State of Iowa v. David Dwight Jackson, 4 N.W.3d 298

David Jackson was involved in a fatal car accident and was convicted of several offenses, including vehicular homicide (OWI), reckless driving, leaving the scene of an accident resulting in death, and operating a vehicle without the owner's consent.
Jackson claimed at trial that he blacked out due to a medical condition and contested the State's assertion that intoxication caused the accident.
The State called a jail healthcare administrator (Peterson) to testify about Jackson's medical records to rebut his claim, though these records were not admitted into evidence.
Jackson objected to this testimony on hearsay, privilege, and best evidence grounds, but his objections were overruled.
The court of appeals upheld most rulings, finding the testimony admissible under the business records exception, and that Jackson had waived privilege by testifying about his medical condition.
The Iowa Supreme Court granted further review to consider whether Peterson’s testimony about the medical records was admissible under hearsay exceptions.

Issue	Jackson's Argument	State's Argument	Held
Admissibility of blood test (motion to suppress)	Warrant application had false info, so inadmissible	Even without errors, probable cause for warrant existed	Evidence admissible; district court ruling affirmed.
Jail admin testimony about medical records (hearsay)	Testimony was hearsay, records not admitted	Business records/medical diagnosis exceptions apply	Testimony was hearsay; not admissible under exceptions.
Business records must be admitted, not just described	Testimony about records is not enough	Content can be testified to by custodian without records	Records themselves must be admitted, not just testimony.
Harmless error regarding improper admission	Testimony was critical (not cumulative/overwhelming)	Substantial other evidence exists, so error was harmless	Error was prejudicial for all but vehicle consent conviction

Franks v. Delaware, 438 U.S. 154 (false statements in warrant affidavits and standards for suppression)
State v. Reynolds, 746 N.W.2d 837 (Iowa 2008) (discussing business records exception and need for actual record)
State v. Smith, 876 N.W.2d 180 (Iowa 2016) (affirming evidentiary rulings on alternative grounds)
State v. Walker, 935 N.W.2d 874 (Iowa 2019) (burden on State to establish hearsay exception applies)
State v. Cagley, 638 N.W.2d 678 (Iowa 2001) (State bears burden to show hearsay exception)
State v. Newell, 710 N.W.2d 6 (Iowa 2006) (prejudice presumed from erroneous admission of hearsay)