State of Iowa v. Jonathan Lee Shutt, 15-1896

Early morning break-in at Fort Dodge; blood sample collected from scene and submitted to DCI for DNA analysis.
DCI Criminalist Tara Scott analyzed the scene sample and a later-known sample taken from Jonathan Shutt; DCI reports indicated a match.
Officer Kleppe testified he received a DCI lab notice of a possible match (but was not allowed to testify to its contents); he then obtained arrest and DNA-sampling warrants for Shutt.
Criminalist Scott testified at trial and her written DCI report showing a match was admitted into evidence; defense received that report shortly before trial.
Shutt was charged with second-degree burglary, tried by jury, convicted, and appealed arguing (1) testimony exceeded the minutes of testimony and (2) ineffective assistance of counsel for failing to object to Officer Kleppe’s testimony about the lab notice.
The district court admitted the criminalist’s comparison testimony and report; the Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether testimony/comparison evidence exceeded the minutes of testimony requirement (Iowa R. Crim. P. 2.5)	State: minutes and amended minutes sufficiently identified the criminalist and that she would testify to DNA findings and in conformity with reports	Shutt: minutes did not notify that an actual comparison and match between his known sample and the scene sample had been completed or disclose report contents	Court: No reversible error — minutes plus amended minutes and reports provided adequate notice; even if outside scope, testimony was cumulative of admitted report and any error harmless
Whether trial counsel was ineffective for not objecting to Officer Kleppe’s testimony about a DCI lab notice of a possible match	State: other admissible evidence (Criminalist Scott’s report/testimony) independently tied Shutt to scene; no reasonable probability of different outcome	Shutt: Kleppe’s testimony was inadmissible hearsay and prejudicial; counsel should have objected	Court: No prejudice shown; ineffective-assistance claim fails because outcome would not likely differ given the criminalist’s report and testimony

State v. Mehner, 480 N.W.2d 872 (Iowa 1992) (minutes must provide a full and fair statement of expected testimony)
State v. Ellis, 350 N.W.2d 178 (Iowa 1984) (scope of minutes determined case-by-case; must alert defendant to source and nature of evidence)
State v. Musso, 398 N.W.2d 866 (Iowa 1987) (incomplete minutes may suffice if they alert defendant to need for further investigation)
State v. Givens, 248 N.W.2d 86 (Iowa 1976) (criminalistics laboratory reports not subject to minutes-of-testimony listing requirement)
State v. Wilson, 878 N.W.2d 203 (Iowa 2016) (erroneously admitted evidence that is merely cumulative need not require reversal)
State v. Clay, 824 N.W.2d 488 (Iowa 2012) (ineffective-assistance prejudice requires reasonable probability of different result)