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State of Iowa v. Tyler C. Hobbs

March 13, 2013

STATE OF IOWA, PLAINTIFF-APPELLEE,
v.
TYLER C. HOBBS, DEFENDANT-APPELLANT.



Appeal from the Iowa District Court for Lee County (South), Mary Ann Brown, Judge.

The opinion of the court was delivered by: Bower, J.

Tyler Hobbs appeals his conviction for the crime of murder in the first degree. AFFIRMED.

Considered by Eisenhauer, C.J., and Danilson and Bower, JJ.

Tyler Hobbs appeals his conviction for the crime of murder in the first degree. In his appeal, Hobbs argues the district court erred in failing to grant his motion for new trial. Hobbs contends the testimony of a key witness, necessary for his conviction, should have been disregarded. Because we find no error, we affirm.

I. Background Facts and Proceedings

Tyler Hobbs was tried, convicted, and sentenced for the offense of murder in the first degree in violation of Iowa Code section 707.1 and 707.2(1) (2009), after a jury trial. Hobbs was sentenced to life in prison without the possibility of parole. He appeals from the district court's denial of his motion for new trial.

The facts of the case surround November 5 and 6, 2010. On the dates in question Hobbs attended the performance of a band at the Lucky Star Bar in St. Francisville, Missouri. The band's lead singer, Kimberly Jaeger, was Hobbs's girlfriend and would later provide key testimony against him. At the close of the band's performance, Hobbs approached the bar and spoke with Shawn Wright, the decedent in this case. Hobbs offered Wright a ride to Keokuk, which Wright accepted. Hobbs, Wright, and Jaeger rode in Hobbs's car from St. Francisville to Keokuk.

During their brief stay in Keokuk Wright purchased marijuana. The circumstances of that purchase are in dispute. However, what is not in dispute is that following the purchase Hobbs, Wright, and Jaeger set out on a return trip to St. Francisville. Jaeger testified that during that trip Wright became sexually and physically aggressive, pushing drugs on her and repeatedly forcing her to kiss him. At some point, the three travelers decided to stop at an abandoned farmhouse located in Iowa; it is at this point that the testimony of Jaeger is disputed.

Jaeger testified that upon arriving at the farmhouse she exited the car to avoid the advances of Wright. Jaeger testified that, in an effort to free herself from Wright, she attempted to push him away and fell to the ground. Jaeger then testified that she observed Hobbs hit Wright in the head with a wooden mallet. Jaeger claims to have "crab walked" backwards to avoid Wright as he fell to the ground. Jaeger testified that she could see the fatal force of the impact in Wright's eyes as he fell. After a period of stunned silence, Hobbs directed Jaeger to empty Wright's pockets. Hobbs then struck Wright with the mallet several times to silence him.

Testifying in his own defense, Hobbs agreed that the parties stopped at the farmhouse. He stated, however, that he walked away from Wright and Jaeger to urinate. Hearing a shriek of some kind, Hobbs stated that he returned to find Jaeger standing over Wright with the mallet in her hand. He claims that Jaeger told him Wright had tried to rape her.

Jaeger and Hobbs generally agree on the course of events which followed. They returned to Hobbs's trailer for a brief time. Hobbs then borrowed a truck and returned to the farmhouse. He wrapped Wright's head in a plastic bag and secured the bag with speaker wire. Hobbs transported Wright's body in the back of the truck to the riverfront location where Wright would later be found dead. Hobbs then returned to the trailer and began cleaning the truck with bleach and water. Later, Hobbs and Jaeger returned to the farmhouse and recovered Wright's dentures and a drug pipe. Both items were eventually thrown from a bridge near St. Francisville.

Jaeger's initial statement to police and her testimony are in stark contrast. She contends that Hobbs instructed her to be quiet so as to protect herself from the consequences of the killing. This instruction was reflected in her initial, inconsistent statement to police. Hobbs testified that his actions following the killing were an effort to protect Jaeger.

Following his trial and conviction, Hobbs requested a new trial. He argued that Jaeger's testimony was inconsistent and unreliable. He further argued that the court should have ruled Jaeger was an accomplice, which would require corroborating evidence. The district court disagreed and denied the motion stating that the physical evidence presented at trial served as sufficient corroboration and that, even excluding Jaeger's testimony, ...


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