State v. Tyler

• Decision Date: 30 June 2015
• Docket Number: No. 13–0588.,13–0588.
• Parties: STATE of Iowa, Appellee, v. Hillary Lee TYLER, Appellant.
• Court: Iowa Supreme Court

867 N.W.2d 136

STATE of Iowa, Appellee
v.
Hillary Lee TYLER, Appellant.

No. 13–0588.

Supreme Court of Iowa.

June 30, 2015.
Rehearing Denied Aug. 14, 2015.

867 N.W.2d 143

Mark C. Smith, State Appellate Defender, and Maria Ruhtenberg, Assistant Appellate Defender, for appellant.

Thomas J. Miller, Attorney General, Tyler J. Buller and Laura Roan, Assistant Attorneys General, and Ricki Osborn and Cori Kuhn Coleman, County Attorneys, for appellee.

Randall D. Armentrout and Ryan G. Koopmans of Nyemaster Goode, P.C., Des Moines, for amicus curiae Iowa Association of County Medical Examiners.

Opinion

ZAGER, Justice.

Hillary Tyler appeals her conviction for murder in the second degree for the death of her newborn son (Baby Tyler). See Iowa Code §§ 707.1, .3 (2011). She maintains the district court erred in denying several of her trial motions, including: a motion in limine to exclude a medical examiner's testimony and autopsy report opining to the cause and manner of Baby Tyler's death, a motion to suppress evidence obtained by police during the search of Tyler's hotel room, and a motion to suppress statements Tyler made to police.

867 N.W.2d 144

She also maintains there was insufficient evidence to support her conviction. The court of appeals held the district court abused its discretion in allowing the medical examiner to testify to the cause and manner of Baby Tyler's death and in admitting the unredacted autopsy report into evidence. Accordingly, it reversed the judgment of the district court and remanded the case for a new trial. The court of appeals did not address the remaining issues raised in the appeal.

The State applied for further review, which we granted. On further review, we conclude the district court abused its discretion in allowing the medical examiner to testify to the cause and manner of Baby Tyler's death because the medical examiner based his opinions primarily, if not exclusively, on Tyler's inconsistent and uncorroborated statements to the police as opposed to objective, scientific, or medical evidence. For the same reason, the district court should have redacted any reference to cause and manner of death in the autopsy report. Additionally, we conclude the district court erred in denying Tyler's motion to suppress evidence obtained by the police during the search of the hotel room based solely on the legal conclusion that Tyler had no reasonable expectation of privacy in the room because she obtained it for the purpose of committing a crime. Thus, we reverse this motion and remand the issue for further hearing and ruling by the district court concerning the applicability of exceptions to the warrant requirement or exclusionary rule. We affirm the district court's denial of Tyler's motion to suppress statements she made to police. We vacate the decision of the court of appeals, affirm the judgment of the district court in part and reverse in part, and remand the case for additional proceedings consistent with this opinion and a new trial.

I. Background Facts and Proceedings.

Tyler and Rodney Cyphers began dating in 2010. In early 2011, Cyphers noticed Tyler was beginning to exhibit signs of pregnancy and asked her if she was pregnant. Tyler denied being pregnant. She told Cyphers she was suffering from a medical condition that caused her to exhibit signs typically associated with pregnancy. Tyler was in fact pregnant. Over time, Tyler exhibited increased signs of pregnancy and began wearing looser fitting clothing. Even so, Tyler continued to deny she was pregnant to anyone who asked and refused to allow Cyphers to touch her abdomen.

In the summer of 2011, Cyphers's employer assigned him to a job at a plant located in Fort Dodge, Iowa. At the end of August, Tyler and Cyphers temporarily relocated to Coalville, Iowa, which is approximately ten miles south of Fort Dodge. While there, Tyler and Cyphers lived in a fifth-wheel trailer in a trailer park.

