State of Iowa v. Hillary Lee Tyler, 2015 Iowa Sup. LEXIS 79

Background

Hillary Tyler gave birth in a Super 8 motel room; hotel staff discovered bloody sheets and, later, an infant’s body in a trash can. Police located Tyler and conducted a series of interviews; she made inconsistent statements but ultimately admitted she placed the newborn in a bathtub and drowned him.
The State charged Tyler with first-degree murder; the jury convicted her of second-degree murder.
Dr. Jonathan Thompson (Associate State Medical Examiner) performed the autopsy. His autopsy report initially listed cause and manner as “undetermined,” but after reviewing Tyler’s statements he concluded cause = drowning and manner = homicide.
Tyler moved to exclude Dr. Thompson’s opinion and the unredacted autopsy report, and to suppress physical evidence from the warrantless search of the motel room and her statements to police. The district court denied suppression and admitted the testimony; the court of appeals reversed on the expert-opinion issue and ordered a new trial.
The Iowa Supreme Court granted further review: it affirmed that Dr. Thompson’s cause/manner opinions were inadmissible because they rested primarily on Tyler’s uncorroborated statements (thus impermissibly bolstering credibility and not based on specialized medical evidence), reversed the denial of Tyler’s motion to suppress the motel-room evidence for reasons explained, and affirmed denial of suppression of Tyler’s statements as voluntary and noncustodial (majority). The case was remanded for a new trial.

Issues

Issue	Plaintiff's Argument (Tyler)	Defendant's Argument (State)	Held
Admissibility of ME’s cause/manner opinions	Dr. Thompson’s opinions were based primarily on Tyler’s statements and thus (1) impermissibly vouched for her credibility and (2) were not expert medical opinions	Medical examiner may rely on history/police information as physicians rely on patient history; his opinions assisted the jury	Court: Exclude ME’s opinions and redact autopsy conclusions — here opinions relied primarily on uncorroborated statements, not medical/scientific findings, and improperly vouched for credibility
Admission of unredacted autopsy report	Report repeats ME’s ultimate opinions based on Tyler’s statements; admission impermissibly bolsters credibility	Report properly summarizes autopsy and investigative history; admissible	Court: Portions stating ultimate cause/manner must be redacted; unredacted report admission was error
Suppression of evidence from warrantless motel-room search	Entry/search violated Fourth Amendment; Tyler had a reasonable expectation of privacy in the room	Room was effectively used to commit a crime so no reasonable expectation of privacy; warrantless entry justified	Court: District court erred in concluding Tyler had no reasonable expectation of privacy; remand for further factual development re: exceptions (e.g., community-caretaking, inevitable discovery)
Suppression of Tyler’s statements (Miranda/voluntariness)	Statements were made while effectively in custody, under medical stress, and after interrogative tactics; thus involuntary or obtained in violation of Miranda (some concurrences argued Seibert applies)	Tyler was not in custody before Miranda warnings; she knowingly, intelligently, and voluntarily waived rights at station and hospital; statements admissible	Court majority: Statements admissible — not in custody before warnings; waivers and confessions voluntary. Separate concurrences/dissents argued custody and Seibert midstream-warning concerns justify suppression

Key Cases Cited

State v. Dudley, 856 N.W.2d 668 (Iowa 2014) (expert testimony may not bolster a witness’s credibility; such testimony impermissibly comments on credibility)
Missouri v. Seibert, 542 U.S. 600 (U.S. 2004) (plurality/controlling discussion of midstream Miranda warnings; two-step interrogation considerations)
State v. Dao Xiong, 829 N.W.2d 391 (Minn. 2013) (medical examiner testimony on manner of death admissible where based primarily on autopsy findings and assists jury)
State v. Sosnowicz, 270 P.3d 917 (Ariz. Ct. App. 2012) (excluding ME’s manner-of-death opinion when based principally on police-provided circumstances rather than medical expertise)
State v. Bradford, 618 N.W.2d 782 (Minn. 2000) (medical examiner’s homicide opinion admissible where grounded in autopsy findings)
People v. Eberle, 697 N.Y.S.2d 218 (N.Y. App. Div. 1999) (excluding pathologist opinion where autopsy equally supported multiple causes and opinion rested on witness statements)
State v. Vining, 645 A.2d 20 (Me. 1994) (excluding ME’s homicide conclusion that lacked physical support and relied on investigative reports)
Baraka v. Commonwealth, 194 S.W.3d 313 (Ky. 2006) (upholding ME homicide opinion that used investigative history in part when opinion assisted the jury)
State v. Commander, 721 S.E.2d 413 (S.C. 2011) (permitting ME to testify based on anecdotal investigative history where that history was part of the autopsy inquiry but distinguishing cases where opinion rests exclusively on police information)