State of Iowa, Appellee v. Hillary Lee Tyler, Appellant

Summary

The court held that the medical examiner’s opinions that the newborn died by drowning and that the death was a homicide were inadmissible because they rested primarily on Tyler’s inconsistent and uncorroborated statements rather than objective medical evidence and indirectly vouched for her credibility. It also held that Tyler had a reasonable expectation of privacy in the hotel room, requiring further proceedings on warrant and exclusionary-rule exceptions, but affirmed the denial of suppression as to her statements because she was not in custody before her initial confession and later waived her rights voluntarily. The court reversed in part, affirmed in part, and remanded for further proceedings and a new trial. Justices Waterman, Hecht, and Appel separately concurred in part and dissented in part, principally disputing the expert-testimony ruling or the admission of Tyler’s statements.