State of Iowa v. Christopher Clay McNeal
2017 Iowa Sup. LEXIS 72
| Iowa | 2017Background
- On Feb 22, 2015 Matthew Browning was assaulted in a tool shop, suffering a skull fracture and permanent injuries; a sledgehammer was missing.
- Christopher McNeal was charged with attempted murder, burglary, willful injury causing serious injury, and related counts; indictment filed March 30; McNeal demanded a speedy trial (90-day deadline June 29).
- A plea offer was made and expected to resolve the case on June 9, but McNeal rejected it; trial was rescheduled and a June 16 pretrial raised expert witness scheduling problems for the week of June 23.
- The State asked to empanel a jury on June 23/26 but delay presentation of evidence until July 7 because three medical experts were unavailable (one out of the country until June 30); the court allowed empaneling and limited the proof delay to July 7.
- Jury was empaneled June 26; evidence presented July 7; McNeal convicted of lesser included offenses and received a 10-year sentence with a five-year mandatory minimum weapon enhancement.
- Court of appeals reversed on speedy-trial grounds; Iowa Supreme Court vacated that decision and affirmed convictions, holding the district court did not abuse its discretion in finding good cause for the brief delay.
Issues
| Issue | State's Argument | McNeal's Argument | Held |
|---|---|---|---|
| Whether empaneling a jury then pausing proof to after the 90‑day deadline violated Rule 2.33(2)(6) absent good cause | Short, eight‑day delay was justified because critical medical experts were unavailable despite the State's scheduling efforts; good cause exists for a brief extension | The start‑and‑stop was a device to evade the speedy‑trial deadline; State failed to show factual proof of necessity or due diligence | Court assumed start‑and‑stop is treated like an extension but held district court did not abuse discretion: expert unavailability + plea negotiation context sufficed for brief extension |
| Sufficiency of evidence for convictions | Evidence (victim’s account, injury, missing hammer, McNeal’s statements) supported convictions | Argued evidence insufficient and alternative explanations possible | Convictions supported by substantial evidence; sufficiency upheld |
| Ineffective assistance re failure to object to drug‑use evidence and hearsay (owner's testimony about victim's statement) | Drug evidence was admissible for motive; hearsay was cumulative of victim’s direct testimony | Counsel should have objected to propensity evidence and hearsay | No ineffective assistance: drug evidence relevant to motive; hearsay cumulative so no prejudice |
| Admissibility of demonstrative sledgehammer replica | Replica was demonstrative, labeled as not the original, and assisted jurors | Replica unduly prejudicial / improper | Admission of demonstrative replica was within trial court discretion; no abuse |
Key Cases Cited
- State v. Miller, 637 N.W.2d 201 (Iowa 2001) (speedy‑trial rules reviewed for legal error; court discretion circumscribed)
- State v. Petersen, 288 N.W.2d 332 (Iowa 1980) (short continuance for unavailable expert can constitute good cause)
- State v. Jones, 281 N.W.2d 13 (Iowa 1979) (holding that a defendant is "brought to trial" when the jury is empaneled and sworn)
- State v. Taylor, 881 N.W.2d 72 (Iowa 2016) (good cause must be demonstrated by facts; disfavor generalities)
- State v. Winters, 690 N.W.2d 903 (Iowa 2005) (good cause focuses on reason for delay; trial court’s discretion reviewed for abuse)
- United States v. Brown, 819 F.3d 800 (6th Cir. 2016) (treating federal Speedy Trial Act start‑and‑stop plans as requiring compliance; unavailability and diligence examined)