State of Iowa v. Arzel Jones
2012 Iowa Sup. LEXIS 75
| Iowa | 2012Background
- Jones was sentenced to consecutive prison terms totaling 35 years after a three-day bench trial.
- The district court entered a written verdict; the court did not reconvene in open court to announce it.
- Jones waived a jury trial; two informations charged different sets of offenses arising from November 30 and December 4 events.
- A 911 transcript of the ex-boyfriend’s call was not disclosed before trial, prompting a Brady challenge.
- Jones challenged the verdict entry, the fork as a dangerous weapon, Brady compliance, trial counsel withdrawal, and jury-trial waiver on appeal.
- The Iowa Supreme Court granted further review and addressed whether Rule 2.17(2) requires open-court verdicts and whether a Brady violation occurred, affirming in part and vacating in part the court of appeals’ decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rule 2.17(2) requires open-court verdicts after bench trials | Jones argues ‘on the record’ means in open court per Liddell | State contends Canady avoids open-court requirement for constitutional reasons | Rule 2.17(2) requires open-court verdicts; district court cure suffices; no remand needed |
| Whether the State committed a Brady violation | Jones contends nondisclosure of the 911 transcript was favorable and material | State did not suppress favorable evidence or violate Brady | No Brady violation; nondisclosure not material to guilt; transcript not likely to change outcome |
Key Cases Cited
- Liddell v. State, 672 N.W.2d 805 (Iowa 2003) (in-person waiver of jury trial; 'on the record' meaning open court procedures)
- Lumadue v. State, 622 N.W.2d 302 (Iowa 2001) (rule 2.23(3)(d); written judgment entry suffices for ‘on the record’)
- Johnson v. State, 445 N.W.2d 337 (Iowa 1989) (sentencing order can satisfy ‘on the record’ for judgment entry)
- Canady v. United States, 126 F.3d 352 (2d Cir. 1997) (verdict announcement after bench trial; right to open proceedings; constitutional concerns)
- Waller v. Georgia, 467 U.S. 39 (1984) (public/safeguards when evidence is suppressed; remedy considerations)