State v. Reynolds

765 N.W.2d 283, 2009 Iowa Sup. LEXIS 36, 2009 WL 1162864
CourtSupreme Court of Iowa
DecidedMay 1, 2009
Docket07-1617
StatusPublished
Cited by43 cases

This text of 765 N.W.2d 283 (State v. Reynolds) is published on Counsel Stack Legal Research, covering Supreme Court of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Reynolds, 765 N.W.2d 283, 2009 Iowa Sup. LEXIS 36, 2009 WL 1162864 (iowa 2009).

Opinions

STREIT, Justice.

Outside of the pool hall in Rock Rapids, Brad Reynolds and Dan Kramer got into a fight. Kramer was injured, and Reynolds was arrested for assault. Before trial, the district court entered an evidentiary ruling allowing the State to introduce evidence that Reynolds had previously threatened and assaulted Kramer. At trial, Kramer testified to eleven past incidents with Reynolds. Before the submission of the case to the jury, Reynolds requested jury instructions regarding the prior-bad-acts evidence and his character for peacefulness. The court denied Reynolds’ request for the instruction on character and gave a modified version of the prior-bad-aets instruction. The jury found Reynolds guilty [287]*287of assault causing bodily injury. Reynolds appealed, and the court of appeals reversed. Even though the prior-bad-acts evidence was relevant to Reynolds’ motive on the night in question, it was prejudicial error to admit the prior bad acts since the danger of unfair prejudice outweighs their probative value. We therefore vacate the court of appeals’ decision, reverse the judgment of the district court, and remand the case.

I.Background Facts and Prior Proceedings.

On September 27, 2006, Dan and Maggie Kramer were at the pool hall in Rock Rapids drinking beer and playing pool. Brad Reynolds, Maggie’s ex-husband, stopped in to chat with a friend. Dan Kramer and Reynolds had a history of animosity between them because Maggie had started dating Kramer while she was still married to Reynolds. Kramer approached Reynolds to ask him a question about Reynolds’ and Maggie’s son. Reynolds indicated he did not want to talk to Kramer. Later, Reynolds and Kramer got into an altercation outside the pool hall. Reynolds invited Kramer to take a swing at him. Reynolds claims he turned to leave and Kramer hit him in the back of the head. Reynolds hit Kramer three times, and Kramer called 911. Kramer sought medical treatment and was diagnosed with a sprained jaw, a minor concussion, and a probable broken nose. Reynolds was charged with assault causing bodily injury.

Before trial, the State requested an evi-dentiary ruling permitting it to present evidence Reynolds had “harassed, threatened, assaulted, and intimidated” Kramer on several occasions in the past in order to demonstrate Reynolds’ “motive, intent, and opportunity.” Reynolds filed a resistance. The court granted the motion, concluding “a logical connection between a defendant’s intent at the time of a crime (assault) and his prior acts of violence existed and that evidence of prior bad acts was relevant and admissible.” At trial, Kramer testified to eleven past incidents involving Reynolds.

1. February 2002: Reynolds pushed Kramer outside the Sportsman’s and told Kramer that (i) the only thing keeping Reynolds from beating Kramer up is the fact that Reynolds is a lawyer and Kramer was not worth his license to practice law, and (ii) if Reynolds ever saw Kramer within five feet of his wife, he would beat Kramer senseless.
2. May 2002: At the country club golf course, Reynolds shook his fist at Kramer and said he would be waiting for him.
3. May 2002: Reynolds went into Todd’s Cafe and said that he should have thrown Kramer off the balcony the other day at the golf course.
4. Summer 2002: Kramer was walking his dog in front of the old high school, and Reynolds pushed Kramer down and said some obscene things to him.
5. September 2002: In front of the Sportsman’s, Reynolds got in Kramer’s face, pushed him down, and poked him in the eye.
6. June 15, 2003: Reynolds approached Kramer while he and his son were sitting in his car in front of the Dollar General. Reynolds threatened Kramer, punched him, and then asked Kramer’s son whether he was “going to grow up to be a pussy like his dad.” In exchange for dropping the assault charge, Reynolds agreed to abide by a no-contact order for one year and to undergo an anger management evaluation.
[288]*2887. February 2005: At a wrestling meet, Reynolds and Kramer were both in the concession lunch line, and Reynolds blew up at Kramer and cursed at him.
8. February 2005: At another wrestling meet, Reynolds tried to start a fight with Kramer in the bathroom, but someone came in.
9. July 2005: While Kramer and his son were riding their bikes, Reynolds drove by in his car, rolled down the window, and tried to spit at Kramer, but missed and hit his son’s leg instead.
10. January 2006: Reynolds spit at Kramer outside of the West Sioux High School and said to Kramer, “come on, let’s do something.”
11. March 2006: Kramer and his son walked into the grocery store and Reynolds was there. Reynolds cursed at them.

The first five incidents, which involved Reynolds pushing and threatening Kramer, occurred in 2002 after Reynolds discovered his wife Maggie was having an affair with Kramer. The sixth incident occurred in 2003 while Reynolds and Maggie were in the midst of getting a divorce. All six of these incidents occurred more than three years before the incident in question. The incidents resumed over a year and a half later in 2005. The remaining five incidents involved Reynolds spitting at Kramer and/or cursing at him. The most recent incident occurred about six months before the incident in question. Defense counsel objected on relevance and hearsay grounds. A few witnesses testified to Reynolds’ peaceful character.

Before submission of the case to the jury, Reynolds requested the court include Iowa Criminal Jury Instructions 200.34, concerning prior-bad-acts evidence, and 200.38, concerning character and reputation. The court denied Reynolds’ request for the instruction on character and reputation and gave a modified version of the prior-bad-acts instruction. The jury found Reynolds guilty of assault causing bodily injury. Reynolds appealed, asserting the court erred in admitting prior-bad-acts evidence, giving the modified prior-bad-acts instruction, and refusing to give the requested character instruction. The court of appeals reversed as to the prior-bad-acts instruction and, without determining whether any of the acts were admissible or not, concluded the district court abused its discretion in issuing a blanket ruling admitting all prior bad acts. The court of appeals did not address the character instruction. The State appealed.

II. Scope of Review.

We review a district court’s evi-dentiary rulings regarding the admission of prior bad acts for abuse of discretion. State v. Parker, 747 N.W.2d 196, 203 (Iowa 2008). “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. Rodriquez, 636 N.W.2d 234, 239 (Iowa 2001) (quoting State v. Maghee, 573 N.W.2d 1, 5 (Iowa 1997)). If an abuse of discretion occurred, reversal will not be warranted if error was harmless. State v. Henderson, 696 N.W.2d 5, 10 (Iowa 2005).

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Bluebook (online)
765 N.W.2d 283, 2009 Iowa Sup. LEXIS 36, 2009 WL 1162864, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-reynolds-iowa-2009.