State of Iowa
v.
Terence Edward Manning Jr.
Appellee
State of Iowa
Appellant
Terence Edward Manning Jr.
Attorney for the Appellee
Zachary Miller, Assistant Attorney General
Attorney for the Appellant
Mary K. Conroy, Assistant Appellate Defender
Court of Appeals
Court of Appeals Opinion
Opinion Number:
Date Published:
Summary
Appeal from the Iowa District Court for Polk County, Heather Lauber, Judge. REVERSED AND REMANDED. Considered by Tabor, C.J., and Ahlers and Sandy, JJ. Opinion by Tabor, C.J. (15 pages)
Invoking the “silent witness” doctrine, the district court allowed the State to admit into evidence a police body camera recording of a surveillance video showing Terence Manning, Jr., punching and kicking another man in a convenience store parking lot. After seeing that video, the jury convicted Manning of willful injury causing serious injury. On appeal, Manning claims that the court should have excluded the video exhibit based on his authentication and best-evidence objections. He also challenges the sufficiency of the State’s evidence that he specifically intended to inflict serious injury. OPINION HOLDS: We find substantial evidence of Manning’s specific intent. But because the district court erred in admitting the surveillance video without proper authentication, and that error was not harmless, we reverse Manning’s conviction and remand for a new trial.
