State of Iowa v. Donald Dean Gridley, 14-1773

Donald Gridley and his father left a funeral; Gridley drank heavily at the reception and later a truck they were in slid down an embankment, killing the father.
Gridley was found at the scene appearing intoxicated; he told a deputy he’d been in an accident and thought his father might be dead; a urine test hours later showed an elevated alcohol level and other drugs.
The father was found pinned on the passenger-side floorboard; witnesses and physical evidence (steering-wheel damage, red mark on Gridley’s chest, DNA from steering wheel/dashboard matching Gridley) tended to indicate Gridley was the driver.
Some witnesses (including the vehicle owner’s acquaintances) testified the father typically drove and was seen near the driver’s door before departure; one witness left early after speaking with them.
A state trooper testified about steering-wheel marks and that the father’s facial injuries were consistent with being on the passenger side; defense objected to the trooper’s qualifications for that opinion.
Gridley was convicted of vehicular homicide; he appealed, challenging sufficiency of evidence on who drove, certain opinion testimony, a jury instruction on refusal to give urine, and the district court’s standard for his new-trial motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency: who operated the vehicle	State: evidence (admissions, witnesses, steering-wheel damage, DNA, injuries) supports Gridley drove	Gridley: father was the driver; testimony that father usually drove and seen by driver door	Affirmed — substantial evidence supports jury finding Gridley drove
Expert testimony: trooper’s opinion on steering-wheel marks and passenger-side injuries	State: trooper qualified by accident-investigation experience; may rely on shared knowledge	Gridley: trooper lacked personal knowledge, vouched for other officer, not a forensic pathologist	Affirmed — trooper could rely on shared knowledge and had sufficient accident-investigator expertise; no counsel breach in failing to object to some points
Jury instruction on test refusal	State: refusal to provide urine is admissible under Iowa Code; instruction proper	Gridley: State failed to show implied-consent steps required to invoke refusal rule	Affirmed — deputy’s testimony that Gridley refused was enough to allow instruction under §321J.16
Motion for new trial: standard applied by district court	State: district court’s sufficiency analysis was adequate	Gridley: district court applied wrong (sufficiency) standard instead of weight-of-the-evidence standard	Reversed as to this ruling — remanded for district court to apply weight-of-the-evidence standard on new-trial motion

State v. Owens, 418 N.W.2d 340 (Iowa 1987) (shared-knowledge rule among cooperating officers)
State v. Schubert, 346 N.W.2d 30 (Iowa 1984) (knowledge of one officer presumed shared by others in an investigation)
State v. Palmer, 554 N.W.2d 859 (Iowa 1996) (acknowledging prior applications of shared-knowledge rule)
State v. Tinius, 527 N.W.2d 414 (Iowa Ct. App. 1994) (vehicular homicide conviction upheld despite evidence the deceased had driven in past)
Hyler v. Garner, 548 N.W.2d 864 (Iowa 1996) (trial court has discretion to qualify expert witnesses)
State v. Maxwell, 743 N.W.2d 185 (Iowa 2008) (ineffective-assistance review for claims based on failure to preserve error)
State v. Ellis, 578 N.W.2d 655 (Iowa 1998) (distinguishing sufficiency standard from weight-of-the-evidence standard for new-trial motions)
State v. Nitcher, 720 N.W.2d 547 (Iowa 2006) (remand for application of correct new-trial standard)