UPDATES & ANALYSIS

Iowa Supreme Court upholds first-degree murder conviction after fourth trial

by Nathan Wegmann | July 18, 2022

Stanley Liggins was convicted of first-degree murder from events which occurred in 1990. Liggins was charged with the murder of a nine-year-old child. Liggins’s initial conviction was overturned on appeal in 1994 due to the admission of irrelevant, prejudicial evidence at trial. Liggins was again convicted of first-degree murder, and his conviction was upheld on appeal by the Iowa Supreme Court in 1996. Liggins then filed for postconviction relief, which was denied in 2000. In 2007 Liggins filed a second action for postconviction relief based on the fact that the prosecution withheld information that one of the State’s witnesses in the case was a paid informant. This action was denied by the district court, but that ruling was overturned by the court of appeals and Liggins was granted a new trial. Liggins’s third trial commenced in 2018, but a mistrial was called due to a hung jury. Finally, Liggins’s fourth trial began in 2019 where he was again convicted of first-degree murder. Liggins moved for a new trial and his motion was denied by the district court. He appealed, and in a unanimous opinion released on June 30, the Iowa Supreme Court affirmed his conviction.

On appeal Liggins argued that his conviction cannot stand due to juror misconduct and numerous evidentiary challenges, insufficient evidence to support the conviction, and violation of due process rights. Liggins’s appeal based on juror misconduct stems from one juror who told the other members of the jury that the previous trial resulted in a hung jury. The Court ruled that this misconduct was not grounds for reversal because the revelation should not be a shock to the jury as there was evidence presented from previous trials and knowledge of a previous hung jury is not inflammatory.

Liggins challenged the admissibility of a deceased witness’s testimony on the grounds that he did not have a full and fair opportunity to cross-examine the witness in light of new evidence discovered since the witness’s death. The Court ruled that this was not grounds for reversal because the new evidence was insignificant, and Liggins had a fair opportunity to cross-examine the witness at a previous trial.

Liggins also challenged the admissibility of the testimony of a witness who provided inconsistent testimony which placed Liggins at the scene where and while the victim’s body was being burned. Liggins claimed that the testimony was so unreliable that it should have been excluded from evidence by the trial court because of the testimonial inconsistency and the fact that the witness was a paid informant. The Court held that the trial court did not abuse its discretion in admitting the testimony. The Court found that the testimony was not so inherently unreliable that it should be excluded; rather, the Court stated that the defects in the testimony gave Liggins an opportunity to “paint the State’s case in a negative light.”

Next, Liggins challenged the admissibility of a jailhouse informant’s testimony which claimed that Liggins admitted to the crime in jail. The Court noted that “there are obvious reasons to be concerned about the reliability of jailhouse informants,” but the district court did not abuse its discretion in admitting the testimony because the credibility of a jailhouse informant should be decided by the jury.

Liggins also claimed the testimony of an eyewitness who saw him and the victim together on the night of the murder was so unreliable that it should have been excluded due to the witness being drunk at the time of identification and the inconsistency of the witness’s story thereafter. The witness initially identified Liggins out of a photo lineup at the police station four days after the murder while drunk. The next day, however, the witness called the police and told them that he was unsure of his identification of Liggins due to his intoxication at the time. He returned to the police station a few days later where he was shown only one photo – of Liggins – and he stated that Liggins resembled the man he saw that night, but he could not be sure. Two years later at his deposition, the witness again positively identified Liggins. The Court found that it was within the trial court’s discretion to admit the evidence of the identification because the trial court also admitted evidence of the witness’s subsequent backtrack and later positive identification. Because the whole story was presented, the totality of the witness’s identification was left for the jury to evaluate its credibility.

At trial, Liggins attempted to introduce statements made by the victim to her friend that “bad things happen” to the victim when her mom was gone – suggesting that the victim’s stepfather may be responsible for the murder. “The district court determined that [the witness]’s testimony did not satisfy the residual hearsay exception and excluded the testimony.” The Court found that the exclusion of the evidence was not an abuse of discretion. It noted that the statement at issue lacked the requisite level of trustworthiness to be admitted under the exception.

Liggins also requested a new trial on the grounds that the evidence did not support his conviction. The trial court denied this motion, and in its ruling, the court misidentified certain pieces of evidence. On appeal, Liggins asserted that the circumstantial evidence was not enough to convict him and the district court’s misunderstanding of the record was grounds for a remand for the district court to reconsider the evidence. The Court found that the evidence was sufficient, and Liggins failed to bring the court’s inaccurate understanding of the record to the attention of the district court after its ruling, so the ground for overturning the conviction was waived.

Finally, Liggins claimed that “the combination of withheld exculpatory evidence . . . and the length of time between Liggins’s first two trials and the remand for retrial in 2014 violated [his] due process rights.” Liggins claims that the delay in the trial was unreasonable, and “given the remarkable passage of time [his] claims should be dismissed.” Liggins claims that this delay caused him prejudice due to the deaths of many of the witnesses in the trial and the effect of time on evidence and the memories of witnesses. The Court noted that such a delay was “troubling;” however, the Court attributed the delays to Liggins’s appeals and applications for postconviction relief. The Court further noted that the State was not without fault – due to its mistaken withholding of evidence – “but there is no evidence that the mistakes were designed to impose delay.” Due to the lack of intent on behalf of the State and the lack of prejudice imposed on Liggins by the delay, the Court found that there were no constitutional violations and Liggins’s conviction was affirmed.

Tags: Iowa Supreme Court 2021-2022