State v. Rodriguez, 807 N.W.2d 35

Rodriguez was charged with second-degree sexual abuse, willful injury, and domestic abuse assault.
He repeatedly waived speedy trial rights in the proceedings.
Rodriguez moved to suppress, contending his Miranda waiver was not knowing and voluntary.
He filed psychiatric evaluations asserting lack of mental competence to waive rights.
The district court denied the State's request for an independent psychiatric evaluation.
The court of appeals held the State could obtain such an evaluation and Rodriguez's speedy-trial claims were addressed separately.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the State may obtain an independent psychiatric evaluation when the defendant challenges Miranda waiver.	Rodriguez argues no independent evaluation should be allowed.	State contends it needs independent expertise to test waiver capacity.	The State is entitled to an independent evaluation when waiver capacity is at issue.

Ortiz v. State, 766 N.W.2d 244 (Iowa 2009) (burden on State to show knowing, intelligent, voluntary waiver of Miranda rights)
Craney, 347 N.W.2d 668 (Iowa 1984) (protects self-incrimination rights in expert testimony following evaluation)
Seehan v. State, 258 N.W.2d 374 (Iowa 1977) (State may obtain psychiatric evaluation when insanity is raised as defense)
Pope v. United States, 372 F.2d 710 (8th Cir. 1967) (state may use psychiatric evaluation to meet competency questions (incriminatory scope considerations))
Whitlow, 45 N.J. 3 (N.J. 1965) (cooperation with psychiatrists does not bar comprehensive examination by State)
Amana Soc'y v. Selzer, 250 Iowa 380 (1959) (no compulsion to testify beyond constitutional protections)
State v. Thomas, 219 N.W.2d 3 (Iowa 1974) (burden of proof on insanity shifted to defendant)
Hills Bank & Trust Co. v. Converse, 772 N.W.2d 764 (Iowa 2009) (discretion to review issues on appeal)