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State of Iowa v. Lawrence George Canady III

Location: Iowa
Status: Ongoing
Last Update: February 20, 2024

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 ACLU 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 Court ultimately reversed the court of appeals conviction, although somewhat attempted to limit the admission of the rap video to the facts of the case.

At Lawrence Canady’s 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 “diss track” 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 ACLU argues that rap lyrics are rarely, if ever, probative of a criminal defendant’s 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’s Folsom Prison Blues is not evidence that the singer “shot a man in Reno,” rapping along to someone else’s “diss track” 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 ACLU’s brief argues that the Iowa Supreme Court should do the same.

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