State of Iowa v. Jonathan Antoine Brown, 16-1021

Jonathan Brown was charged with first-degree murder after Timothy Washington died from multiple stab wounds following a fight at a house party on June 21, 2015.
Multiple eyewitnesses placed Brown in the group fighting Washington and observed Brown holding a knife and stabbing Washington.
At trial the jury convicted Brown of the lesser-included offense of second-degree murder with a dangerous weapon; court sentenced him to up to 50 years.
Brown moved in limine to exclude evidence of other stabbings at the party and certain statements from a police-interview video; the trial court admitted both categories of evidence.
On appeal Brown argued (1) admission of his prior bad acts violated Iowa Rule of Evidence 5.404(b), and (2) admission of law-enforcement statements from the interview was hearsay, violated his Confrontation Clause rights, and was unfairly prejudicial under Iowa Rule of Evidence 5.403.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of other-stabbing evidence under Rule 5.404(b)	Evidence showed Brown had a knife and a plan/opportunity; admissible for identity, opportunity, and plan	Evidence was impermissible propensity evidence and should be excluded	Admitted: evidence was relevant to opportunity, identity, and plan, not character propensity
Admissibility of law-enforcement statements in police-interview video (hearsay/Confrontation)	Statements were relevant; any error harmless given eyewitness testimony	Statements were hearsay, violated confrontation, prejudiced jury	Any error was harmless because strong eyewitness evidence independently established guilt
Rule 5.403 unfair prejudice challenge	Probative value outweighed any prejudice in context	Admission unfairly prejudiced jury against Brown	No reversible error: probative value outweighed prejudice or error harmless in result
Ineffective assistance for failing to request limiting instruction	No prejudice shown; outcome would be same	Counsel should have sought limiting instruction to mitigate prejudice	Denied: Brown failed to show reasonable probability of different result

State v. Huston, 825 N.W.2d 531 (Iowa 2013) (standard of review for evidentiary rulings)
State v. Huser, 894 N.W.2d 472 (Iowa 2017) (harmless-error analysis for improperly admitted hearsay)
State v. Kennedy, 846 N.W.2d 517 (Iowa 2014) (assessing what evidence the jury actually considered and comparing probative forces)
State v. Harris, 891 N.W.2d 182 (Iowa 2017) (standard for ineffective-assistance claims; require probability of different result)