State v. Amisi
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The Supreme Court affirmed Defendant's conviction for operating while intoxicated (OWI) and eluding, holding that the district court did not abuse its discretion in admitting evidence about a preliminary breath test (PBT) and that the evidence was sufficient to support the convictions.
During the underlying jury trial, the district court admitted a portion of an officer body cam video showing Defendant agreeing to a PBT, after which the edited video jumped to Defendant's arrest for OWI. The Supreme Court held (1) this juxtaposition of the PBT and arrest violated Iowa R. Evid. 5.403 because it had minimal probative value while strongly implying that Defendant had failed the PBT, but the error was harmless; and (2) there was sufficient evidence to sustain Defendant's eluding conviction.
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