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Case No. 18-1821

State of Iowa
Patrick Ryan Thompson


State of Iowa


Patrick Ryan Thompson

Attorney for the Appellee

Genevieve Reinkoester, Assistant Attorney General

Attorney for the Appellant

Stephan J. Japuntich, Assistant Appellate Defender

Court of Appeals

Court of Appeals Opinion

Opinion Number:
Date Published:
Jan 21, 2021

            Appeal from the Iowa District Court for Guthrie County, Brad McCall, Judge.  AFFIRMED.  Heard by Mullins, P.J., and May and Schumacher, JJ.  Opinion by Mullins, P.J. (14 pages)

            Patrick Thompson appeals his convictions of murder and arson.  He argues the district court erred in failing to issue a spoliation jury instruction and in denying his motion to exclude expert witnesses, the evidence was not sufficient to support the convictions, and trial counsel provided ineffective assistance.  OPINION HOLDS: Thompson has failed to show there was an intentional destruction of evidence to necessitate a spoliation instruction.  Because the expert witnesses were qualified in accordance with the Iowa Rules of Evidence, the district court did not abuse discretion in denying Thompson’s motion to exclude.  Following our review of the record, we conclude a rational factfinder could find Thompson guilty beyond a reasonable doubt of arson in the first degree.  Thompson’s ineffective-assistance-of-counsel claim is preserved.

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