Lynn Mary Staats and Stanley Edgar Staats v. Richard Drew Yotter

CourtCourt of Appeals of Iowa
DecidedOctober 30, 2024
Docket23-1694
StatusPublished

This text of Lynn Mary Staats and Stanley Edgar Staats v. Richard Drew Yotter (Lynn Mary Staats and Stanley Edgar Staats v. Richard Drew Yotter) is published on Counsel Stack Legal Research, covering Court of Appeals of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Lynn Mary Staats and Stanley Edgar Staats v. Richard Drew Yotter, (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 23-1694 Filed October 30, 2024

LYNN MARY STAATS and STANLEY EDGAR STAATS, Plaintiffs-Appellants,

vs.

RICHARD DREW YOTTER, Defendant-Appellee. ________________________________________________________________

Appeal from the Iowa District Court for Louisa County, Clinton Boddicker,

Judge.

Property owners appeal after a jury verdict for the defendant in their action

for negligence and trespass. AFFIRMED.

John Daufeldt, John C. Wagner, and Colin Smyka of John C. Wagner Law

Offices, P.C., Amana, for appellants.

Nicholas J. Huffmon, Elliott R. McDonald III, and Patrick Woodward of

Brooks Law Firm, P.C., Davenport, for appellee.

Heard by Tabor, C.J., Ahlers, J., and Bower, S.J.*

*Senior judge assigned by order pursuant to Iowa Code section 602.9206

(2024). 2

TABOR, Chief Judge.

Orchard owners Lynn and Stanley Staats sued neighboring farmer Richard

Yotter for negligence and trespass. The jury found for Yotter on both claims, and

the district court denied the Staatses’ motion for new trial. The Staatses appeal,

arguing that the district court erred by (1) excluding a warning letter the Iowa

Department of Agriculture and Land Stewardship (IDALS) sent to Yotter and

(2) allowing the jury to view an electronic exhibit during deliberations. We find no

error in the district court’s exclusion of the warning letter on hearsay grounds and

no abuse of discretion in its decision to let the jury view the exhibit on a “clean”

laptop. So, we affirm.

I. Facts and Prior Proceedings

The Staatses own a chestnut orchard in Wapello. In June 2019, Stanley

Staats1 filed a formal complaint to the IDALS alleging that herbicide drifted from

Yotter’s farm field onto the Staatses’ orchard, damaging their chestnut trees. He

reported that Yotter “farm[s] the fields east and south of [the Staatses’ property]

and possibly sprayed during the week of May 20th.” Robert Mikota, an investigator

for the IDALS Pesticide Bureau, looked into the complaint. As part of Mikota’s

investigation, Yotter signed an affidavit stating that he applied herbicides to a farm

field “located approximately 2000 feet northeast of [the Staatses’] acreage” on

May 16, 2019.

Following the investigation, the Staatses sued Yotter for negligence and

trespass, alleging that he “applied an herbicide burndown application” to farmland

1 We will refer to Stanley Staats by his last name. 3

east of the Staatses’ orchard “in a manner inconsistent with label instructions and

the Code of Iowa,” which caused the destruction of 764 of the Staatses’ chestnut

trees.2 The case proceeded to jury trial.

The Staatses planned to offer into evidence a warning letter that Carol

Corbin, a case review officer for the IDALS, sent Yotter in June 2020. The letter

stated, in part: “Mr. Mikota documented that on May 16, 2019[,] at approximately

8:29 a.m., you made a burndown application to your soybean field located directly

east of Mr. Staats’[s] acreage.” The letter also stated: “Your use of a registered

pesticide inconsistent with its labeling or rules of the state is a violation of Iowa

Code paragraph 206.11(3)(b) which deems it unlawful for anyone to use a

pesticide in a manner inconsistent with label directions.”

Yotter moved in limine to exclude the warning letter, contending that it was

inadmissible hearsay, factually inaccurate, and unfairly prejudicial. The district

court reserved ruling on the admission of the letter until the Staatses formally

offered it as an exhibit. During trial, Yotter questioned Corbin about the letter

outside the presence of the jury. Corbin testified that the letter was intended to

summarize Mikota’s investigation based on “all the documentation, all the

information given.” She also explained, “I’m not taking sides when I case review.”

When Yotter asked about discrepancies between Mikota’s investigation reports

and her warning letter, Corbin testified that the letter was wrong about the location

of the field Yotter reported spraying:

2 The Staatses’ orchard was on the Iowa Sensitive Crop Registry in 2019, and they

were certified as organic growers. They marketed their crop to various restaurants and other consumers. Their experts testified that chestnuts can be eaten fresh but are mostly consumed after they are boiled or roasted. 4

Q. Okay. In your letter you state: “Mr. Mikota documented that on May 16, 2019, at approximately 8:29 a.m., you made a burndown application to your soybean field located directly east of Mr. Staats’ acreage.” That language is contrary to what the narrative says— A. Yes. Q. —inasmuch as Mikota documented that he made the spray down on Donnie Williams’ acreage, which is 2000 feet to the northeast; correct? A. The “east” in the letter is an error and should say “north.” That is my error. Q. What about “located directly east of Mr. Staats’ acreage”? A. Again, it should say “directly north,” not “east.” And I . . . didn’t catch that until I was reviewing the case file for the court today. Q. I see. So that . . . letter is in error? A. That is an error on the direction of where [Yotter’s] field is located to Mr. Staats’ property.

(Emphasis added.)

Yotter then moved to exclude the warning letter and Corbin’s testimony,

contending that her conclusions were not based on an articulable standard of

proof, the letter and testimony were factually inaccurate and unfairly prejudicial

under Iowa Rule of Evidence 5.403, and the letter was inadmissible hearsay. The

Staatses countered that Corbin “ought to be able to testify about her own letter

without it being hearsay,” and it was “a public record. Anybody can gain access to

this. That’s an exception, number (8).” They also contended that “this is one of

hundreds . . . of facts that the jury is going to have an opportunity to sort out in this

case.” The district court sustained Yotter’s objections and excluded the letter,

finding that it was hearsay without exception and its prejudicial effect would

outweigh its probative value under rule 5.403.

The date when Yotter applied herbicides to the field directly east of the

Staatses’ orchard—the alleged source of the herbicide drift—was a factual dispute 5

at trial. The Staatses claimed Yotter sprayed that field on May 16. Staats testified

that he discovered damage to his orchard from the herbicide drift on June 3. After

discovering the damage, Staats took photographs of Yotter’s field directly east of

the orchard. Yotter testified that he did not spray that field until June 10.

Both parties offered photographs that Staats took of that field on June 3.

The Staatses offered their photos in paper form. Staats testified that they were

“higher resolution photographs” and that he had them enlarged and printed at

Walmart. Yotter’s photo exhibits were saved on a flash drive and only shown to

the jury in digital form on the courtroom monitors. There were visible differences

in the coloration of the photographs offered by each side.3 And the parties disputed

whether the photographs showed “burndown” of plants in the field caused by

herbicides, which would indicate that the field was sprayed before the photos were

taken.

During deliberations, the jury submitted a request to the court to view

Yotter’s Exhibit VV. That exhibit, a flash drive, contained two electronic

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Lynn Mary Staats and Stanley Edgar Staats v. Richard Drew Yotter, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lynn-mary-staats-and-stanley-edgar-staats-v-richard-drew-yotter-iowactapp-2024.