Marshall v. State
Annotate this CaseWhile investigating a death by shooting, state police spoke with Justin Marshall, whom the police believed to have information relating to the crime. Because of Marshall's apparent plan to leave the area, the State filed a material witness complaint against him and obtained an arrest warrant for him. After Marshall's arrest, another man was charged with murder in connection to the death. Marshall filed a motion to dismiss the material witness complaint, alleging his continued detention violated due process, equal protection, and cruel and unusual punishment. The district court ordered Marshall's release, concluding that the authority of the State to detain a material witness is extinguished when a trial date is set for the underlying crime and the material witness is served with a subpoena. At issue on review was the proper interpretation of Iowa Code 804.11, which provides for the arrest of a material witness when the witness might be unavailable for service of a subpoena. The Supreme Court affirmed the order of the district court, concluding that section 804.11 authorizes the arrest and detention of material witnesses to felonies only for the purpose of ensuring that a valid subpoena may be served upon the witness.
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