State of Iowa v. Michael Buman, 955 N.W.2d 215

Michael Buman, a registered nurse working nights at Pride Group Residential Care Facility, charted administration of Clozapine for resident Joseph Lenz on October 18, 2016 though the medication was not present and then wrote “DC’d” on the chart.
Lenz suffered chronic paranoid schizophrenia; Clozapine had been missing from his med tray for several days prior and other staff had marked “NA” when it was unavailable.
On October 27, Lenz had a psychotic episode; a PA testified Lenz’s lack of Clozapine likely caused the episode.
The State charged Buman with wanton neglect of a resident in violation of Iowa Code § 726.7 (knowingly acting in a manner likely to be injurious).
At trial the State introduced an Iowa Administrative Code nursing standard (Exhibit 15) over objection and the court gave Instruction No. 17 summarizing the standard and stating violation of it is not itself a crime.
The jury convicted on wanton neglect (no serious injury found). The court of appeals reversed; the Iowa Supreme Court affirmed that reversal, holding the administrative standard was unfairly confusing and should have been excluded, and remanded for further proceedings though it found the evidence could support a conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of nursing professional standards (Exhibit 15)	Standards were relevant to show risk attendant to Buman’s conduct and supported State’s mens rea inference	Exhibit 15’s “accountability” language differs from criminal standard and would mislead jury into equating professional violations with criminal guilt	Exclusion required under Iowa R. Evid. 5.403; admission of the full exhibit (esp. accountability language) posed substantial danger of jury confusion and was improper
Jury Instruction No. 17 referencing standards	Instruction correctly told jury standards aren’t themselves crimes and could be used only to assess elements	Instruction was confusing because Exhibit 15 emphasized accountability without connecting it to elements, risking jury focus on professional violations	Instruction did not cure prejudice from Exhibit 15’s admission; combined evidence/instruction risked jury misapplication
Sufficiency of the evidence for wanton neglect	Evidence (false initialing, DC’d notation, foreseeability of harm from stopping Clozapine) permits inference Buman knowingly acted in manner likely injurious	No proof Buman knew his notation caused medication cessation or that pharmacy stopped delivery; acts were clerical, not knowing misconduct	The court found evidence was sufficient for a reasonable jury to convict, but reversal is required due to evidentiary error; case remanded for further proceedings

State v. McKee, 392 N.W.2d 493 (Iowa 1986) (upheld statute against vagueness challenge)
State v. Newell, 710 N.W.2d 6 (Iowa 2006) (prejudice occurs when evidence prompts jury to decide on improper basis)
United States v. Robertson, 875 F.3d 1281 (9th Cir. 2017) (excluding a standards manual where admission would confuse issues and mislead jury)
Torres-Arroyo v. Rullán, 436 F.3d 1 (1st Cir. 2006) (district courts must guard against juror confusion when admitting complex standards)
United States v. Gibson, 568 F.2d 111 (8th Cir. 1978) (collateral regulatory material may be excluded to avoid misleading jury)
State v. Coleman, 907 N.W.2d 124 (Iowa 2018) (review of jury instruction error and prejudice)
State v. Kelso-Christy, 911 N.W.2d 663 (Iowa 2018) (standards for sufficiency-of-evidence review)
Graber v. City of Ankeny, 616 N.W.2d 633 (Iowa 2000) (deference to district court in Rule 5.403 balancing)