Supreme Court of Iowa
State of Iowa, Appellee v. Andrew Marcus Sullivan, Appellant
April 7, 20042004 Iowa Sup. LEXIS 110
Summary
The Iowa Supreme Court held that the trial court abused its discretion by admitting testimony about Sullivan’s prior drug‑dealing conduct, finding the evidence inadmissible under Iowa Rule of Evidence 5.404(6) and that the error was not harmless. Accordingly, the Court reversed the district‑court judgment and remanded for a new trial. The Court also overruled its prior decision in State v. McDaniel, reaffirming the exclusionary nature of the rule.
Holding
- Whether testimony about Sullivan’s prior possession of crack cocaine with intent to deliver is admissible under Iowa Rule of Evidence 5.404(6).. The testimony is inadmissible because the State failed to articulate a valid, noncharacter theory of relevance; thus the district court abused its discretion in admitting it.
- Whether the admission of that testimony constitutes reversible error or a harmless error under Iowa Rule of Evidence 5.103(a).. The error is not harmless; it affected Sullivan’s substantial rights, requiring reversal of the judgment.
Docket 02-0542
Cited authorities
- Iowa Rule of Evidence 5.404(6)
- rule 5.404(6)
- Iowa Rule of Evidence 5.404(6)
- Iowa Rule of Evidence 5.404(6)
- Iowa R. Evid. 5.404(6)
- Rule 5.404(6)
- rule 5.404(b)
- rule 5.404(6)
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