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State of Iowa
v.
William E. Crawford
William E. Crawford seeks further review from a court of appeals decision that determined the trial court did not abuse its discretion in denying his motion to continue trial and in admitting a video recording of his police interview into evidence. The court of appeals vacated the portion of the sentencing order requiring Crawford to affirmatively request a hearing on his ability to pay attorney fees and remanded for entry of a corrected sentencing order.
Resister
State of Iowa
Applicant
William E. Crawford
Attorney for the Resister
Timothy M. Hau, Assistant Attorney General
Attorney for the Applicant
Mary K. Conroy, Assistant Appellate Defender
Supreme Court
Oral Argument Schedule
Non-Oral
Apr 09, 2019 1:30 PM
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Supreme Court Opinion
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Court of Appeals
Court of Appeals Opinion
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Summary
Appeal from the Iowa District Court for Scott County, Thomas G. Reidel, Judge. CONVICTION AFFIRMED, SENTENCE VACATED IN PART, and remanded. Considered by Danilson, C.J., and Potterfield and Doyle, JJ. Opinion by Doyle, J. (8 pages)
William Crawford appeals the judgment and sentence imposed following his second-degree-murder conviction. OPINION HOLDS: I. The district court acted within its discretion in denying Crawford’s motion to continue the trial. The record shows the issue was not a matter of counsel’s lack of preparation but one of surprise based on unfavorable deposition testimony given by a witness that Crawford believed would help him at trial, and Crawford failed to make a sufficiently specific statement as to why a continuance was necessary. II. Even assuming statements made in a video of Crawford’s police interview were inadmissible, Crawford has failed to establish he was prejudiced by the statements when the evidence was cumulative and the court’s instruction limited the purposes for which the jury could consider the statements. III. We vacate the portion of the sentencing order requiring that Crawford affirmatively request a hearing on his ability to pay appellate attorney fees and remand for entry of a corrected sentencing order.