State of Iowa v. Karen Sue Huston, 2013 Iowa Sup. LEXIS 7

Huston, one of several adult caregivers for T.H., faced DHS child-abuse investigation over alleged neglect; T.H. suffered malnutrition and failure to thrive.
T.H. was hospitalized and treated for malnutrition after doctors ruled inadequate caloric intake as the cause; DHS intervened prior to hospitalization.
DHS caseworker Leslie Boyer testified that the abuse report against Huston was founded and explained the appeal process; Huston objected to this testimony.
A jury convicted Huston of child endangerment causing serious injury; Huston was sentenced to up to 15 years’ imprisonment; Fred Huston was convicted of a lesser included misdemeanor.
The Court of Appeals affirmed in part and reversed in part; Huston sought Supreme Court review restricted to the DHS-founded testimony issue.
The Iowa Supreme Court reversed, holding the admission of the DHS-founded testimony was reversible error and remanded for a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of DHS founded finding in trial	Huston: founded finding irrelevant and prejudicial	State: founded finding explains DHS actions	Reversible error; admission improper

State v. Marin, 788 N.W.2d 833 (Iowa 2010) (Rule 403 balancing in evidentiary rulings; limited admissibility of administrative findings)
McClure v. Walgreen Co., 613 N.W.2d 225 (Iowa 2000) (Evidence admissibility balanced against prejudice; probative value vs. unfair prejudice)
State v. Elliot, 806 N.W.2d 660 (Iowa 2011) (Investigator testimony must not cross from explaining actions to asserting guilt; limits on agency findings)
State v. Doughty, 359 N.W.2d 439 (Iowa 1984) (Limitation on admissibility of investigative findings that may influence the jury)