State v. Harrington
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Defendant Wendell Harrington was convicted of ongoing criminal conduct, first-degree theft, second-degree theft, and three counts of second-degree burglary, all enhanced as a habitual offender. The court of appeals reversed Harrington's conviction for ongoing criminal conduct, affirmed his remaining convictions, and preserved his ineffective-assistance claim for postconviction relief. The Surpeme Court granted review to consider whether the district court erred in admitting Harrington's prior theft and burglary convictions under Iowa R. Evid. 5.609. At issue was whether State v. Axiotis required the district court to balance the probative and prejudicial nature of Harrington's prior convictions before admitting them. The court of appeals concluded the district court had no duty to apply a balancing test as Harrington's prior convictions involved dishonesty and were therefore admissible under Iowa R. Evid. 5.609(a)(2). The Supreme Court agreed with the court of appeals and overruled Axiotis to the extent it suggests the balancing test articulated in Iowa R. Evid. 5.609(a)(1) applies to prior convictions that involve dishonesty or false statement under Iowa R. Evid. 5.609(a)(2). Accordingly, the Court affirmed the court of appeals decision as to the issue and affirmed the district court's admission of Harrington's prior convictions for impeachment purposes.
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