State of Iowa v. Undray Jermaine Reed, 16-1673

Early-morning traffic stop: Officer Albert Bovy observed a Buick without plates, Reed failed to stop, fled at high speed, and crashed into a house.
After Reed exited and fled, officers chased and arrested him; dash-cam video recorded the events and police K-9 activity.
Officer Bovy testified he found a baggie of crystal meth on the sidewalk near the Buick (no frost on the baggie) and a meth pipe in nearby grass; lab testing confirmed .18 grams of methamphetamine.
Reed admitted smoking meth about an hour before the crash but denied ownership of the baggie; defense argued Bovy planted the baggie and pointed to dash-cam frames as showing a planting motion.
During rebuttal closing, the prosecutor vouched for Officer Bovy’s honesty, arguing Bovy would not risk perjury or his career by lying; the district court overruled a defense objection.
Jury convicted Reed on eluding, driving while barred, and possession of methamphetamine; on appeal Reed challenged only the possession conviction based on prosecutorial vouching.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the prosecutor improperly vouched for a police witness in closing argument	Prosecutor entitled to vigorous rebuttal to planting accusation; statements were responsive and not prejudicial	Vouching (saying officer was "being honest" and wouldn’t risk perjury/career) was improper and prejudicial	Court: Prosecutor’s remarks constituted impermissible vouching under Graves and prejudiced Reed’s possession conviction; reversed and remanded for new trial

State v. Graves, 668 N.W.2d 860 (Iowa 2003) (prosecutor may not personally vouch for witness credibility; guides misconduct analysis)
State v. Phillips, 226 N.W.2d 16 (Iowa 1975) (prosecutor latitude in closing but limited)
State v. Williams, 334 N.W.2d 742 (Iowa 1983) (prosecutors precluded from personally vouching for defendant’s guilt)
State v. Jacobs, 607 N.W.2d 679 (Iowa 2000) (abuse of discretion standard for prosecutorial-misconduct rulings)
State v. Boggs, 741 N.W.2d 492 (Iowa 2007) (strength of the State’s case is key Graves factor)
State v. Carey, 709 N.W.2d 547 (Iowa 2006) (discussing Graves prejudice factors)
State v. Martens, 521 N.W.2d 768 (Iowa Ct. App. 1994) (vouching may lead jurors to trust prosecutor over evidence)
State v. Schlitter, 881 N.W.2d 380 (Iowa 2016) (distinguishing prosecutorial misconduct from error)
United States v. Boyd, 54 F.3d 868 (D.C. Cir. 1995) (prosecutor improperly vouched for officers by referencing career-risk as reason to believe them)