State of Iowa, Appellee v. Jonas Dorian Neiderbach, Appellant

Summary

The court affirmed Thompson’s second-degree murder conviction, holding that the evidence did not support a voluntary-manslaughter instruction, the challenged hearsay was properly excluded or harmless, and the defendant failed to satisfy the statutory threshold for access to the victim’s mental-health records. It upheld Iowa Code section 622.10(4) against a facial due-process challenge, concluding that the statute may require a reasonable probability of exculpatory information, unavailability from other sources, and judicial rather than defense-counsel in camera review. The court also held that Thompson failed to preserve his challenge to the standard used to deny a new trial. Justice Cady concurred specially regarding case-by-case development of the statutory standard, and Justice Appel, joined by Justices Wiggins and Hecht, concurred in the result while disagreeing with portions of the majority’s analysis.