IOWA CITY, Iowa — A woman accused of drowning her newborn baby in an Iowa hotel room will get a new trial after an appeals court ruled Wednesday that her second-degree murder conviction was tainted by improper expert testimony.
The Iowa Court of Appeals reversed the conviction of Hillary Tyler, a former Mulhall, Oklahoma, resident sentenced last year to 50 years in prison. A state medical examiner should not have been allowed to testify the baby's death was a homicide caused by drowning because that conclusion was based on Tyler's alleged confession, not on scientific findings, the court said.
Prosecutors contend that Tyler became pregnant with her boyfriend's child in early 2011 but denied she was pregnant to him and everyone else even as her belly grew. The couple was living temporarily near Fort Dodge, Iowa, where they worked at a nitrogen plant.
Investigators say Tyler checked into a Fort Dodge hotel, where she gave birth. Hotel workers found blood in her room after Tyler left the next day and called police, who found the deceased baby in a trash can.
During an interview with police, Tyler initially claimed that the baby didn't make sounds or move after she gave birth and she immediately put him in the trash. Her story changed when asked about what the autopsy might show. She said the baby moved and cried and that she placed him face down in a water-filled bathtub to drown him. After she got medical treatment the next day, Tyler told officers that she knew the baby would drown when she put him in the water.
The medical examiner ruled the death a homicide caused by drowning after watching Tyler's videotaped police interview. But he said that based on the autopsy, he couldn't have given a scientific opinion on whether the baby was born alive or had ever taken a breath. Instead, he said he found her statements to police credible and consistent with how the baby might have died.
A judge allowed the medical examiner to testify at trial over Tyler's objections. Her defense argued that her confession was coerced and made when she needed medical care. Jurors rejected a first-degree murder charge but found her guilty of second-degree murder.
Writing for a three-judge panel, Judge Richard Doyle said the medical examiner's opinion on the cause of death should have been inadmissible since it was based on Tyler's disputed confession, not his medical expertise. He said there was little other corroborating evidence of a drowning, so the testimony "may have been the decisive factor in the jury's finding that the baby's death was the result of Tyler's action."
"Without his reliance upon her statements, he admitted he could not medically or scientifically opine whether the baby died in utero, immediately after its birth, or later via drowning," Doyle wrote. "His opinion could not be of assistance to the jury under the limited facts of this case."
Maria Ruhtenberg, a public defender who represented Tyler in the appeal, said the ruling was the first of its kind in Iowa. The ruling should prevent medical examiners from "becoming an arm of the police rather than a scientific expert testifying what the medical issues are," she said.
Prosecutors can ask the Iowa Supreme Court to review the ruling.