State of Iowa v. Jonathan Q. Adams
810 N.W.2d 365
| Iowa | 2012Background
- Dec 8, 2006: Adams hit Tina Brown bicycling in Des Moines; Adams’ headlight was out and he fled the scene.
- Adams was charged with murder by vehicle, operating while intoxicated (OWI), and leaving the scene; trial evidence contested intoxication and driving behavior.
- Trial evidence included witnesses who said Adams did not appear intoxicated, and one witness who used marijuana; police noted no clear reckless driving.
- Jury convicted Adams on all counts; Court of Appeals affirmed sufficiency of evidence but remanded for resentencing.
- Dispute on appeal: whether section 707.6A(1) requires the State to prove intoxicated driving caused Brown’s death (causation).
- Court held: State must prove a causal connection between the defendant’s intoxicated driving and the victim’s death; record on ineffective assistance of counsel is insufficient for direct appeal and remanded for possible postconviction relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is causation required under 707.6A(1)? | Adams contends no causal link required between intoxication and death. | State need not prove intoxication caused death; only driving while intoxicated caused death. | State must prove a causal connection between intoxicated driving and death. |
| What is the correct causation standard in 707.6A(1)? | Causation may be broader or implied by dangerousness of drunk driving. | Should not import proximate cause or legal cause concepts beyond the statute’s text. | Causation is factual: would the death have occurred absent the defendant’s intoxicated driving. |
| Was Adams’ trial counsel ineffective for failing to challenge causation on direct appeal? | Ineffective assistance for not raising causation dispute. | Record inadequate to resolve on direct appeal; may pursue postconviction. | Record inadequate on direct appeal; issue preserved for potential postconviction proceedings. |
| Are jury instructions proper regarding causation under 707.6A(1)? | State must prove the causal link; the instruction should require causation. | ISBA 710.1 appropriately states the law; district instruction incorrectly framed. | ISBA 710.1 is correct; district instruction should reflect causation requirement. |
| Did the court err in applying historical causation principles to 707.6A(1)? | Legacy cases support direct causal connection between intoxicated driving and death. | Modern causation concepts may suffice; no need to require a direct intoxication-to-death link. | The court aligns with prior Iowa causation precedents requiring a factual causal connection. |
Key Cases Cited
- State v. Sluyter, 763 N.W.2d 575 (Iowa 2009) (statutory interpretation and correction of legal errors)
- State v. Wiederien, 709 N.W.2d 538 (Iowa 2006) (harmonization of statutes and legislative intent)
- State v. Carpenter, 616 N.W.2d 540 (Iowa 2000) (interpretation principles and avoiding absurd results)
- Kellison, 233 Iowa 1274 (1943) (drunken driving related manslaughter and causation principles)
- Rullestad, 259 Iowa 209 (1966) (need direct causal connection in drunken-driving deaths)
- Comried, 693 N.W.2d 773 (Iowa 2005) (drugs vs. intoxication distinctions; purpose of 707.6A; causal questions)