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State of Iowa v. Adam Eugene Coy
23-1476
Iowa Ct. App.
Dec 4, 2024
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Background

  • Adam Coy was convicted by a jury of attempted murder, willful injury causing serious injury, and domestic abuse causing bodily injury against his fiancĂ©, 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)
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Case Details

Case Name: State of Iowa v. Adam Eugene Coy
Court Name: Court of Appeals of Iowa
Date Published: Dec 4, 2024
Docket Number: 23-1476
Court Abbreviation: Iowa Ct. App.