State of Iowa v. Dennis Duane Richards, 809 N.W.2d 80

Dennis Richards was convicted of second-degree murder and second-degree arson for strangling his ex-wife and setting her house on fire.
The Court of Appeals reversed and remanded, finding error in excluding a late-disclosed defense witness, a physical therapist, Miller-Jacobs.
The Supreme Court vacated the Court of Appeals and affirmed Richards' convictions, deeming any error harmless given overwhelming guilt evidence.
Evidence showed Cyd Richards died by strangulation before the fire; DNA on nails and shirt supported Richards' involvement; arson tools and accelerants were found near his residence.
Richards disclosed Miller-Jacobs late; the State moved to strike; the district court excluded Miller-Jacobs as an expert witness, but allowed lay testimony from Richards' mother.
The State argued the late disclosure would prejudice its case; trial occurred December 1–11, 2009, with Richards ultimately convicted and sentenced to 50 years (murder) and 10 years (arson).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Miller-Jacobs improperly excluded as an expert?	Richards argues exclusion harmed defense; late disclosure was justified delay.	State contends late disclosure prejudicial and non-discoverable.	Harmless error; no substantial rights affected; evidence against Richards was overwhelming.
Were the 'bad acts' (alcohol use, domestic violence, and killings-related statements) admissible?	Richards contends prejudicial and unduly inflammatory.	State argues evidence is relevant to motive and intent in a murder case.	Admissible; probative value not substantially outweighed by prejudice; consistent with precedent.
Did the trial court abuse discretion in ruling on the late-disclosed expert testimony under Rule 2.13(4)?	Richards claims burden on defense outweighs prejudice to State.	State asserts necessity of excluding to protect against undue prejudice.	No abuse; relevant factors supported exclusion given time constraints and risk of prejudice.
Do the challenged evidentiary rulings require a new trial?	Exclusion of Miller-Jacobs and admission of bad acts unfairly tilted the case.	Evidentiary rulings were within discretion and did not prejudice substantial rights.	No new trial required; convictions affirmed.

State v. Babers, 514 N.W.2d 79 (Iowa 1994) (abuse of discretion requires prejudice to override denial)
State v. Newell, 710 N.W.2d 6 (Iowa 2006) (hearsay and prior acts evidence admissibility specifics for murder cases)
State v. Magnuson, 308 N.W.2d 83 (Iowa 1981) (waiver of speedy-trial deadline considerations in criminal procedure)
State v. O'Connell, 275 N.W.2d 197 (Iowa 1979) (prior acts showing malice and status of relationship relevant to identity and intent)
State v. Duncan, 710 N.W.2d 34 (Iowa 2006) (two-step analysis for admissibility of bad-acts evidence; probative value vs. prejudice)
State v. Taylor, 689 N.W.2d 116 (Iowa 2004) (prior acts show motive and possible intent in domestic violence context)