At approximately 3:00 a.m. on September 19, Tyler began experiencing mild contractions. At approximately 6:30 a.m., she called the Super 8 Hotel in Fort Dodge to inquire about a room. She spoke with the hotel manager who advised her that a room was available. Tyler arrived at the hotel approximately twenty minutes later and checked into room 225. Tyler occupied room 225 from approximately 6:50 a.m. until 4:30 p.m. At approximately 12:00 p.m., she gave birth to Baby Tyler in the bathroom of room 225. She then “laid around for a little bit” and “cleaned the bathroom floor” before returning to the trailer in Coalville. Cyphers was home when she arrived. Shortly before 7:00 p.m., Cyphers left to work a night shift.

867 N.W.2d 145

Tyler stayed alone at the trailer for the night.

After working the night shift, Cyphers returned to the trailer at approximately 7:15 a.m. on September 20. Tyler was present when he arrived. The couple ate breakfast and ran a few errands before returning to the trailer so that Cyphers could sleep. At approximately 10:15 a.m., Tyler returned to the hotel to check out of room 225. Upon Tyler's arrival, the hotel manager informed Tyler there had been a cancellation and room 225 was available for an additional night. Another member of the hotel staff had previously informed Tyler room 225 was not available for an additional night. Tyler rented room 225 for the night of September 20. Shortly thereafter, she left the hotel and returned to the trailer in Coalville. She intended to return to the room later that evening to clean it further.

At approximately 11:00 a.m., a housekeeper at the hotel entered room 225 to clean it. Because Tyler had not rerented the room until late that morning, the sheet informing the housekeeper of the room's rental status had not been updated to reflect that the room was a “stayover” as opposed to a “checkout.” The doorknob to the room had a “Do Not Disturb” sign hanging from it. Upon entering the room, the housekeeper observed the carpet was saturated with blood. Upon entering the bathroom, she further discovered “a lot of blood smear[ed] ... on the floor.” The housekeeper then exited the bathroom and discovered a “hoodie coat.” She picked it up and observed the inside of the coat was saturated with blood. Additionally, she observed two discarded vodka bottles and “$8 ... on the dresser by the TV,” which she thought was a tip. She also observed a garbage can in the room, which contained a “white towel bundled up” among other trash. She “slid the garbage can” across the room and discovered it was “heavy.” She did not empty the garbage can or further examine its contents. In a panicked state, she left the room and reported her findings to the hotel manager. The manager and the housekeeper returned to the room. Another housekeeper also entered the room “because she could tell there was something going on in the room.” The other housekeeper “pulled the can liner out of the garbage can” and the group observed the towel in the garbage can had some blood on it and the bottom of the garbage bag contained “fluid and some blood.” Although they did not see Baby Tyler's body, they were very concerned about the contents of the garbage can. The manager then called the police to report these findings.

Police were dispatched to the hotel at approximately 11:36 a.m. According to the responding officer, the original complaint “was for ... criminal mischief ... or ... vandalism[,] ... so that's what [he] was thinking going into it.” Upon arrival at the hotel, the responding officer spoke with the hotel manager who advised him what the hotel staff had observed. Accompanied by hotel staff, the officer entered room 225 to investigate. Thereafter, he contacted his supervisor who arrived within approximately ten minutes. Over the next twenty to fifty minutes, the officers looked around the room as several additional officers arrived at the scene. In the course of their investigation, officers observed that, in addition to the blood, there appeared to be other bodily fluids present in the room. Eventually, one of the officers moved the towel and other items in the garbage can. Beneath these items, he discovered Baby Tyler's body. At that point, it “didn't appear that there was any need to render any aid,” so the officers secured the room until they could obtain a search warrant.

867 N.W.2d 146

After officers discovered Baby Tyler's body, Fort Dodge police contacted the Iowa Division of Criminal Investigation (DCI). Detectives from the Fort Dodge Police Department, in cooperation with the DCI, were subsequently able to identify and locate Tyler. At approximately 2:08 p.m., Special Agent Michael Roehrkasse of the DCI, Special Agent Ray Fiedler of the DCI, and Detective Jody Chansler of the Fort Dodge Police Department went to the trailer in Coalville.¹ The officers were dressed in plain clothes as opposed to police uniforms. The officers approached the trailer and knocked on the door. Tyler answered. The officers' encounter with Tyler was audio recorded.

After making contact with Tyler, the officers told her they needed to speak with her. She told them she understood that she needed to speak with them. Detective Chansler asked Tyler if she needed any medical attention. She...