## Facts

- Waterloo police officers received a tip about Phillip Glenn Caldwell, Jr. and located him as he parked at a convenience store where he worked.
- An officer approached Caldwell to detain him; Caldwell fled.
- During pursuit, Officer Mark Meyer claimed he saw Caldwell throw a white object; police recovered it and identified it as a baggie containing cocaine base.
- The prosecution’s proof that Caldwell possessed the baggie depended largely on Meyer’s account.
- Caldwell was charged with possession of a controlled substance with intent to deliver and failure to affix a drug tax stamp.
- To impeach Meyer, Caldwell offered three reputation witnesses to testify that Meyer had a community reputation for untruthfulness, including Ray Dial, a teacher and community participant who heard numerous complaints about Meyer from people of varied backgrounds.
- The trial court excluded all three witnesses, reasoning their knowledge came from a “limited class” of people who had negative experiences with Meyer rather than a general cross-section of the community.
- Caldwell was convicted on both counts.

## Issues

1. Whether the trial court abused its discretion by excluding reputation testimony offered to impeach a police witness’s character for truthfulness on the ground that it was derived from a “limited class” rather than a general cross-section of the community.
2. Whether exclusion of the reputation testimony prejudiced the defense where the excluded evidence targeted the credibility of a key prosecution witness.

## Decision

- The Iowa Supreme Court held the trial court abused its discretion by excluding Ray Dial’s proposed reputation testimony.
- The Court concluded Dial’s information came from a sufficiently broad and representative set of sources within the officer’s work community.
- The Court held the evidentiary error was prejudicial because Meyer’s credibility was central to the State’s case.
- The Court reversed in part, affirmed in part, and remanded for a new trial.

## Legal Principles

- Reputation evidence about a witness’s truthfulness is admissible only if a proper foundation shows it is derived from a general cross-section of the relevant community.
- The “general cross-section” requirement concerns the diversity and representativeness of the sources of reputation information, not whether the statements are uniformly favorable or unfavorable.
- A trial court has discretion to assess foundation for reputation testimony, but it abuses that discretion when it applies the wrong legal focus (content of comments rather than breadth of sources).
- Erroneous exclusion of impeachment evidence warrants reversal when it is reasonably likely to have affected the verdict, especially where the case turns on a single witness’s credibility.

## Conclusion

The court ordered a new trial because the trial court wrongly excluded broadly sourced reputation evidence that the State’s key officer-witness was untruthful, an error that likely affected the jury’s assessment of the central evidence of possession.


State v. Caldwell, 529 N.W.2d 282 (Iowa 1995)