Stewart v. Iowa

Background

A man, Leroy James Stewart, was involved in an automobile accident on September 10, 1971, that resulted in two deaths. He was charged in Justice of the Peace Court with reckless driving and convicted on December 3, 1971, receiving 30 days in jail and costs. Meanwhile, a Benton County grand jury indicted him for manslaughter on October 12, 1971, and he was later tried and convicted of manslaughter. He appealed, and the Iowa Supreme Court affirmed the manslaughter conviction by a 5-to-4 vote.

Reasoning

The central question was whether prosecuting manslaughter after a prior reckless-driving conviction arising from the same event violated the constitutional protection against being tried twice for the same offense. The U.S. Supreme Court declined to take the case and denied the petition for review, leaving the Iowa court’s decision in place. A dissenting Justice argued the Court should have taken the case and reversed because, in his view, the federal protection against repeated prosecution requires related charges to be joined in one trial.

Real world impact

Because the high Court denied review, the Iowa Supreme Court’s judgment stays in effect and Stewart’s manslaughter conviction remains. The dispute among Justices, shown by the dissent, highlights that a federal question about whether separate trials on related charges are allowed was left unresolved by the den ial of review. This means similar disagreements could continue to be decided in state courts unless the Supreme Court takes a future case.

Dissents or concurrances

Justice Brennan, joined by Justices Douglas and Marshall, dissented from the denial and argued for granting review and reversing the manslaughter conviction on double-jeopardy grounds.