State of Iowa v. Monica Sheani Williams, 15-0755

Monica Williams was arrested April 4, 2014 for driving while license barred and waived a jury; bench trial occurred March 9, 2015.
Conviction under Iowa Code § 321.561 requires proof the defendant operated a vehicle and that the defendant’s license was barred with proper mailed notice.
The State introduced: the bar notice, two certificates of bulk mailing, two certificates of mailing listing unrelated names/addresses, an affidavit from the DOT records manager (Kathy McLear), and one page of a name/address list containing Williams’ information.
The certificates and affidavit lacked identifying information linking the mailing to Williams or her known address; the list page did not explain its role in bulk mailing or tie to a specific mailing date.
No USPS certificate of mailing specifying Williams’ name/address was produced, and the affidavit did not incorporate or reference the list page.
The district court convicted; on appeal the court reviewed sufficiency of evidence and the adequacy of proof that notice was mailed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there substantial evidence that notice of license bar was mailed to Williams?	State: documentation (notice, certificates, affidavit, list page) sufficiently shows mailing.	Williams: records fail to link mailing to her or to a specific date; affidavit and certificates are non-specific.	Reversed — evidence insufficient to prove mailing to Williams.
Was there sufficient evidence to support conviction for driving while barred?	State: whole record viewed in light most favorable to State supports conviction.	Williams: missing proof of mailed notice defeats element of offense.	Reversed — insufficient evidence to sustain conviction.
Were the bulk mailing certificates and affidavit adequate substitutes for a USPS certificate of mailing?	State: certificates and affidavit suffice under established practice.	Williams: certificates and affidavit lack required identifying information tying them to her notice.	Court: they were inadequate here; cannot presume notice was mailed.
Should remaining ineffective-assistance and evidentiary claims be addressed?	Williams: raised ineffective-assistance and objection to admission of documents.	State: (defense of trial procedure and admitted evidence).	Court: did not reach remaining claims after reversing for insufficient evidence.

State v. Brubaker, 805 N.W.2d 164 (Iowa 2011) (standard of review for sufficiency of evidence)
State v. Biddle, 652 N.W.2d 191 (Iowa 2002) (definition of substantial evidence and viewing evidence in favor of State)
State v. Quinn, 691 N.W.2d 403 (Iowa 2005) (substantial evidence must do more than raise suspicion)
State v. Wise, 697 N.W.2d 489 (Iowa 2005) (elements of driving while barred offense)
State v. Green, 722 N.W.2d 650 (Iowa 2006) (requirement to show mailing of notice by affidavit or certified mail receipt)