State of Iowa, Appellee v. Daniel Sullivan Elam, Appellant

Summary

The court affirmed Daniel Elam’s first-degree murder conviction after rejecting four challenges concerning excluded psychological testimony, jury instructions on permissive inferences of malice and intent, admission of a confederate’s threat to a witness, and sufficiency of the evidence against justification. The court held that the expert testimony did not address Elam’s actual circumstances, the instructions did not shift the burden of proof, the threat was admissible as evidence of a conspiracy to conceal the crime and obstruct prosecution, and substantial evidence supported the jury’s rejection of justification.