State of Iowa v. Roosevelt (NMN) Matlock

Summary

The Iowa Supreme Court reviewed convictions for willful injury and going armed with intent involving Roosevelt Matlock. The court held that evidence of prior bad acts was improperly admitted to establish intent through propensity, although it could be relevant to show access to a sharp instrument for the going-armed-with-intent charge. The court vacated the court of appeals decision, reversed the district court judgment, and remanded for a new trial.

Holdings

1. Under Iowa Rule of Evidence 5.404(b), other bad acts may be admitted to prove the mens rea of the charged crime only when they are probative of that intent in a manner other than by showing the defendant's propensity to act in a particular manner.
2. The other-bad-acts evidence was inadmissible for any purpose on the willful-injury charge because it showed Matlock's intent only through propensity and did not independently establish motive, opportunity, knowledge, or specific intent.
3. Evidence of the other stabbing incidents was relevant to show Matlock's access to a sharp cutting instrument, and its probative value on that limited issue outweighed its prejudicial effect. It nevertheless could not be used to establish the specific intent required for going armed with intent.
4. Matlock preserved his challenge to the use of the other-bad-acts evidence to prove intent by making the objection and obtaining a pretrial ruling; he was not required to renew the objection to the limiting instruction.

Questions Presented

1. Whether the district court improperly admitted evidence of two other stabbing-related incidents under Iowa Rule of Evidence 5.404(b) to prove Matlock's intent and other issues.
2. Whether the other-bad-acts evidence was admissible on the willful-injury charge to establish intent.
3. Whether the other-bad-acts evidence was admissible on the going-armed-with-intent charge to show access to a sharp cutting instrument and, if so, whether it was improperly used to prove intent.
4. Whether Matlock preserved his challenge to the evidentiary ruling and the related limiting instruction.

Disposition

reversed_and_remanded