State of Iowa v. Chad Albert Godfrey

Summary

The Iowa Supreme Court reviewed whether Iowa Rule of Criminal Procedure 2.5(3) required the State to disclose witnesses’ home addresses in the minutes of testimony. The court held that newly adopted Rule 2.11(12), governing disclosure of witness addresses, applied retrospectively because it was procedural rather than substantive. The court vacated the court of appeals decision, reversed the district court order, and remanded for consideration under the amended rule.

Holdings

1. Iowa Rule of Criminal Procedure 2.11(12), because it governs procedure rather than the substantive elements of the charged crimes, applies retrospectively to the pending dispute.
2. The court of appeals decision was vacated and the district court order requiring disclosure of witnesses' home addresses was reversed; the matter was remanded for the district court to consider the motion to compel under Iowa Rule of Criminal Procedure 2.11(12), as amended.

Questions Presented

1. Whether Iowa Rule of Criminal Procedure 2.5(3) required the State to include each witness's home address in the minutes of testimony.
2. Whether newly adopted Iowa Rule of Criminal Procedure 2.11(12), governing disclosure of witness addresses in minutes of testimony, applied retrospectively to resolve the pending dispute.

Disposition

reversed_and_remanded