State of Iowa v. Jeffrey Alan Schories
2013 Iowa Sup. LEXIS 15
| Iowa | 2013Background
- Schories was arrested Aug. 27, 2010 for operating while intoxicated under Iowa Code 321J.2(l)(c) after methadone was found in his urine.
- A syringe was found in the vehicle, but was not preserved for testing.
- Schories asserted the prescription drug defense under Iowa Code 321J.2(7)(6); he had a valid methadone prescription and claimed use per physician labeling.
- Trial evidence included Officer Boone’s testimony about signs of impairment and the urine methadone result, plus Dr. Baldi’s medical testimony and monographs.
- The district court denied acquittal; the jury convicted; the Iowa Supreme Court reversed, finding insufficient evidence to defeat the prescription-drug defense, and remanded for entry of judgment for Schories.
- Dissent would have affirmed; majority held instructional error but reversed on sufficiency grounds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Preservation of the prescription-drug defense challenge | Schories preserved the issue via the acquittal motion. | State contends the issue was not properly preserved. | Issue preserved; review available on appeal. |
| Sufficiency of evidence to rebut the prescription-drug defense | State urged three theories—behavioral inferences, labeling violation, and injection—supporting guilt beyond reasonable doubt. | Evidence too speculative; failure to rebut prescription defense. | Insufficient evidence; ruling for defendant. |
| Impact of jury-instruction on prescription-drug defense burden | Jury instructions properly conveyed burden; defense could rely on prescription evidence. | Instruction may have confused burden, affecting verdict. | Instructional error; new trial warranted. |
Key Cases Cited
- Crone v. State, 545 N.W.2d 267 (Iowa 1996) (preservation requires identifying the elements for each challenged aspect)
- Geier v. State, 484 N.W.2d 167 (Iowa 1992) (preservation and sufficiency standards for evidence-related claims)
- Lawler v. State, 571 N.W.2d 486 (Iowa 1997) (State bears burden to disprove prescription defense beyond a reasonable doubt)