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State v. Marin
Supreme Court of Iowa · 2010-09-24 · cited 71×
In State v. Marin, the defendant was charged with two counts of first-degree murder after confessing to killing two people and raised a defense based on involuntary intoxication from drugs and alcohol. The district court refused to give the defendant's proposed jury instruction distinguishing involuntary intoxication as a complete defense and instead used a standard intoxication instruction that did not differentiate between voluntary and involuntary intoxication, while also providing a diminished responsibility instruction. The court of appeals addressed the involuntary intoxication issue on the merits, but the Iowa Supreme Court held that the defendant failed to preserve error on whether involuntary intoxication constitutes a complete defense to criminal liability. The court affirmed the district court's judgment, concluding that the given instructions, read together, fairly informed the jury that intoxication could negate the specific intent, premeditation, and deliberation required for first-degree murder. The decision vacated the portion of the court of appeals ruling addressing the unpreserved claim but otherwise upheld the outcome.
criminal lawprocedure
Doe v. Iowa Department of Human Services
Supreme Court of Iowa · 2010-07-09 · cited 39×
The case involved Jane Doe challenging the Iowa Department of Human Services' decision to place her on the central child abuse registry after finding she committed child abuse by failing to properly supervise her child through repeated exposure to the child's domestically abusive father in 2001 and 2002. The district court had affirmed the agency's final decision. The Iowa Supreme Court reversed and remanded, holding that Iowa Code section 232.71D does not authorize placement on the registry for the specific form of child abuse defined as failure to provide proper supervision under section 232.68(2)(d) and rule 441-175.21, because the legislature omitted that category from the enumerated grounds for registry placement in section 232.71D(3)(f).
family law
Iowa Supreme Court Attorney Disciplinary Board v. Templeton
Supreme Court of Iowa · 2010-07-02 · cited 119×
The case involved the Iowa Supreme Court Attorney Disciplinary Board charging attorney Mark A. Templeton with violations of the Iowa Rules of Professional Conduct after he was caught repeatedly looking into the windows of a residence occupied by young women, admitting to a long-standing problem with such behavior for sexual gratification. On de novo review, the court found that Templeton violated one ethical rule related to his misconduct. The court decided to suspend his law license indefinitely with no possibility of reinstatement for three months, requiring a professional fitness evaluation before any reinstatement, rather than the two-year suspension recommended by the commission. The reasoning centered on the nature of the violation, protection of the public, deterrence, Templeton's fitness to practice, and comparisons to sanctions in similar cases involving criminal conduct or sexual misconduct.
criminal lawprocedure
Clay County v. Public Employment Relations Board
Supreme Court of Iowa · 2010-06-04 · cited 12×
The case concerned whether Iowa’s Public Employment Relations Act (PERA) protected a public employee, James Sikora, from discipline after he negotiated higher wages for himself and fellow crew members with the private Clay County Fair Board while also working part-time there. The Public Employment Relations Board found the activity protected and ruled the county committed a prohibited practice by terminating Sikora; the district court affirmed. The Iowa Supreme Court reversed, holding that PERA’s protections apply only to concerted activities directed at a public employer, not a private one, because the statute’s text and purpose are narrower than the National Labor Relations Act and are limited to fostering harmonious relations between the government and its own employees. The court therefore remanded with instructions to dismiss the complaint.
labor & employment
Bank of the West v. Kline
Supreme Court of Iowa · 2010-05-14 · cited 26×
The case involved Bank of the West suing to collect on a defaulted loan and related guaranties from Acme Land Company and several individual and corporate guarantors, including spouses Christine Walters and Phyllis Kline. The spouses asserted that the bank violated the Equal Credit Opportunity Act by requiring their guaranties solely due to their marital status rather than insufficient creditworthiness of other parties. The district court allowed the ECOA violations to be raised as affirmative defenses despite the counterclaims being time-barred, rendering the guaranties unenforceable, and granted summary judgment to the spouses. On appeal, the Iowa Supreme Court affirmed, holding that guarantors qualify as applicants under the ECOA and can use violations as affirmative defenses, with no genuine issue of material fact on creditworthiness because the bank failed to present timely supporting evidence.
business & regulatorycivil rightsprocedure
Iowa Supreme Court Attorney Disciplinary Board v. Hauser
Supreme Court of Iowa · 2010-05-14 · cited 26×
The case involved the Iowa Supreme Court Attorney Disciplinary Board charging attorney Ross G. Hauser with multiple violations of ethical rules for neglecting a client's dissolution-of-marriage case. Hauser failed to attend the trial, resulting in a default judgment against the client, did not communicate properly, and ignored requests for information from the board. The court reviewed the matter de novo and, considering Hauser's extensive prior disciplinary record for similar issues, decided to suspend his law license indefinitely with no possibility of reinstatement for six months, requiring proof of fitness to practice and accounting for client fees before reinstatement. The reasoning centered on the need to protect the public from unfit lawyers based on the pattern of neglect and non-compliance.
procedurefamily law