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State of Iowa v. Hillary Lee Tyler. IA criminal law, expert testimony
Hillary Lee Tyler was convicted in Webster County of the second-degree murder of her newborn baby. In 2011, she became pregnant, but denied being pregnant. She managed to conceal the pregnancy, even from the boyfriend with whom whe was living. When the boyfriend was transferred to a job in Fort Dodge, she accompanied him, and they were living in a trailer. In the early morning hours of September 19, she began experiencing contractions, and called a hotel in Fort Dodge, which told her that a room was available, and she checked in. At about noon, she gave birth in the bathroom. She then did some cleaning and returned to the trailer, where she stayed for the night. At about 10:15, she returned to the hotel to check out, but was told that the room was available for a second night because of a cancellation. She rented the room for another night before returning to the trailer, intending to come back and do more cleaning.
At 11:00, the housekeeper, believing that Tyler had checked out, entered the room to clean it. The housekeeper saw blood on the carpet, the bathroom floor, and on a coat that had been left behind. On the counter, she saw $8, which she believed had been left as a tip. She saw a towel bundled up in the garbage can and noted that it was heavy. Believing that something was wrong, another housekeeper entered the room and noticed blood and fluid in the can. They reported their findings to the manager, who called the police.
The first officer believed that the call was for "criminal mischief or vandalism," and entered the room with hotel staff to investigate. He eventually called his supervisor, who arrived, as did other officers. Eventually, one of them found the baby's body in the trash can. They secured the room and called in detectives, who located Tyler a couple of hours later. When they knocked on her door, they first asked if she needed any medical attention, and she told them that she did not. They told her that they needed to get to the bottom of what had happened, and told her they wanted her to go with them to the police station.
During the ride to the station, one of the officers asked if the baby had cried or moved, and Tyler said that he had not. She was taken to an interview room and told that she was allowed to leave. After a break, she eventually told officers that the baby moved and cried, and that she had put him in the bathtub for the purpose of drowning him. At that point, she was told that she would be charged and was read her Miranda rights. She waived those rights, and continued to make statements. The officers then took her to the hospital for medical treatment.
After the interview, the police also obtained a search warrant for the hotel room, the trailer, and a vehicle. An autopsy was performed by Associate State Medical Examiner Dr. Jonathan Thompson. His final report concluded that the cause of death was "bathtub drowning" and that the death was a homicide. That opinion was based largely upon the statements given to police that the baby was alive and had been drowned. The physical evidence from the autopsy was largely inconclusive.
Before trial, Tyler had moved to suppress her statements, as well as the medical examiner's testimony as to the cause of death. Those motions were denied, and the appeal was eventually heard by the Iowa Supreme Court. The Supreme Court reversed the conviction and remanded the case for a new trial.
On the issue of the foundation for the medical examiner's opinion, the Court first noted that whether he can rely on statements made to police in forming his opinion was a question of first impression in Iowa. The Court first noted that expert testimony should be allowed only when the opinion assists the jury. After examining cases from other jurisdictions, the Court concluded that there is no bright-line rule, and the determination rests on the facts of the particular case.
In this case, the Court held that the opinion as to cause of death was not admissible. In so holding, it focused on the fact that the opinion was not based on scientific, technical, or other specialized knowledge. Instead, it was based primarily upon the defendant's statements. The medical examiner's testimony regarding those statements did not call upon his particular expertise, and was really the province of the jury.
For these reasons, the Supreme Court held that it was improper to include this testimony, and reversed the case and remanded for new trial for that reason. Justices Waterman, Cady, and Mansfield dissented from this portion of the opinion and would have allowed the evidence, asking the question, "why fault Dr. Thompson for considering the mother's own incriminating statements as to how she killed her baby?"
On the issue of the police search of the hotel room, the Supreme Court concluded that the district court had erred in finding that Tyler had no reasonable expectation of privacy. And since there was an insufficient record to determine whether an exception to the warrant requirement applied, it remanded the case for this determination.
Finally, the court held that Tyler was not in custody at the time she made her initial incriminating statements, and that she had voluntarily waived her Miranda rights after having them read to her. Therefore, the Court held that it was not error to allow those statements into evidence. Juctices Hecht, Wiggins, and Appel dissented from this portion of the ruling and would have held these statements inadmissible.
No 13-0588 (Iowa June 30, 2015)
Please see the original opinion for the court's exact language.
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Richard P. Clem is an attorney and continuing legal education (CLE) provider in Minnesota. He has been in private practice in the Twin Cities for 25 years. He has a J.D., cum laude, from Hamline University School of Law in St. Paul and a B.A. in History from the University of Minnesota. His reported cases include: Asociacion Nacional de Pescadores a Pequena Escala o Artesanales de Colombia v. Dow Quimica de Colombia, 988 F.2d 559, rehearing denied, 5 F.3d 530 (5th Cir. 1993), cert. denied, 510 U.S. 1041 (1994); LaMott v. Apple Valley Health Care Center, 465 N.W.2d 585 (Minn. Ct. App. 1991); Abo el Ela v. State, 468 N.W.2d 580 (Minn. Ct. App. 1991).
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