State of Iowa v. Oladimeji A. Ayodele, 15-2059

Background

Trooper Sackett stopped a car for speeding, observed movement in the back seat, and saw an object thrown from the right rear passenger window. Sackett later smelled marijuana and observed residue on Ayodele; marijuana was found in the vehicle near Ayodele.
Ayodele was charged with possession of a controlled substance (marijuana), second offense; co-defendant Madison was also tried and convicted separately.
Ayodele obtained a pretrial limine ruling: the State could show something was thrown but could not say or imply the thrown object was marijuana or describe it in a way that suggested it was marijuana.
During trial the prosecutor asked Sackett questions about the thrown object (some elicited objections), then played a redacted video that nonetheless contained several statements referring to “shit” being thrown and references to marijuana; the State also referenced other occupants’ innocence in rebuttal.
Ayodele moved for mistrial multiple times after these disclosures; the district court found the State violated the limine ruling but denied mistrial, concluding Ayodele was not prejudiced given other evidence of constructive possession.
The court of appeals reversed and remanded for a new trial, concluding the prosecutor’s unredacted references to the thrown object as drugs were prejudicial and the jury received no curative instruction.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether prosecutor’s references to excluded evidence violated the limine order and required mistrial	State argued the redactions were technically sufficient and other evidence cured any error	Ayodele argued repeated references (video and questions) implied the thrown object was marijuana, violating the limine ruling and prejudicing the jury	Reversed: court found the State violated the order and the references were so prejudicial the effect could not be erased; mistrial was required
Whether any error was harmless given other admissible evidence of possession	State argued overwhelming admissible evidence (residue, smell, marijuana in shoe, inculpatory statements) rendered any limine violation harmless	Ayodele argued the jury could infer possession from the improper references, and no curative instruction was given	Court rejected harmlessness; held prejudice present because the improper video statements likely caused juror inference beyond admitted evidence
Preservation of error versus ineffective-assistance claim	State implied limited preservation; urged review under harmless-error standards	Ayodele preserved error by timely mistrial motions; appellate review is direct abuse-of-discretion	Court concluded error preserved and reviewed for abuse of discretion; reversal followed
Need for curative instruction after introduction of potentially prejudicial material	State did not give such instruction and court did not require one at trial	Ayodele argued absence of curative instruction made prejudice irreparable	Court noted failure to give limiting instruction and treated that absence as contributing to irreparable prejudice

Key Cases Cited

State v. Gathercole, 877 N.W.2d 421 (Iowa 2016) (standard of review for district court rulings on mistrial/abuse of discretion)
State v. Frei, 831 N.W.2d 70 (Iowa 2013) (defendant must show limine violation resulted in prejudice denying a fair trial)
State v. Jackson, 587 N.W.2d 764 (Iowa 1998) (prejudice requires forbidden matter be so prejudicial its effect could not be erased)
State v. Trudo, 253 N.W.2d 101 (Iowa 1977) (prosecution’s attempts to elicit forbidden testimony can be reversible error)
State v. Richards, 879 N.W.2d 140 (Iowa 2016) (better practice to give limiting instruction to curtail unfair prejudice)
State v. Sullivan, 679 N.W.2d 19 (Iowa 2004) (nonconstitutional harmless-error standard and presumption of prejudice unless contrary affirmatively established)