State of Iowa v. Charles David Brown, 19-1377

On July 7, 2018, a beige SUV that had shown up earlier at Willie Outlaw’s house returned at night; three men emerged, one with an AR-15, shots were fired, and Outlaw was wounded.
Officer Tindall, who had seen the SUV earlier, heard the shots, followed the SUV, and observed four people flee; he recognized Brown as the front-seat passenger who ran out carrying a silver-and-black rifle; Brown discarded the rifle and initially escaped.
Physical items tying Brown to the vehicle that night included an A’s jersey in the SUV and a same-night Western Union receipt listing Brown as sender found outside the passenger door.
Brown gave pretrial notice of an alibi and testified he was at a friend’s apartment from about 8:00 p.m.; two defense witnesses corroborated his nighttime alibi.
The State rebutted with Barbara (Outlaw’s daughter), who identified Brown as one of the three men and the person she saw pull out the gun; the defense later obtained officer bodycam recording showing Barbara earlier said she did not know who the three men were.
After close of evidence but before closing arguments, defense moved to reopen the record to introduce the prior inconsistent statement (via recall or officer testimony); the trial court denied the motion under Iowa Rules of Evidence 5.611(a) and 5.613(b). Brown was convicted and appealed, arguing the denial was an abuse of discretion; the court of appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion in denying defense motion to reopen the record to introduce extrinsic evidence of a witness’s prior inconsistent statement	Brown: reopening was necessary to show Barbara’s prior bodycam statement (that she didn’t know the men) contradicted her in-court ID and was necessary for substantial justice	State: court properly exercised discretion; record was closed after rebuttal, rules limit extrinsic impeachment, and reopening at that stage would be untimely and prejudicial	Denied abuse of discretion; appellate court affirmed the trial court’s decision to refuse reopening
Whether the court should address Brown’s ineffective-assistance and constitutional challenge to Iowa Code § 814.7 on direct appeal	Brown: trial counsel ineffective for failing to object to witness testimony and § 814.7 is unconstitutional; alternatively plain error	State: such ineffective-assistance claims must be raised in postconviction proceedings and Supreme Court precedent forecloses plain-error review	Court declined to address on direct appeal; followed precedent requiring PCR for ineffective-assistance claims

State v. Long, 814 N.W.2d 572 (2012) (trial court has broad discretion to reopen the record)
State v. Mason, 203 N.W.2d 292 (1972) (courts given wide leeway in permitting reopening of cases)
State v. Teeters, 487 N.W.2d 346 (1992) (lists factors courts should consider before reopening the record)
State v. Tucker, 959 N.W.2d 140 (2021) (ineffective-assistance claims must be decided in postconviction proceedings, not on direct appeal)
State v. Treptow, 960 N.W.2d 98 (2021) (Supreme Court considered and rejected the constitutional challenges to § 814.7)
State v. Beck, 854 N.W.2d 56 (2014) (appellate courts must follow controlling supreme court precedent)