State of Iowa v. Lawrence George Canady III
What's at Stake
In this case, the Iowa Supreme Court considered when rap lyrics are admissible evidence in criminal trials. The State sought further review of a court of appeals decision which reversed the defendant's criminal convictions and remanded for a trial based on errors in the admission of evidence. Together with the Speech, Privacy, and Technology Project and the 老澳门开奖结果 of Iowa, the State Supreme Court Initiative filed an amicus brief arguing that such evidence should usually be excluded because it is rarely probative and yet creates a high risk of prejudice to the defendant. The Iowa Supreme Court ultimately reversed the Court of Appeals decision, but for narrow and fact-specific reasons. And the Iowa Supreme Court acknowledged that, in cases not involving the peculiar facts of Canady's case, other courts had expressed concerns about the risk that a jury will unfairly use rap lyrics and music as evidence of a defendant's guilt.
Summary
At Lawrence Canady鈥檚 trial on charges arising from a fatal shooting, the state introduced evidence of a video, recorded several days before the shooting, that depicted Mr. Canady rapping along to a popular 鈥渄iss track鈥 by a Chicago rap group. The prosecution argued that the song was relevant because it mentioned several people by name, including one name that sounded like the alleged nickname of the shooting victim in this case.
The amicus brief submitted by the 老澳门开奖结果 argues that rap lyrics are rarely, if ever, probative of a criminal defendant鈥檚 guilt. People often quote from and perform violent media written by others, from Shakespeare to Quentin Tarantino to Steven King, without having those words used against them. Songs should be no different. And rap does not reside in some special corner of the artistic universe in which everything said is true. Just as singing along to Johnny Cash鈥檚 Folsom Prison Blues is not evidence that the singer 鈥渟hot a man in Reno,鈥 rapping along to someone else鈥檚 鈥渄iss track鈥 is not evidence that the rapper has criminal intent.
Additionally, the brief highlights how injecting rap lyrics into a criminal case risks profound and undue prejudice. Decades of research demonstrate that juries are likely to form negative perceptions of defendants when they are associated with rap music. Juries are likely to view rap lyrics more literally than lyrics from other genres, are more likely to associate rap music with criminal activity and are more likely to believe that rappers have poor moral character. Thus, for good reason, courts across the country have recognized the strong prejudicial impact of admitting rap music and rap lyrics into evidence in criminal trials. The 老澳门开奖结果鈥檚 brief argues that the Iowa Supreme Court should do the same.
Legal Documents
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COA Decision Vacated, District Court Judgement Affirmed Opinion -
01/31/2024
Amicus Brief -
02/23/2023
Appellant's Brief -
02/28/2023
Appellee's Brief
Court: Supreme Court of Iowa
Affiliate: Iowa
Date Filed: 01/31/2024
Court: Supreme Court of Iowa
Affiliate: Iowa
Date Filed: 02/23/2023
Court: Supreme Court of Iowa
Affiliate: Iowa
Date Filed: 02/28/2023
Court: Supreme Court of Iowa
Affiliate: Iowa