State of Iowa v. Tyler James Webster, 2015 Iowa Sup. LEXIS 69

Background

Defendant Tyler Webster shot and killed Buddy Frisbie; charged with first-degree murder; jury convicted of second-degree murder.
During trial a juror failed to volunteer that her adult daughter was friends with Frisbie’s stepsister and was Facebook “friends” with Frisbie’s stepmother; voir dire and initial admonition were not reported.
After verdict, evidence surfaced that the juror discussed the case in public, clicked “like” on the victim’s stepmother’s Facebook post during trial, and later told others she had looked up a witness’s age.
Webster moved for a new trial/arrest of judgment alleging juror misconduct and bias and challenged district court evidentiary exclusions (pregnancy of victim’s ex-wife at time she was struck; Frisbie’s felon status/prison mentality).
The district court denied relief; the court of appeals reversed on juror-bias grounds; the Iowa Supreme Court granted further review and affirmed the district court.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Juror misconduct (outside communications)	Juror talked about the case at a store and on Facebook; this violated admonitions and warrants new trial	Juror’s contacts were brief, non-substantive, and did not influence deliberations	No new trial; store interactions and Facebook "like" did not show misconduct that probably influenced verdict
Juror bias (undisclosed relationship with victim’s family)	Juror concealed ties and later showed sympathy for victim’s family; concealment of bias requires reversal	Juror disclosed ties in camera, said she did not know victim, and affirmed ability to decide on evidence; defense had chance to probe but did not move to strike	No actual bias shown on record; district court did not abuse discretion in finding juror impartial (court declines to reach preserved constitutional claim)
Juror independent research (looked up witness age)	Juror researched witness age, undermining impartiality and verdict	Research occurred after verdict; thus could not have affected deliberations	Not misconduct—conduct occurred post-verdict and could not have influenced the verdict
Evidentiary exclusions and ineffective assistance (pregnancy, felon/prison mentality)	Excluding pregnancy detail and failing to admit felon/prison-mentality evidence deprived Webster of context for self-defense	State: pregnancy detail was unfairly prejudicial; felon/‘prison mentality’ evidence was cumulative and prejudicial; counsel’s failure to offer some evidence would not have changed outcome	Exclusion of pregnancy detail was proper under Rule 5.403; counsel’s failure on felon/prison-mentality claims did not show prejudice—no reversible error; ineffective-assistance claims left for postconviction relief if pursued

Key Cases Cited

Fry v. Blauvelt, 818 N.W.2d 123 (Iowa 2012) (standard for reviewing juror-misconduct new-trial rulings)
State v. Hendrickson, 444 N.W.2d 468 (Iowa 1989) (juror-misconduct and bias standards)
State v. Johnson, 445 N.W.2d 337 (Iowa 1989) (discretion on new-trial motions for juror issues)
State v. Cullen, 357 N.W.2d 24 (Iowa 1984) (three-part test for new trial based on juror misconduct)
McDonough Power Equip. v. Greenwood, 464 U.S. 548 (1984) (deliberate concealment of bias in voir dire requires reversal)
United States v. Martinez-Salazar, 528 U.S. 304 (2000) (seated juror who concealed bias requires reversal)
Irvin v. Dowd, 366 U.S. 717 (1961) (juror must be able to set aside impressions and decide on evidence)
State v. Huston, 825 N.W.2d 531 (Iowa 2013) (Rule 5.403 balancing test explained)
State v. Martin, 704 N.W.2d 665 (Iowa 2005) (factors for weighing probative value vs. unfair prejudice)
State v. Shearon, 449 N.W.2d 86 (Iowa Ct. App. 1989) (limitations on admitting victim’s prior violent acts)