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668 N.W.2d 585

State v. Dullard

Supreme Court of Iowa

Decided September 4, 2003

Supreme Court of Iowa · decided 2003-09-04

Good law ✅— No negative treatment on recordhow we know

Decided 2003-09-04

How this case has been cited

Cited by 23 later decisions — most recently September 2020

23 state decisions

140200320102020decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

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CARTER, Justice

¶1(dissenting).

¶2I agree with the majority’s conclusion that the court of appeals applied an improper standard in considering the motion for judgment of acquittal as if the hearsay statement had not been admitted into evidence. Such motions must be determined on the basis of the evidence that has been admitted rather than the evidence that should have been admitted. I disagree, however, with the conclusion of the majority that, if the evidence presented by the State is viewed as including the challenged hearsay statement, the evidence was sufficient to support the verdict of guilt. The mysterious message to “B” is so lacking in probative value and the other evidence so inconclusive that, even if the message is considered to be a part of the record on which the sufficiency-of-evidence ruling is to be based, the motion for judgment of acquittal should have been sustained. I would reverse defendant’s conviction and remand for an entry of judgment of acquittal.

¶3LAVORATO, C.J., joins this dissent.

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