State of Iowa v. Jonas Dorian Neiderbach
836 N.W.2d 470
| Iowa | 2013Background
- Thompson was convicted by a jury of second-degree murder for shooting his live-in girlfriend Angela Gabel.
- Evidence showed two headshots from a distance of 15–20 feet after an argument where Gabel flipped him off.
- Thompson’s defense included insanity and diminished responsibility; he sought to introduce PTSD evidence.
- The district court declined to give a voluntary manslaughter instruction due to lack of serious provocation.
- Thompson sought in camera review of Gabel’s mental health records under Cashen and challenged Iowa Code section 622.10(4) as unconstitutional; trial included a videotaped confession.
- The Iowa Supreme Court upheld the constitutionality of section 622.10(4) and affirmed Thompson’s conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Voluntary manslaughter instruction warranted? | Thompson: provocation supports manslaughter. | Thompson: records show serious provocation. | No; provocation not legally/factually sufficient. |
| Exclusion of hearsay and PTSD evidence? | Hearsay and PTSD letters were admissible. | Courts erred in exclusion; records relevant to PTSD. | Exclusion proper; any error harmless. |
| Constitutionality and application of 622.10(4)? | Cashen protocol should govern access; statute unconstitutional on face. | Statute constitutional; Cashen superseded; case-by-case. | Statute constitutional on its face; Cashen superseded. |
| Verdict contrary to evidence? | Weight of evidence favored new trial. | Evidence overwhelming; no basis for new trial or arrest of judgment. | No reversal; verdict not contrary to the weight of the evidence. |
Key Cases Cited
- In re Estate of Barroso, 122 S.W.3d 554 (Ky. 2003) (threshold exculpatory evidence standard for records)
- State v. Inger, 292 N.W.2d 119 (Iowa 1980) (voluntary manslaughter elements and provocation framework)
- Commonwealth v. Ritchie, 480 U.S. 39 (1987) (due process in-camera review, defense counsel rights limited)
- Cashen, 789 N.W.2d 404 (Iowa 2010) (five-step protocol for accessing victim’s mental-health records)
- State v. Heemstra, 721 N.W.2d 549 (Iowa 2006) (psychotherapist-patient privilege and trial relevance)
- State v. Neiderbach, 837 N.W.2d 180 (Iowa 2013) (case-by-case approach to 622.10 analysis; special concurrence cited)