State v. Boothby
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The Supreme Court affirmed Defendant's convictions for assault with a dangerous weapon and third degree criminal mischief, holding that Iowa R. Evid. 5.701 and 5.702 did not require certain testimony concerning historical cell site data to be presented by an expert.
Investigating officers used Defendant's cell phone records to place him in the general vicinity at the time of the incident giving rise to Defendant's convictions. On appeal, Defendant argued that his counsel provided ineffective assistance by not challenging the phone records as inadmissible hearsay and by not challenging the testimony provided by an officer as an unqualified expert. The Supreme Court affirmed, holding (1) the testimony at issue was not based on specialized knowledge and thus did not require an expert; and (2) therefore, Defendant's counsel was not ineffective for failing to challenge the phone records or the officer's testimony.
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