State of Iowa v. Adam Eugene Coy
23-1476
Iowa Ct. App.Dec 4, 2024Background
- Adam Coy was convicted by a jury of attempted murder, willful injury causing serious injury, and domestic abuse causing bodily injury against his fiancé, J.S.
- The incident involved Coy firing a shot into the ceiling and then shooting J.S. in the back of the head; J.S. survived and testified against Coy.
- Coy claimed at trial that J.S. attempted suicide or was shot accidentally, and provided inconsistent statements to authorities.
- Over defense objection, J.S. testified about prior abuse by Coy, including multiple incidents of violence and threats with weapons.
- Coy appealed his convictions, arguing the district court erred in admitting evidence of his prior acts of domestic abuse.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of prior domestic abuse evidence | Evidence shows intent; not admitted to show bad character. | Evidence about prior acts is unfairly prejudicial and should be excluded. | Admitting the prior acts evidence was not an abuse of discretion. |
Key Cases Cited
- State v. Tipton, 897 N.W.2d 653 (Iowa 2017) (standard of review for evidentiary rulings is abuse of discretion)
- State v. Buenaventura, 660 N.W.2d 38 (Iowa 2003) (reversal required only if prejudice is shown after abuse of discretion)
- State v. Sullivan, 679 N.W.2d 19 (Iowa 2004) (three-part test for admitting prior bad acts under rule 5.404(b))
- State v. Taylor, 689 N.W.2d 116 (Iowa 2004) (history of domestic abuse highly relevant; prior bad acts probative in domestic violence cases)
