State of Iowa v. Thomas A. Woodard, 17-0114

Two men forced entry into a woman's home; one displayed a knife, the victim was assaulted, tied up, and about $80 plus a cell phone were taken.
Thomas A. Woodard was tried and convicted by a jury of first-degree robbery and first-degree burglary; his accomplice pleaded guilty to related charges and testified for the prosecution.
Accomplice testified Woodard drove them to the house, wore a dark/black hoodie, and directed parts of the robbery; the accomplice wore a red hoodie and had a Band-Aid on his nose and said both wore conspicuous gloves.
The victim testified two men came to her door, described one in a red hoodie with a Band-Aid who held the knife in his left hand, and identified Woodard at trial and in a photo lineup as the man in the black hoodie who took the cash.
Woodard challenged the sufficiency of the evidence on appeal, arguing the accomplice’s identification of him required corroboration and that such corroboration was insufficient.
The court reviewed corroboration under Iowa R. Crim. P. 2.21(3) and affirmed the convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether accomplice testimony identifying Woodard required corroboration to convict	State: accomplice testimony was corroborated by the victim’s in-court identification and testimony about the events, satisfying Rule 2.21(3)	Woodard: accomplice’s ID was uncorroborated or insufficiently corroborated (discrepancies in descriptions, photo ID weaknesses)	Court: Victim’s testimony and photo identification tended to connect Woodard to the crime; corroboration sufficient; convictions affirmed
Whether photo identification flaws (delay, facial-hair discrepancy, non-double-blind procedure) undermine corroboration	State: pretrial ID and careful examination by victim supported corroboration; even without photo ID, victim’s trial ID and testimony suffice	Woodard: two-year delay, victim recalled assailant as clean-shaven though Woodard had facial hair, officer did not use double-blind protocol	Court: Photo ID not iron-clad but was careful and bolstered corroboration; even absent it, in-court ID plus facts of intrusion sufficiently corroborated accomplice testimony

State v. Peterson, 663 N.W.2d 417 (Iowa 2003) (corroboration required to connect defendant to crime and to bolster accomplice credibility)
State v. Ware, 338 N.W.2d 707 (Iowa 1983) (explaining need to enhance credibility of accomplice testimony)
State v. Hutchison, 341 N.W.2d 33 (Iowa 1983) (corroboration need not confirm every material fact of accomplice’s testimony)
State v. Neal, 353 N.W.2d 83 (Iowa 1984) (cautious pretrial identification can support reliability of identification)
State v. Barnes, 791 N.W.2d 817 (Iowa 2010) (definition of accomplice for corroboration analysis)