State of Iowa v. Armando Adame III, 20-0993

In October 2017 Armando Adame III and two friends drove across several Iowa towns seeking methamphetamine; the deal fell through and tensions rose.
On a rural Floyd County gravel road Adame and victim Michael Johns argued; Adame retrieved a sawed-off shotgun from the trunk and shot Johns, who was later found dead.
Adame was charged with first-degree murder and being a felon in possession of a firearm; after trial a jury convicted him on both counts.
At trial the State introduced testimony from Ashley Clement, who said weeks before the killing she came home to Adame pointing what she identified as a sawed-off shotgun at her during an argument with Johns; Johns intervened and moved the gun away.
Adame moved to exclude Clement’s testimony as improper character/other-acts evidence under Iowa R. Evid. 5.404 and as unduly prejudicial under rule 5.403; the district court admitted the testimony after a Rule 5.403/5.404(b)(2) balancing.
On appeal Adame challenged that evidentiary ruling; the Iowa Court of Appeals affirmed, finding no abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of Clement's testimony as other-acts evidence under Iowa R. Evid. 5.404(b)(2)	Testimony was relevant to motive, intent, lack of mistake and identified the same type of weapon used to kill Johns	Testimony was only propensity evidence of bad character and should be excluded	Admissible: testimony relevant to non-character issues; clear-proof threshold met by witness testimony; probative value outweighed prejudice
Whether district court abused discretion in Rule 5.403 balancing	Evidence was necessary and probative; less inflammatory than charged murder; probative value substantial	Evidence was substantially more prejudicial than probative and likely to inflame jury	No abuse of discretion: court gave thoughtful balancing; prejudice risk reduced because charged offense was more serious; affirmed

State v. Helmers, 753 N.W.2d 565 (Iowa 2008) (standard of review for evidentiary rulings)
State v. Tipton, 897 N.W.2d 653 (Iowa 2017) (abuse-of-discretion standard)
State v. Richards, 879 N.W.2d 140 (Iowa 2016) (three-part other-acts admissibility test)
State v. Taylor, 689 N.W.2d 116 (Iowa 2004) (clear-proof threshold and 5.403 balancing factors)
State v. Caples, 857 N.W.2d 641 (Iowa Ct. App. 2014) (witness testimony can satisfy clear-proof requirement)
State v. Knox, 464 N.W.2d 445 (Iowa 1990) (other-acts showing defendant’s state of mind/motive)
State v. Rodriquez, 636 N.W.2d 234 (Iowa 2001) (prejudice analysis when charged crime is more serious than other act)
State v. Plaster, 424 N.W.2d 226 (Iowa 1988) (risk that other-acts evidence will inflame jury)
State v. Tyler, 873 N.W.2d 741 (Iowa 2016) (deference to thoughtful district-court evidentiary rulings)