State of Iowa v. Raymond Carl Redmond
2011 Iowa Sup. LEXIS 70
| Iowa | 2011Background
- Redmond was charged with indecent exposure, a serious misdemeanor under Iowa law.
- The State sought to impeach Redmond with a prior first-degree harassment conviction (August 21, 2009) during his trial.
- The district court admitted the prior conviction for impeachment under Iowa Rule of Evidence 5.609(a)(1) without explicit on-record findings.
- The court of appeals affirmed, and the Iowa Supreme Court granted review.
- The Supreme Court held the district court abused its discretion by admitting the conviction, vacated the court of appeals’ decision, reversed the district court, and remanded for a new trial.
- The ruling emphasizes Rule 5.609(a)(1) balancing against prejudicial effect and requires or permits de novo review when explicit on-record balancing findings are absent.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion admitting the prior conviction | Redmond | Redmond | Yes; abuse of discretion; probative value did not outweigh prejudice |
| Whether the district court should have made explicit on-the-record findings | Redmond asks for explicit balancing findings | Redmond | No; not required to have explicit findings, but abuse found without proper balancing |
| Whether the admission was harmless error | Redmond | State | No; error not harmless given unreliability and limited corroboration |
| Whether Rule 5.609(a)(1) framework supports de novo review on appeal | Redmond | State | Yes; de novo review appropriate when explicit findings are absent |
| What factors govern the probative value vs prejudicial effect under Rule 5.609(a)(1) | Redmond | State | The Court outlines probative value and substantial prejudice considerations, applying them to the case |
Key Cases Cited
- State v. Parker, 747 N.W.2d 196 (Iowa 2008) (abuse-of-discretion standard for impeachment evidence)
- State v. Daly, 623 N.W.2d 799 (Iowa 2001) (recording balancing considerations; de novo review when needed)
- State v. Hackney, 397 N.W.2d 723 (Iowa 1986) (recognizes need for on-the-record balancing findings)
- Martin v. State, 217 N.W.2d 536 (Iowa 1974) (framework for admissibility of prior convictions (pre-Rule 5.609))
- Harrington, 800 N.W.2d 46 (Iowa 2011) (distinguishes rule 5.609(a)(1) vs (a)(2) and emphasizes proper framework)