State of Iowa v. Montez Tyrone Caples, 857 N.W.2d 641

Caples murdered Shannon by pressing a .357 revolver to Shannon’s neck and shooting him.
Court addressed two main issues: admissibility of gang-affiliation evidence and suppression of Caples’ confession.
District court admitted gang-evidence to show rival gang dynamics; Caples objected under Rule 5.404(b).
State’s theory used ‘inextricably intertwined’ narrative rationale, but the court applied a narrow exception and balancing test under Rule 5.404(b).
Evidence of gang affiliation included Shannon’s identification as Blood, a red bandana, Caples’ alleged Gangster Disciples ties, tattoos, clothing, and contemporaneous texts; circumstantial DNA linked the gun to Shannon.
Caples argued the confession to police violated Miranda and was improperly admitted; the record shows multiple custodial interviews over two days, with the final interview yielding a confession after renewed warnings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of gang evidence under 5.404(b).	State contends evidence is inextricably intertwined with the homicide.	Caples argues evidence is impermissible other-acts and unfairly prejudicial.	Admissible as non-propensity, not unduly prejudicial; limited and contextually explanatory.
Harmlessness of evidentiary error if gang evidence admitted.	State asserts evidence supports guilt beyond reasonable doubt.	Erroneous admission could prejudice the verdict.	Harmless error; overwhelming guilt evidence independently supports verdict.
Miranda rights and admissibility of Caples’ confession.	State maintains confession was voluntary after warnings.	Police reinitiated interrogation after requests for counsel.	Confession not obtained in violation; any error was harmless.
Harmless-error standard applied to confession.	State bears burden to prove no contribution to verdict.	Errors could have tainted the outcome.	Constitutional error harmless; verdict not attributable to admission of confession.

State v. Reynolds, 765 N.W.2d 283 (Iowa 2009) (abuse-of-discretion review for evidentiary rulings; prejudice standard)
State v. Rodriguez, 636 N.W.2d 234 (Iowa 2001) (abuse-of-discretion and prejudice in admission of evidence)
State v. Nelson, 791 N.W.2d 414 (Iowa 2010) (inextricably intertwined evidence; limited exception to 5.404(b))
State v. Putman, 848 N.W.2d 1 (Iowa 2014) (three-step test for admissibility of other-acts evidence)
State v. Delaney, 526 N.W.2d 170 (Iowa Ct. App. 1994) (balancing test for probative value vs. unfair prejudice)
State v. Newell, 710 N.W.2d 6 (Iowa 2006) (proof standards for gang affiliation evidence)
State v. Shortridge, 589 N.W.2d 76 (Iowa Ct. App. 1998) (relevance of motive evidence in homicide)