State v. Rodriquez
| Decision Date | 15 November 2001 |
| Docket Number | No. 00-0763.,00-0763. |
| Parties | STATE of Iowa, Appellee, v. Aladdin RODRIQUEZ, Appellant. |
| Court | Iowa Supreme Court |
Douglas E. Johnston, Muscatine, for appellant.
Thomas J. Miller, Attorney General, Mary E. Tabor, Assistant Attorney General, Richard R. Phillips, County Attorney, and Dana Christensen and Teresa Stoeckel, Assistant County Attorneys, for appellee.
The defendant, Aladdin Rodriquez, appeals his multiple criminal convictions arising out of an incident of domestic abuse. Concluding that evidence of prior and subsequent occasions of domestic abuse had been improperly admitted, the Iowa Court of Appeals reversed the defendant's convictions and remanded for a new trial. We granted the State's application for further review and now vacate the court of appeals decision and affirm the district court's judgment of conviction and sentence.
Melinda Enriquez, age twenty, was seen in the emergency room of a Muscatine hospital on the evening of October 11, 1999. She reported that her boyfriend had beaten her, but she refused to identify him by name. She said her boyfriend hit her with a metal belt buckle, and hit her with his hand and kicked her with his feet in the head, chest, and abdomen. She also alleged her boyfriend stomped on her neck.
A physical examination revealed injuries consistent with this history. Enriquez had bruising around her nose, forehead, left eye and cheek. In addition there were bruises on the right side of her neck, her right upper chest, her lower left rib cage, across the upper part of the left shoulder, her right upper arm and the outer aspect of her left upper arm. Evidence of "sparing," a pattern often left at the site of impact of an object, was also noted. This sparing was consistent with being hit by a belt buckle with great force. Although x-rays revealed no fractures, there was some retropharyngeal soft tissue swelling in Enriquez's neck, indicating that her trachea had been depressed backward. In addition, Enriquez's abdomen was tender, and she was stiff and sore.
When a Muscatine police officer arrived at the hospital, Enriquez gave him several names for the perpetrator, but never identified her true assailant. It was not until a subsequent incident, approximately one month later, when the defendant chased Enriquez with a knife, that she informed the police that the defendant was responsible for her injuries of October 11, 1999.
On December 3, 1999, the defendant was charged with five separate offenses relating to the October 11 assault: (1) attempted murder; (2) willful injury; (3) third-degree kidnapping; (4) aggravated domestic assault; and (5) serious domestic assault. See Iowa Code §§ 707.11, 708.4, 710.1, 710.4, 708.2A(2)(c), 708.2A(2)(b) (1999). The defendant pled not guilty.
Prior to trial, the State filed notice that it intended to introduce evidence from Enriquez and her mother regarding other incidents of abuse. The defendant objected to this evidence at trial, but the court permitted testimony by Enriquez about prior occasions of abuse and about the incident that occurred after the October 11 assault. Her mother corroborated this testimony. In addition to the testimony of these witnesses, the State called the emergency room physician who treated Enriquez for her injuries, the officer who interviewed Enriquez at the hospital, and an expert who testified about "the battered women's syndrome."
After the court overruled his motion for a directed verdict, the defendant took the stand. The defendant did not dispute that he had caused Enriquez's injuries, but claimed he was jealous and angry. He admitted that he assaulted Enriquez with a belt, hit her with his hand, and stepped on her cheek and neck. He denied choking Enriquez and denied confining her in their apartment.
After the defendant's testimony, the case was submitted to the jury. The jury found the defendant guilty of all charges except attempted murder. At his later sentencing, the defendant urged that the two domestic assault convictions should be merged in the willful injury conviction. The court declined to do so and sentenced the defendant to serve consecutive sentences for each charge of which he was convicted.
The defendant appealed, challenging his convictions on four grounds: (1) error in admitting evidence of prior and subsequent bad acts; (2) error in allowing the domestic abuse expert to testify; (3) the trial judge was not impartial; and (4) error in failing to merge the assault convictions into the willful injury conviction.1 We transferred the case to the court of appeals. That court reversed the defendant's convictions, concluding that the prior and subsequent bad acts evidence was improperly admitted. We granted further review.
A. Scope of review. This court "generally review[s] evidentiary rulings for abuse of discretion." Williams v. Hedican, 561 N.W.2d 817, 822 (Iowa 1997); accord State v. Bugely, 562 N.W.2d 173, 177 (Iowa 1997) (). An abuse of discretion occurs when the trial court exercises its discretion "on grounds or for reasons clearly untenable or to an extent clearly unreasonable." State v. Maghee, 573 N.W.2d 1, 5 (Iowa 1997). "A ground or reason is untenable when it is not supported by substantial evidence or when it is based on an erroneous application of the law." Graber v. City of Ankeny, 616 N.W.2d 633, 638 (Iowa 2000).
B. Analytical framework. Iowa Rule of Evidence 404(b) addresses the admissibility of evidence of other bad acts. It states:
Evidence of other crimes, wrongs, or acts is not admissible to prove the character of a person in order to show that he acted in conformity therewith. It may, however, be admissible for other purposes, such as proof of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident.
Iowa R. Evid. 404(b). This court has recently observed that rule 404(b) "is a codification of our common-law rule that one crime cannot be proved by proof of another." State v. Castaneda, 621 N.W.2d 435, 439 (Iowa 2001). Thus, rule 404(b) seeks to exclude evidence that serves no purpose except to show the defendant is a bad person, from which the jury is likely to infer he or she committed the crime in question. Id. at 439-40. Accordingly, to be admissible, evidence must be relevant "`to prove some fact or element in issue other than the defendant's criminal disposition.'" Id. at 440 (quoting State v. Cott, 283 N.W.2d 324, 326 (Iowa 1979)).
Evidence is relevant ... "when it has `any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence.'" Evidence is relevant if a reasonable person might believe the probability of the truth of the consequential fact to be different if the person knew of the challenged evidence.
State v. Brown, 569 N.W.2d 113, 116 (Iowa 1997) (quoting State v. Plaster, 424 N.W.2d 226, 229 (Iowa 1988)).
State v. Wade, 467 N.W.2d 283, 284-85 (Iowa 1991) (). Since our decision in Wade, we have stated that there must be "clear proof" that the defendant committed the prior bad acts. Brown, 569 N.W.2d at 117.
Before we examine the ruling in this case, we briefly consider the standard of review in the context of the analysis required of the trial court. The abuse of discretion standard of review applicable in this matter recognizes that whether evidence of prior crimes should be admitted is a judgment call on the part of the trial court.
Analyzing and weighing the pertinent costs and benefits [of admitting prior acts evidence] is no trivial task. Wise judges may come to differing conclusions in similar situations. Even the same item of evidence may fare differently from one case to the next, depending on its relationship to the other evidence in the case, the importance of the issues on which it bears, and the likely efficacy of cautionary instructions to the jury. Accordingly, much leeway is given trial judges who must fairly weigh probative value against probable dangers.
1 McCormick on Evidence § 185, at 647-48. The complaining party—here the defendant...
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