State of Iowa
v.
William Bret Moothart
Appellee
State of Iowa
Appellant
William Bret Moothart
Attorney for the Appellee
Joseph D. Ferrentino, Assistant Attorney General, and Samantha Stewart (argued), certified law student intern
Attorney for the Appellant
Trevor A. Jordison (argued) and Billy J. Mallory
Court of Appeals
Court of Appeals Opinion
Opinion Number:
Date Published:
Summary
Appeal from the Iowa District Court for Dallas County, Michael Jacobsen, Judge. AFFIRMED. Heard at oral argument by Schumacher, P.J., and Badding and Langholz, JJ. Opinion by Langholz, J. (11 pages)
William Moothart appeals his conviction for operating while intoxicated. He argues that admitting his blood-test results deprived him of due process when the State destroyed his blood sample before trial, the State’s late production of a chain-of-custody document warrants a new trial, and insufficient evidence supports the verdict. OPINION HOLDS: Due process does not referee strict compliance with state law—it safeguards Moothart’s access to constitutionally material evidence. Because Moothart has not shown his blood sample had exculpatory value at the time it was destroyed or that the State intentionally destroyed the sample in bad faith, admitting testimony about his blood-test results did not deprive him of due process. As for his other issues, the State’s late production of a chain-of-custody document was not prejudicial, so we deny his request for a new trial. And substantial evidence supports the jury’s findings that Moothart indeed operated the motorcycle and did so while under the influence of alcohol. We thus affirm Moothart’s conviction.
