State of Iowa v. Tanner Jon King, 20-0158

Two brothers (Marion and Eldominic Rhodes) were fatally shot in an alley; an eyewitness saw a white man running from the scene holding a phone and a gun.
Police investigated multiple suspects, focusing on Tanner King after .40-caliber ammunition (matching crime-scene casings) and a receipt linking him to a recent ammunition purchase were found in his apartment/trash; surveillance and witness statements also placed King near the scene and acting nervously afterward.
Cletio Clark was also investigated as a potential suspect; officers interviewed Clark multiple times and transported him from another jail for questioning; text messages and witness statements connected Clark to the events and suggested a gang-related motive involving another person (Johnny Young).
Defense sought to present a Bowden-style argument (investigative omissions/alternative-suspect rumors) and called barber Priest Wilson to testify about barbershop rumors implicating Clark; the district court restricted Wilson’s testimony as hearsay but allowed similar testimony from another witness (Jeremy Mack).
The jury convicted King of two counts of first-degree murder; King appealed, arguing the court’s limitation on Wilson’s testimony deprived him of a complete defense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether excluding barber Priest Wilson’s testimony violated King’s right to present a complete (Bowden) defense	Exclusion proper under Iowa hearsay rules because Wilson’s out-of-court statements were offered for the truth of the matter asserted (that Clark was the killer) and thus inadmissible	Wilson’s testimony was admissible under a Bowden theory to show police received and ignored a lead; hearsay rules should yield to allow evidence of investigative lapses	Court affirmed exclusion: Wilson’s statements were offered for their truth (inadmissible hearsay); King’s Bowden-style purpose was not the actual use, and any error was harmless because similar evidence was admitted and State’s case was strong
Standard of review for admissibility and constitutional claim	Review evidentiary rulings for abuse of discretion; no separate due-process protection for inadmissible evidence	Constitutional claim warrants de novo review of the right-to-present-defense issue	Court applied mixed approach: hearsay rulings reviewed for correction of legal error; other evidentiary rulings for abuse of discretion; declined to adopt Massachusetts Bowden doctrine wholesale

Commonwealth v. Bowden, 399 N.E.2d 482 (Mass. 1980) (original articulation that investigative omissions and lack of certain evidence may be relevant to raise reasonable doubt)
Commonwealth v. Silva-Santiago, 906 N.E.2d 299 (Mass. 2009) (distinguishes Bowden investigative-omission theory from third-party-culprit evidence and permits certain hearsay to show police ignored leads)
Commonwealth v. Moore, 109 N.E.3d 484 (Mass. 2018) (clarifies admissibility standards for Bowden-type evidence)
State v. Dessinger, 958 N.W.2d 590 (Iowa 2021) (explains hearsay rule and when out-of-court statements may be nonhearsay for purposes other than proving truth)
State v. Farmer, 492 N.W.2d 239 (Iowa Ct. App. 1992) (defendant offering third-party-culprit evidence must present substantive facts creating more than mere suspicion)
State v. Collins, 10 A.3d 1005 (Conn. 2011) (recognizes Bowden principle that investigative lapses can be admissible to raise reasonable doubt)