State of Iowa v. Tacoa Talley, 23-0914

Tacoa Talley was convicted of first-degree murder based on evidence that included a Snapchat video he made with co-conspirator Samantha Bevans shortly after the victim's death.
The State introduced multiple forms of the Snapchat video: the original, audio-enhanced versions, and a transcript.
Talley objected to the admission of certain exhibits related to the Snapchat recording, arguing issues of foundation, accuracy, and that the transcript violated evidentiary rules.
Talley also challenged the inclusion of specific language in a stock jury instruction regarding how to resolve conflicting evidence.
The district court admitted the challenged evidence and gave the contested jury instruction; the jury convicted Talley, and he received a mandatory life sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of enhanced Snapchat audio and video	Sufficient foundation and accuracy established	Enhancements altered evidence, not trustworthy	Admission affirmed; foundation adequate
Admission of Snapchat transcript	Transcript aids jury, with both original and transcript available	Transcript violates best evidence rule; unfair prejudice	Admission affirmed; no abuse of discretion
Jury instruction re: conflicting evidence	Model language is proper and long upheld	Language misstates law, forces jury to 'choose sides'	No error; instruction proper as given

State v. Buller, 517 N.W.2d 711 (Iowa 1994) (review standards for admissibility of evidence)
State v. Helmers, 753 N.W.2d 565 (Iowa 2008) (abuse of discretion in evidentiary rulings)
State v. Anderson, 159 N.W.2d 809 (Iowa 1968) (trial court discretion in admissibility of recordings)
State v. Allen, 565 N.W.2d 333 (Iowa 1997) (admissibility of transcripts for audio recordings)
State v. Benson, 919 N.W.2d 237 (Iowa 2018) (reviewing jury instructions as a whole)