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State v. Jenkins
Supreme Court of Iowa · 2010-09-17 · cited 44×
In State v. Jenkins, the defendant was convicted of third-degree kidnapping and assault with intent to commit sexual abuse and was ordered to pay restitution to Iowa's Crime Victim Compensation Program for payments made to the victim for lost wages and other expenses. The district court, relying on precedent, ruled it had no discretion to review the claim and ordered full reimbursement of $946.60 without examining causation. On appeal, the Iowa Supreme Court reversed, holding that while restitution to the program is mandatory, the sentencing court must verify that the compensated losses meet the statutory causation requirements under Iowa Code section 915.86, as the offender was not a party to the program's prior decisions. The case was remanded for a factual determination of whether the crimes proximately caused the specific injuries compensated by the program.
criminal lawprocedure
Iowa Network Services, Inc. v. Iowa Department of Revenue
Supreme Court of Iowa · 2010-07-02 · cited 5×
Iowa Network Services, Inc., a competitive long-distance telephone provider, sought a refund of sales and use taxes paid on computer equipment purchased for its business between 1998 and 2003, claiming an exemption under Iowa Code section 422.45(27)(a)(4) for computers used in data processing by commercial enterprises. The Iowa Department of Revenue denied the claim, and an administrative law judge and the department director upheld the denial on the ground that INS's property was centrally assessed under chapter 433, triggering an exception to the exemption in sections 422.45(27)(c)(3) and 427A.1(1)(b). The district court affirmed, and the Iowa Supreme Court affirmed on appeal, concluding that a 1996 amendment in section 476.1D(10) altered only the manner of valuation and did not divest the department of assessment authority under chapter 433, and that a 2006 statutory exemption would have been unnecessary if the equipment had already been exempt.
taxesbusiness & regulatoryproperty
State v. TAEGER
Supreme Court of Iowa · 2010-04-30 · cited 22×
In State v. Taeger, the defendant faced criminal charges for operating a motor vehicle while intoxicated and filed a motion to suppress evidence based on alleged deficiencies in testing procedures and officer certification. The State moved to voluntarily dismiss the charges with prejudice before the motion was ruled on, stating it lacked sufficient evidence for trial, which would have prevented the defendant from using a favorable suppression ruling to challenge related evidence in a parallel civil proceeding to revoke his driver's license. The district court granted the dismissal over the defendant's objection, finding it complied with the requirement that dismissals be in the furtherance of justice. On appeal, the Iowa Supreme Court reversed, holding that once a suppression motion is pending, a dismissal is not in the furtherance of justice under Iowa Rule of Criminal Procedure 2.33(1) unless the State provides grounds independent of those in the motion, to avoid undermining the legislative policy in Iowa Code section 321J.13(6). The case was remanded for adjudication of the suppression motion.
criminal lawprocedure
In Re Property Seized for Forfeiture From Young
Supreme Court of Iowa · 2010-04-09 · cited 25×
This case involved a challenge to Iowa's forfeiture law after a handgun and ammunition were seized from Michael Young during a 2002 traffic stop and DUI arrest. More than five years later, the State filed an in rem forfeiture complaint under Iowa Code chapter 809A, and Young argued that section 809A.13(3) unconstitutionally prevented him from filing an answer, violating his right to procedural due process. The Iowa Supreme Court ruled that the statute's plain language barring answers in verified-complaint proceedings without a prior timely claim is unconstitutional as applied, because it denies property owners notice and a meaningful opportunity to be heard. However, the district court had properly allowed Young to file an answer anyway, so the default forfeiture order was affirmed when he declined to do so. The court addressed only the constitutional issue on further review.
criminal lawpropertyprocedurecivil rights
State v. Jordan
Supreme Court of Iowa · 2010-03-05 · cited 12×
The case involved a defendant convicted of second-degree theft after the district court refused to extend the deadline for pretrial motions to permit a diminished responsibility defense, which new counsel sought to raise following appointment after the original deadline had passed. The Iowa Supreme Court vacated the court of appeals decision, reversed the district court judgment, and remanded the case, concluding that good cause existed to extend the deadline because new counsel had recently been appointed, the state was not prejudiced, and the proposed defense was legally available for the specific-intent crime at issue. The court further held that the district court abused its discretion in denying the extension and that the error was not harmless, as it prevented development of evidence regarding the defendant's mental state at the time of the offense.
criminal lawprocedure
Veal v. State
Supreme Court of Iowa · 2010-02-26 · cited 42×
In Veal v. State, a woman convicted of first-degree murder as a fourteen-year-old in 1995 and sentenced to mandatory life without parole challenged her sentence in a 2008 postconviction relief action, claiming it violated the cruel and unusual punishment clauses of the Iowa and U.S. Constitutions. The district court and court of appeals dismissed the action as untimely under the three-year statute of limitations in Iowa Code section 822.3. The Iowa Supreme Court reversed, holding that the claim qualified as a challenge to an illegal sentence under Iowa Rule of Criminal Procedure 2.24(5)(a), which can be raised at any time and is not subject to the postconviction relief time limits, following its recent decision in State v. Bruegger. The court remanded for further proceedings on the merits of the constitutional claim.
criminal lawprocedure