial courts retain discretion to evaluate reliability and helpfulness. Dissenters argued the Galloway rule remained sound.

criminal lawprocedure

This case involved Ward Ramsey's challenge to the revocation of his driver's license by the Iowa Department of Transportation after he refused chemical testing following a traffic stop for running a stop sign. The Supreme Court of Iowa affirmed the district court's decision upholding the revocation. The court held that the DOT had authority under the Iowa Administrative Procedure Act to review the administrative law judge's initial decision rescinding the revocation. Additionally, the reviewing officer's finding that the arresting officer had reasonable grounds to believe Ramsey was operating while intoxicated was supported by substantial evidence.

criminal lawprocedure

The case involved a prisoner who escaped from a correctional facility, faced institutional disciplinary sanctions including solitary confinement, administrative segregation, loss of good time, and restitution, and was then prosecuted criminally for escape under Iowa Code section 719.4(1). The defendant moved to dismiss the criminal charges, arguing that the prior administrative punishment barred the prosecution under the Double Jeopardy Clause. The trial court denied the motion, and the Iowa Supreme Court affirmed, holding that prison disciplinary sanctions do not constitute punishment for double jeopardy purposes when they are not grossly disproportionate to the state's interest in maintaining order. The court relied on longstanding precedent distinguishing administrative discipline from criminal penalties and found the sanctions here were not so punitive as to trigger double jeopardy protections. The opinion also addressed and rejected challenges to jury instructions and the denial of a new trial motion based on newly discovered evidence.

criminal lawprocedure