State of Iowa v. Marcel Rose, 15-2036

Marcel Rose was charged with assault causing serious injury and domestic abuse assault after Amanda Guzzle suffered five broken ribs and a punctured lung following an altercation in July 2015.
Guzzle testified Rose beat her; medical personnel confirmed the rib fractures and punctured lung; Rose initially called 911 the day after and claimed Guzzle assaulted him.
Guzzle alleged a separate, earlier incident a few days before the injury where Rose punched her in the face and damaged her property; she did not call police for that earlier incident.
The State sought to admit testimony about that prior alleged assault; Rose moved to exclude it under Iowa R. Evid. 5.404(b).
The district court held an offer-of-proof hearing, found the prior incident was proved with sufficient specificity and limited the scope of testimony; the jury ultimately convicted Rose of assault causing bodily injury (lesser included) and domestic abuse assault causing injury.

Issue	State's Argument	Rose's Argument	Held
Admissibility under Rule 5.404(b): relevance of prior-act testimony	Prior act is relevant to intent, identity, and refutes alternate theories	Prior-act testimony is irrelevant to whether Rose caused Guzzle’s injuries	Admissible — prior act relevant to intent and identity; Rose put intent and identity at issue
Clear-proof requirement for prior bad act	Offer-of-proof testimony and corroboration satisfied clear-proof standard	No clear proof without arrest, report, photos, or medical records	Clear proof met by Guzzle’s credible testimony plus Medina’s corroboration; corroboration not required
Unfair prejudice outweighing probative value	Probative value (intent, identity, refute defenses) outweighs prejudice; scope limited by court	Evidence of prior domestic violence is highly prejudicial and likely to inflame jury	No abuse of discretion — limited scope and corroboration reduced unfair prejudice
Standard of review	Trial court given wide discretion on admissibility and balancing	Same	Affirmed — appellate court reviews for abuse of discretion and found none

State v. Putman, 848 N.W.2d 1 (Iowa 2014) (sets three-step prior-bad-acts admissibility framework including clear-proof requirement)
State v. Taylor, 689 N.W.2d 116 (Iowa 2004) (prior domestic violence relevant to intent and motive)
State v. White, 668 N.W.2d 850 (Iowa 2003) (prior intentional violent acts probative of intent for current charge)
State v. Mitchell, 670 N.W.2d 416 (Iowa 2003) (prior acts admissible to refute defense theories and affect credibility)
State v. Alberts, 722 N.W.2d 402 (Iowa 2006) (definition and test for relevance)
State v. Newell, 710 N.W.2d 6 (Iowa 2006) (discussion of balancing probative value and unfair prejudice)
State v. Greene, 592 N.W.2d 24 (Iowa 1999) (consideration of strength of evidence in prejudice analysis)
State v. Rodriquez, 636 N.W.2d 234 (Iowa 2001) (victim testimony plus corroboration can establish clear proof)
State v. Spaulding, 313 N.W.2d 878 (Iowa 1981) (corroborating testimony strengthens probative value of prior-act evidence)