State of Iowa v. John Arthur Wilson, 878 N.W.2d 203

Defendant John Arthur Wilson was accused of forging and falsifying a public document filed with the Iowa Supreme Court; he was out on bond pending an unrelated theft appeal.
A document purporting to be signed by his appellate attorney, Audlehelm, was filed July 27, 2011; the attorney discovered the forgery after this court mailed an order on August 4.
Law enforcement executed warrants: on August 11 officers approached Wilson at his truck; he fled in reverse, led a vehicle chase, wrecked, and escaped on foot (eluding charge later severed).
On September 20 officers executed additional warrants and, after canine assistance, found Wilson hiding in a hole under a plastic bin in his basement; police seized a laptop.
At trial the court admitted testimony and photos of both episodes; the jury convicted Wilson of forgery and falsifying a public document.
The Iowa Supreme Court granted further review to decide admissibility of the flight/concealment evidence; it affirmed admission of the August 11 flight, reversed admission of the September 20 concealment as an abuse of discretion but held that error harmless, and left other issues decided by the court of appeals intact.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of flight on Aug. 11 as consciousness-of-guilt evidence	Flight was probative: close temporal sequence and notice of the forged filing made it reasonable to infer Wilson fled to avoid apprehension for the forgery	Flight was prejudicial and not sufficiently connected to charged offenses	Admitted—court found adequate nexus and probative value outweighed prejudice; not an abuse of discretion
Admissibility of concealment on Sept. 20 (hiding in basement hole)	Concealment shows same consciousness of guilt and motive to remain free pending appeal	Too remote and lacking events tying it to the specific forgery/falsification charges; unfairly prejudicial	Erroneously admitted—probative value was marginal and unfairly prejudicial; district court abused discretion
Harmless-error analysis for Sept. 20 evidence	Admission affected substantial rights and warrants reversal	Evidence was cumulative of Aug. 11 flight; properly admitted flight was powerful and concealment was cumulative	Harmless error—the concealment evidence was cumulative and would not have changed verdict
Scope/procedural posture on other claims (new trial, ineffective assistance)	Wilson argued trial errors and counsel failures required relief	State defended rulings; appellate court had already addressed some issues	Court let court-of-appeals decision stand on motion for new trial and IAC; affirmed in part and vacated in part, judgment of district court affirmed

State v. Nelson, 791 N.W.2d 414 (Iowa 2010) (framework for admissibility of other-acts evidence under Rule 5.404(b))
State v. Bone, 429 N.W.2d 123 (Iowa 1988) (cautionary principles and requirements for flight instructions/evidence)
Wong Sun v. United States, 371 U.S. 471 (U.S. 1963) (skepticism as to probative value of flight evidence)
United States v. Myers, 550 F.2d 1036 (5th Cir. 1977) (four-inference chain for evaluating probative value of flight evidence)
State v. Wimbush, 150 N.W.2d 653 (Iowa 1967) (flight as circumstantial evidence of consciousness of guilt)