State of Iowa v. Raul Casillas Martinez, 21-0145

Background

A confidential informant arranged two controlled buys of methamphetamine; officers equipped and searched the informant and followed him but did not witness the transactions; the informant returned with meth each time.
After the second buy at Martinez’s home, law enforcement obtained and executed a search warrant; officers found meth in wet bags in a bedroom closet (total ~10.36 g), drug paraphernalia, a digital scale, surveillance equipment, and cash on Martinez (some serialized buy bills were reportedly among it).
Lieutenant Perdew prepared an investigative report and a search-warrant application recounting the informant’s statements that Martinez sold the drugs; the informant did not testify at trial.
Over defense hearsay and Confrontation Clause objections, the district court admitted the report and warrant application as business records (Iowa R. Evid. 5.803(6)); the court later instructed the jury to disregard similar testimonial statements in Perdew’s testimony but the documents remained admitted.
The jury convicted Martinez on specified unlawful activity and three possession-with-intent / tax-stamp counts (the court granted acquittal on one controlled-buy count). On appeal the State conceded a Confrontation Clause violation but argued harmless error for some counts.
The court applied Iowa’s two-step harmless-error test and concluded the Confrontation Clause violation was not harmless as to counts 1, 2, 3, and 5; convictions on those counts were reversed and remanded for new trial (count 4 may not be retried due to double jeopardy).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility under business-records rule (Iowa R. Evid. 5.803(6)) vs. public-records exclusion (5.803(8)(B))	Exhibits were records of regularly conducted activity and admissible as business records.	Investigatory reports by law enforcement fall within the public-records exclusion and are not admissible as business records.	Appellate court avoided a definitive ruling on the hearsay-rule interplay; noted the State conceded 5.803(8) likely excludes the documents.
Confrontation Clause: testimonial statements of confidential informant introduced via documents	Admission was harmless for some counts; error did not require reversal for counts tied to search-warrant evidence.	The informant’s statements were testimonial hearsay; admittance without the informant’s testimony violated the Sixth Amendment and Iowa Constitution.	The informant’s statements were testimonial; admitting them without testimony violated confrontation rights.
Harmless-error analysis for convictions (counts 1,2,3,5)	Some convictions (counts 2 and 5) could stand because other evidence linked Martinez to the seized drugs; State conceded count 3 was not harmless.	The nontestimonial evidence was not overwhelming; the informant’s statements may have been the tipping evidence given multiple occupants and ambiguous links.	Error was not harmless beyond a reasonable doubt as to counts 1,2,3,5; convictions reversed and remanded for new trial.
Preservation of confrontation objection	Defense failed to preserve Confrontation Clause objection to some exhibits or court did not expressly rule.	Counsel objected at trial on hearsay and confrontation grounds; the court necessarily ruled when it admitted the exhibits.	Preservation argument rejected; the record shows the court considered and overruled confrontation objections, so error was preserved.

Key Cases Cited

Crawford v. Washington, 541 U.S. 36 (2004) (defines "testimonial" statements for Confrontation Clause purposes)
Davis v. Washington, 547 U.S. 813 (2006) (distinguishes testimonial from nontestimonial statements)
State v. Schaer, 757 N.W.2d 630 (Iowa 2008) (applies Crawford framework under Iowa law)
State v. Wells, 738 N.W.2d 214 (Iowa 2007) (Confrontation Clause error may be harmless; sets standard)
State v. Kennedy, 846 N.W.2d 517 (Iowa 2014) (two-step harmless-error analysis applied to Confrontation Clause errors)
State v. Tompkins, 859 N.W.2d 631 (Iowa 2015) (prosecution has burden to present adverse witnesses; defendant not required to produce them)
State v. Lamasters, 821 N.W.2d 856 (Iowa 2012) (issue preserved when court necessarily considered and ruled on it)
State v. Segura, 889 N.W.2d 215 (Iowa 2017) (rejects hypertechnical preservation arguments)
State v. Montgomery, 966 N.W.2d 641 (Iowa 2021) (appellate caution about speculating juror deliberations)
State v. Chapman, 944 N.W.2d 864 (Iowa 2020) (double jeopardy bars retrial after acquittal)