State of Iowa v. Toby Ryan Richards, 2016 Iowa Sup. LEXIS 56

Defendant Toby Richards was charged with domestic abuse assault after an altercation with his then-girlfriend, Trish Poell; both parties gave conflicting "he‑said/she‑said" accounts and each had visible injuries.
Richards filed a notice of intent to assert self‑defense and moved to exclude evidence of prior uncharged incidents; the State sought to admit prior acts to prove intent and to rebut self‑defense.
Poell testified in deposition and at trial about multiple prior incidents in the previous year (slapping, throwing a phone at her neck, throwing her against a refrigerator); the district court limited scope and admitted three prior altercations.
The jury convicted Richards of domestic abuse assault causing bodily injury; the court of appeals affirmed, and the Iowa Supreme Court granted further review.
The central legal question was whether other‑acts evidence under Iowa Rule of Evidence 5.404(6) is admissible to prove intent (or to rebut self‑defense) when a defendant asserts justification.
The Supreme Court applied the three‑part Sullivan test (relevance to a legitimate issue other than propensity; clear proof the defendant committed the prior act; probative value vs. unfair prejudice) and affirmed the admission as not an abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence of prior uncharged domestic‑violence incidents is admissible to prove intent when defendant asserts self‑defense	Other acts are relevant to intent and motive and may rebut self‑defense; prior violence against the same victim shows probable motivation	Richards argued self‑defense removes intent as a genuinely disputed issue and the other acts therefore amount to inadmissible propensity evidence; also unfairly prejudicial	Court held self‑defense does not categorically remove intent from dispute; other acts against same victim were relevant to intent/rebuttal and admissible under 5.404(6) given limitations and a limiting instruction
What constitutes clear proof of prior bad acts	State relied on victim’s deposition and trial testimony as sufficient proof	Richards contested reliability and prejudicial effect	Court held victim’s testimony alone can constitute clear proof and was sufficient here
Whether probative value was substantially outweighed by unfair prejudice under Rule 5.403	State argued probative value was high in a he‑said/she‑said case and trial court narrowed scope and gave limiting instruction to reduce prejudice	Richards argued jurors would impermissibly infer propensity and be unduly prejudiced	Court held the district court appropriately limited scope and instructed jury; probative value did not present unfair prejudice that substantially outweighed it

State v. Taylor, 689 N.W.2d 116 (Iowa 2004) (prior acts against same victim admissible to show motive and intent in domestic‑violence context)
State v. Sullivan, 679 N.W.2d 19 (Iowa 2004) (articulates three‑part test for admissibility of other‑acts evidence under rule 5.404(6))
State v. Matlock, 715 N.W.2d 1 (Iowa 2006) (discussion of effect of justification defense on intent issue)
United States v. Commanche, 577 F.3d 1261 (10th Cir. 2009) (prior violent convictions inadmissible where probative showing of intent indistinguishable from impermissible propensity inference)
Yusem v. People, 210 P.3d 458 (Colo. 2009) (prior act evidence to rebut self‑defense must be logically independent of propensity inference)
State v. Shanahan, 712 N.W.2d 121 (Iowa 2006) (other acts admissible to rebut a self‑defense theory where they show inconsistency with defensive conduct)