State of Iowa v. Jackson
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In the Supreme Court of Iowa, the case involved David Jackson, who was involved in a car accident that resulted in the death of another motorist. Jackson was convicted of vehicular homicide by operating while intoxicated, reckless driving, leaving the scene of an accident resulting in death, and operating a motor vehicle without the owner’s consent. Jackson appealed on the basis that the court allowed rebuttal evidence of his medical condition, which he claimed caused him to black out and lose control of the vehicle, over his objections that the evidence was hearsay.
The Court concluded that the district court had erred in admitting the testimony of an employee of a healthcare vendor who had reviewed some of Jackson’s post-accident medical records. The court found that the testimony was hearsay and did not fall into the business records exception to the hearsay rule because the testimony was about the records, not the records themselves.
The Court affirmed Jackson’s conviction for operating a motor vehicle without the owner’s consent, but vacated his convictions for vehicular homicide (OWI), reckless driving, and leaving the scene of an accident resulting in death, and remanded the case for further proceedings.
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