State of Iowa v. Adam Eugene Coy
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.
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,
Free access — add to your briefcase to read the full text and ask questions with AI
Related
Cite This Page — Counsel Stack
State of Iowa v. Adam Eugene Coy, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-adam-eugene-coy-iowactapp-2024.