State of Iowa v. Charles Emanuel Hall, 16-0307

Charles Hall was convicted by a jury of first-degree murder and child endangerment causing serious injury for the death of three-year-old J.K.; sentenced to life without parole plus up to ten years (concurrent).
Evidence showed Hall was the only adult in the home when J.K. was found unresponsive on a bathroom floor with water in the tub; medical examiner concluded death by asphyxia by drowning and classified it a homicide.
Prior incidents included corporal punishment with a piece of wood and a thermal burn on J.K.’s face that had not been medically treated.
At trial, the State played the 911 call made by Hall’s roommate April Clair; after the call Clair left the stand distraught and vomited just outside the courtroom, audible to the jury. Defense moved for mistrial.
The district court denied the mistrial; on appeal Hall argued the hallway vomiting prejudiced his right to a fair trial.
Hall also appealed the sufficiency of the evidence for the child endangerment causing serious injury conviction, arguing the burn did not meet the statutory definition of "serious injury."

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused discretion by denying a mistrial after a State witness vomited outside the courtroom audible to the jury	State: witness illness was involuntary, isolated, unforeseeable, not intended to influence the jury; no curative instruction requested; evidence against Hall strong	Hall: the vomiting occurred immediately after emotional testimony and the 911 call, prejudiced the jury by eliciting sympathy for the State’s witness and emphasized damaging testimony	Court: denial of mistrial not an abuse of discretion; event was isolated, not shown to be unduly prejudicial, and evidence against Hall was strong
Whether evidence supports conviction for child endangerment causing serious injury (element: "serious injury")	State: hot-water burn and other injuries constituted serious injury supporting the charge	Hall: evidence insufficient that burn caused serious permanent disfigurement, substantial risk of death, protracted loss of function, or required surgery/GA—statutory definitions of "serious injury" not met	Court: insufficient evidence for "serious injury" as defined; conviction for that count reversed, but evidence supported lesser-included offense of child endangerment causing bodily injury (remand to amend judgment and resentence)

State v. Newell, 710 N.W.2d 6 (Iowa 2006) (mistrial standard and factors for evaluating prejudicial evidence)
State v. Sanford, 814 N.W.2d 611 (Iowa 2012) (standard for sufficiency-of-evidence review)
State v. McKee, 312 N.W.2d 907 (Iowa 1981) (definition and technical meaning of "serious injury")
State v. Hanes, 790 N.W.2d 545 (Iowa 2010) (scarring may constitute serious permanent disfigurement in some circumstances)
State v. Morris, 787 N.W.2d 788 (Iowa 2010) (finding lesser-included offense established when greater offense elements are found)
State v. Johnson, 784 N.W.2d 192 (Iowa 2010) (preservation of ineffective-assistance claims for postconviction proceedings)