State of Iowa v. Diamond S. Wilson
16-0156
| Iowa Ct. App. | Oct 26, 2016Background
- Defendant Diamond S. Wilson was convicted by a jury of intimidation with a dangerous weapon, carrying weapons, and unlawful possession of a firearm under Iowa law.
- Incident: after a dispute during a card game at the defendant’s girlfriend’s apartment, Wilson allegedly pulled a handgun, pointed it at the victim, and threatened to kill her; a struggle occurred and a gun discharged.
- The victim fled and later testified Wilson called and offered money to persuade her to say he was not the shooter.
- Forensic corroboration: bullet hole in the floor where Wilson stood, a bullet jacket, and a fresh dent in the ductwork consistent with the bullet trajectory; the firearm itself was not recovered.
- Wilson moved for a new trial arguing the verdict was contrary to the weight of the evidence (victim not credible; no gun recovered); the district court denied the motion and the appeal challenges that denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the verdict was contrary to the evidence such that a new trial was required | State argued evidence (victim testimony + forensic corroboration) supported convictions and credibility/recovery issues were for jury | Wilson argued victim lacked credibility and absence of the gun made verdict contrary to weight of evidence | Court affirmed denial of new trial; no abuse of discretion in district court |
| Whether absence of recovered firearm requires acquittal or new trial | State: recovery not necessary to prove elements when other evidence suffices | Wilson: no recovered gun undermines prosecution’s case | Court: lack of gun did not mandate new trial given corroborating evidence |
| Whether appellate court may reweigh evidence/credibility | State: credibility and weight are jury/district court functions; appellate review limited | Wilson: urged reweighing to find verdict against weight of evidence | Court: reiterated appellate courts do not reassess credibility or reweigh; review limited to abuse-of-discretion standard |
| Standard for granting new trial on weight grounds | State: district court properly applied standard and exercised discretion sparingly | Wilson: district court should have found weight countered verdict | Court: applied precedent requiring clear, manifest abuse to overturn denial and found none |
Key Cases Cited
- State v. Nitcher, 720 N.W.2d 547 (Iowa 2006) (new-trial standard when verdict contrary to law or evidence)
- State v. Reeves, 670 N.W.2d 199 (Iowa 2003) (contrary to the evidence means contrary to the weight of the evidence)
- State v. Ellis, 578 N.W.2d 655 (Iowa 1998) (trial courts should grant new trials carefully and sparingly)
- United States v. Ashworth, 836 F.2d 260 (6th Cir. 1988) (appellate courts should not reassess witness credibility or reweigh evidence)
