State of Iowa v. Jesus Isai Diaz, 24-0496

Jesus Isai Diaz was convicted by a jury of second-degree murder for fatally stabbing his brother, Eduardo “Eddie” Diaz, after a physical altercation at Jesus’s house.
There was a history of conflict between the brothers, but fighting had largely subsided in adulthood; the altercation leading to Eddie’s death occurred following an afternoon of drinking and an argument about Eddie refusing to leave the house.
No witnesses saw the entire fight, but evidence indicated Jesus stabbed Eddie thirteen times, later concealed the weapon, and did not dispute the stabbing.
Jesus was originally charged with first-degree murder, but the jury convicted him of the lesser offense of second-degree murder.
On appeal, Jesus argued that the evidence supported only a voluntary manslaughter conviction (serious provocation), not second-degree murder (malice), and challenged certain jury instructions and trial rulings.
The district court denied several motions for mistrial based on witness references to prior incarceration, invocation of right to silence, and testimony about unrelated speeding; appellate review generally found error was not preserved or any prejudice was cured by limiting instructions.

Issue	State's Argument	Diaz's Argument	Held
Sufficiency of evidence for malice (second-degree murder)	Substantial evidence supported malice; jury properly rejected provocation	Evidence supported only voluntary manslaughter due to serious provocation	Substantial evidence supports conviction; challenge denied
Jury Instruction allowing inference of malice from weapon	Objection at trial was only about self-defense, not provocation	Jury should not infer malice unless provocation rejected first	Not preserved for appeal; not considered
Denial of mistrial: prior incarceration reference	Isolated, non-prejudicial, curative options offered	Prejudicial character evidence	Court did not abuse discretion; no mistrial
Denial of mistrial: irrelevant speeding evidence	Cured by prompt instruction to disregard	Prejudicial and irrelevant; may have biased jury	Court took proper action; instruction presumed followed

State v. Cook, 996 N.W.2d 703 (Iowa 2023) (standard for sufficiency of the evidence review)
State v. Brimmer, 983 N.W.2d 247 (Iowa 2022) (jurors are free to reject/accept evidence)
State v. Nitcher, 720 N.W.2d 547 (Iowa 2006) (jury can choose among reasonable narratives)
State v. Ambrose, 861 N.W.2d 550 (Iowa 2015) (error preservation for jury instruction challenges)
State v. Maghee, 573 N.W.2d 1 (Iowa 1997) (objection to jury instruction must be specific and preserved)
State v. Brown, 5 N.W.3d 611 (Iowa 2024) (motion for mistrial reviewed for abuse of discretion)
State v. Davis, 951 N.W.2d 8 (Iowa 2020) (juries are presumed to follow court's instructions)