State of Iowa v. David Raymond Fritz, 16-0311

On May 26, 2015, James Remmick heard a loud noise while driving past neighbor David Fritz standing at the roadside; James believed rocks had been thrown at his car.
James stopped, called the sheriff, and later saw Fritz kicking rocks toward the ditch; a deputy arrived ~20 minutes later and observed mud splatter and chips to the car's paint and glass.
James had the car repaired; he testified he paid a $500 deductible (total repair estimates were testified to at higher amounts).
Fritz was charged with criminal mischief in the second degree; a jury convicted him of the lesser-included offense of criminal mischief in the fourth degree.
Fritz appealed, arguing (1) improper hearsay admission about repair costs, (2) improper rebuttal testimony by Megan Remmick, and (3) insufficient evidence to support the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of testimony about repair payment	State relied on James's testimony that he paid $500 to repair the car as admissible, non-hearsay or otherwise harmless error	Fritz argued James's testimony about payment and repair estimates was hearsay/nonverbal out-of-court conduct and improper	Not preserved as to $500 testimony (no timely objection); larger amounts were nonprejudicial because jury awarded only $200–$500
Rebuttal testimony by Megan Remmick	Testimony was admissible to contradict Fritz's denial of communications and to show motive/intent	Fritz argued rebuttal was irrelevant or collateral	No abuse of discretion; testimony was relevant to intent and contradicted Fritz's testimony denying communications
Sufficiency of the evidence	State argued facts (audible impact, Fritz nearby, mud/chips, animosity history, repair payment) permitted inference Fritz threw a rock and intended damage	Fritz argued evidence was insufficient—no eyewitness to throw and his denial	Substantial evidence supported the conviction when viewed in the light most favorable to the State; jury credibility determinations upheld
Whether intent was proven	State argued intent could be inferred from circumstantial evidence and hostile interactions	Fritz argued lack of direct proof of intent	Court held specific intent could be inferred from the circumstances and evidence presented, sustaining the conviction

State v. Dullard, 668 N.W.2d 585 (Iowa 2003) (standard of review for hearsay rulings)
In re Det. of Williams, 628 N.W.2d 447 (Iowa 2001) (abuse-of-discretion review for relevance rulings)
State v. Odem, 322 N.W.2d 43 (Iowa 1982) (permitting contradiction of adverse witness by showing facts contrary to testimony)
State v. Fowler, 248 N.W.2d 511 (Iowa 1976) (inadmissible matter is collateral if not material to the case)
State v. Chang, 587 N.W.2d 459 (Iowa 1998) (specific intent requirement for criminal mischief)
State v. Plaster, 424 N.W.2d 226 (Iowa 1988) (low bar for relevance inquiry)
State v. Romer, 832 N.W.2d 169 (Iowa 2013) (standard for reviewing sufficiency of evidence)
State v. Showens, 845 N.W.2d 436 (Iowa 2014) (consider record in light most favorable to State and include reasonable inferences)
State v. Hennings, 791 N.W.2d 828 (Iowa 2010) (jury verdict binding absent absence of substantial evidence)
State v. Howse, 875 N.W.2d 684 (Iowa 2016) (definition of substantial evidence)
State v. Shanahan, 712 N.W.2d 121 (Iowa 2006) (jury’s role in weighing credibility and evidence)