State of Iowa v. Adam Eugene Coy

CourtCourt of Appeals of Iowa
DecidedDecember 4, 2024
Docket23-1476
StatusPublished

This text of State of Iowa v. Adam Eugene Coy (State of Iowa v. Adam Eugene Coy) 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.

Bluebook
State of Iowa v. Adam Eugene Coy, (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 23-1476 Filed December 4, 2024

STATE OF IOWA, Plaintiff-Appellee,

vs.

ADAM EUGENE COY, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Greene County, Kurt J. Stoebe,

Judge.

A defendant appeals his convictions for attempted murder, willful injury

causing serious injury, and domestic abuse causing bodily injury, arguing the

district court erred in admitting testimony of prior acts of domestic assault.

AFFIRMED.

Martha J. Lucey, State Appellate Defender, and Maria Ruhtenberg,

Assistant Appellate Defender, for appellant.

Brenna Bird, Attorney General, and Joseph D. Ferrentino, Assistant

Attorney General, for appellee.

Considered by Tabor, C.J., and Chicchelly and Sandy, JJ. 2

SANDY, Judge.

“Nobody tries to shoot themself in the back of the head.” Following a jury

trial, Adam Coy was convicted of one count of attempted murder, one count of

willful injury causing serious injury, and one count of domestic abuse causing

bodily injury. He argues the district court erred in permitting testimony of prior acts

of domestic assault after he claimed his fiancé, who was shot in the back of the

head at further than point-blank range, attempted to commit suicide or was

accidentally shot. We affirm.

I. Background Facts and Proceedings

In 2023, Adam Coy and his fiancé, J.S., were engaged and lived together

in Grand Junction. On February 4, Adam fired a shot into the ceiling of their

bedroom and then shot J.S. in the back of the head. A neighbor confirmed the

shots occurred around 8:15 p.m. A 911 call placed at 9:52 p.m. brought law

enforcement to the residence. They found dried blood in the hallway leading to

the bedroom. J.S. was still conscious and vomiting in the bedroom. Coy provided

inconsistent claims relating to what occurred, including that J.S. “shot herself in the

head—right in front of [him]” and that she had been “depressed.”

At trial J.S. testified, over objection, that Coy had previously abused her.

She testified that on one occasion he took a “big knife” and “dragged the blade

down my arm,” leaving a scar still visible at the time of trial. She also testified that

Coy owned a double-edge sword that he would hold against her stomach, and that

he strangled her “two to three times a week.” She also recounted times that he

urinated on her and other incidents in which he threw hot cigarette butts on her.

She testified that, on multiple occasions, Coy would hold a gun to her head with 3

the safety on. J.S. confirmed that Coy escalated this behavior when, on February

4, he demonstrated to her that he was turning the safety off and pointed the gun

at her. Her next memory was waking up on the bedroom floor.

The jury convicted Coy for attempted murder, willful injury causing serious

injury, and domestic abuse assault. He now appeals.

II. Standard of Review

“Evidentiary rulings are generally reviewed for abuse of discretion.” State v.

Tipton, 897 N.W.2d 653, 690 (Iowa 2017). The district court has abused its

discretion when it “exercises its discretion on ‘grounds or for reasons clearly

untenable or to an extent clearly unreasonable.’” Id. (citation omitted). “Even if an

abuse of discretion is found, reversal is not required unless prejudice is shown.”

State v. Buenaventura, 660 N.W.2d 38, 50 (Iowa 2003).

III. Discussion

Coy argues the district court erred in admitting evidence of prior domestic

abuse.

Evidence of other crimes, wrongs, or acts are inadmissible “to prove a

person’s character in order to show that on a particular occasion the person acted

in accordance with the character.” Iowa R. Evid. 5.404(b)(1). But such evidence

may be admissible for other purposes “such as proving . . . intent.” Iowa R.

Evid. 5.404(b)(2).

We undertake a three-step test in determining whether the proffered

evidence is consistent with the uses permitted under rule 5.404(b)(2). First, if the

“evidence is relevant and material to some legitimate issue in dispute, then it is

prima facie admissible.” State v. Sullivan, 679 N.W.2d 19, 25 (Iowa 2004). Next, 4

“there must be clear proof the individual against whom the evidence is offered

committed the bad act or crime.” Id. Third, if the first two prongs are satisfied, “the

court must then decide if [the evidence’s] probative value is substantially

outweighed by the danger of unfair prejudice to the defendant.” Id.

Coy does not contest the first two prongs in the three-step test for admitting

bad-acts evidence under rule 5.404(b)(2). And the State does not contest that the

evidence was prejudicial. So we are tasked with deciding whether the district court

erred in determining the admitted evidence did not cause “unfair prejudice” to Coy.

See id. (emphasis added).

Our supreme court acknowledges the “logical connection between a

defendant’s intent at the time of a crime, when the crime involves a person to whom

he has an emotional attachment, and how the defendant has reacted to

disappointment or anger directed at that person in the past, including acts of

violence, rage, and physical control.” State v. Taylor, 689 N.W.2d 116, 125

(Iowa 2004). The supreme court has also recognized that “[d]omestic abuse often

has a history highly relevant to the truth-finding process.” Id. at 130 (citation

omitted). Domestic violence is often “a means to achieve power and control by the

abuser and once successfully used engenders additional incidents of abuse.” Id.

at 128 n.6 (citation omitted). “Thus, evidence of prior bad acts is especially

relevant and probative in domestic violence cases because of the cyclical nature

of domestic violence.” Id. (cleaned up).

Coy’s intent was directly at issue before the jury. He expressly stated to

authorities that J.S. had attempted suicide. At trial, Coy argued that the gunshots

were accidental, and his history of abuse was vital to rebutting that story. Previous 5

acts of domestic violence, particularly the previous instances when Coy had

pointed a firearm at J.S., helped disprove any theory that February 4 was an

accident. His history of pointing a firearm at J.S. while leaving the safety on was

directly relevant to whether his act of turning the safety off on February 4 was

accidental or intentional.

Moreover, J.S.’s testimony relating to prior bad acts was a relatively small

amount of testimony compared to the hundreds of pages of total trial testimony.

The State focused on the eight minutes Coy spent assaulting J.S. before the

gunshots. The State noted the ninety-nine minutes that passed between the

gunshots and the 911 call. The prosecutor emphasized Coy’s lack of emotion, his

decision to change his clothing immediately after shooting J.S., and Coy’s own

words: “I’m going to keep kicking you.”

Lastly, the State relied on the expert opinions of multiple medical doctors,

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Related

State v. Sullivan
679 N.W.2d 19 (Supreme Court of Iowa, 2004)
State v. Taylor
689 N.W.2d 116 (Supreme Court of Iowa, 2004)
State v. Buenaventura
660 N.W.2d 38 (Supreme Court of Iowa, 2003)
State of Iowa v. Eddie Tipton
897 N.W.2d 653 (Supreme Court of Iowa, 2017)

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