State of Iowa v. Andrew Raymond Karvel

CourtCourt of Appeals of Iowa
DecidedDecember 4, 2024
Docket23-1741
StatusPublished

This text of State of Iowa v. Andrew Raymond Karvel (State of Iowa v. Andrew Raymond Karvel) is published on Counsel Stack Legal Research, covering Court of Appeals of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Iowa v. Andrew Raymond Karvel, (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 23-1741 Filed December 4, 2024

STATE OF IOWA, Plaintiff-Appellee,

vs.

ANDREW RAYMOND KARVEL, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Allamakee County, Alan Heavens,

Judge.

The defendant appeals his second-degree murder conviction. AFFIRMED.

Shea M. Chapin of The Chapin Center, PLC, Dubuque, for appellant.

Brenna Bird, Attorney General, and Joseph D. Ferrentino, Assistant

Attorney General, for appellee.

Considered by Greer, P.J., and Ahlers and Badding, JJ. 2

GREER, Presiding Judge.

The death of Daniel Lundy, Andrew Karvel’s roommate, was ruled a

homicide. Following an investigation into the cause of Lundy’s death, Karvel was

charged with first-degree murder. Ultimately a jury found Karvel guilty of murder

in the second degree, a class “B” felony, after a three-day trial. Before trial, the

district court ruled evidence of Karvel’s prior conviction for an assault against

Lundy was admissible at trial. After the jury’s verdict, Karvel moved for a new trial,

claiming the State committed Brady violations,1 the weight of the evidence did not

support the jury’s verdict, and the verdict form was improper and prejudicial.

Karvel now appeals, arguing there was insufficient evidence to support the verdict

and that the district court abused its discretion admitting evidence of Karvel’s prior

bad act and by denying his motion for new trial. After our review, we affirm Karvel’s

conviction.

I. Background Facts and Proceedings.

For many years, Lundy lived in the old Allamakee County courthouse with

his roommate, Karvel. But shortly after Lundy returned home from a winter stay at

a nursing home, he was found dead on the floor. On May 9, 2022, at 7:30 a.m.,

Karvel called 911, requesting medical attention for Lundy and telling the dispatch

operator that Lundy was not breathing. First responders entered the residence,

checked for Lundy’s pulse, and noted that his extremities were “cool to the touch.”

Karvel alerted the responders that Lundy had been lying on the floor, unable to sit

up, for up to two days. Within the last day, Lundy had been struggling to breathe

1 Brady v. Maryland, 373 U.S. 83, 87 (1963) (holding due process requires the

prosecution to disclose exculpatory evidence to the accused). 3

through his own phlegm. After briefly discussing the nature of the scene with

Karvel, first responders removed Lundy from the residence. Contrary to Karvel’s

statements to the dispatch operator that he was performing life saving measures

on Lundy, law enforcement and the responders on scene observed otherwise, and

Karvel could not logically explain why he did nothing to help Lundy where he had

been left immovable on the ground for days. Only after the autopsy was completed

was Lundy’s death ruled a homicide. At the time of his death, Lundy was septic,

but based on bruising, internal hemorrhaging, and fracturing, and the fact Lundy

had not been in a “high velocity” accident before his death, the medical examiner

found Lundy’s cause of death to be strangulation.

Karvel was charged with the first-degree murder of Lundy, a class “A”

felony. Before trial, Karvel moved in limine, seeking to bar the admission of his

prior criminal behavior, specifically a simple assault against Lundy that occurred in

2019, which Karvel pled guilty to through an Alford2 plea agreement. The district

court reserved ruling on the motion in limine, giving both parties an opportunity to

brief the issues.

Shortly before the trial, the State moved for a ruling based on Iowa Rule of

Evidence 5.104(a), asking the court to admit evidence of Karvel’s prior assault on

Lundy, including Lundy’s statements to law enforcement during the investigation

of that simple assault and statements of observations by an eyewitness. Karvel

resisted, asserting several evidentiary challenges to the admission of evidence of

2 North Carolina v. Alford, 400 U.S. 25, 37 (1970) (holding “express admission of

guilt . . . is not a constitutional requisite to the imposition of [a] criminal penalty”). 4

the prior assault. After conducting the appropriate analysis, the district court ruled

that the complaint, affidavit, and order of disposition were admissible.

At the trial, evidence of the prior simple assault by Karvel against Lundy

was admitted. Additional evidence, including time stamps from Lundy’s

pacemaker and a traffic camera showing Karvel’s travel around the time of Lundy’s

death, were admitted to partially corroborate the timeline of events on May 9. The

jury found Karvel guilty of second-degree murder, one of the lesser-included

offenses of murder included in jury instructions. On October 2, 2023, before

sentencing, Karvel filed a motion for new trial and motion in arrest of judgment.

Karvel alleged that the district court allowed unduly prejudicial prior-bad-act

evidence to be admitted into evidence at trial, the verdict was contrary to the weight

of the evidence, the State committed Brady violations, and the verdict form was

improper and prejudicial. The district court found each of these claims meritless.

Karvel was sentenced to fifty years in prison, with a mandatory minimum of thirty-

five years. Karvel appeals.

II. Discussion.

In this sequence, we tackle Karvel’s challenges to the (1) admission of the

prior simple assault evidence, (2) the sufficiency of the evidence supporting his

conviction and (3) the denial of his motion for new trial.

A. Admission of Prior-Bad-Acts Evidence.

The State sought to admit evidence of Karvel’s previous assault against

Lundy. Karvel moved to exclude the evidence. After a hearing on the motion, the

district court found the criminal complaint, affidavit, and dispositional order

pertaining to Karvel’s simple assault conviction were admissible at the trial under 5

Iowa Rule of Evidence 5.404(b)(1). We review the district court’s admission of

prior-bad-acts evidence for an abuse of discretion. State v. Tyler, 867 N.W.2d 136,

152 (Iowa 2015).

At the onset, we consider that under rule 5.404(b)(1), the use of prior bad

acts is prohibited when used to prove someone’s character to show they acted in

accordance with that character on a particular occasion. However, evidence “may

be admissible for another purpose such as proving motive, opportunity, intent,

preparation, plan, knowledge, identity, absence of mistake, or lack of accident.”

Iowa R. Evid. 5.404(b)(2). We are required to evaluate the admissibility of prior-

bad-act evidence under a three-step analysis: whether (1) the evidence of prior

bad acts “relevant to a legitimate, disputed factual issue”; (2) there is clear proof

that Karvel committed the prior bad act; and (3) the evidence’s probative value

“substantially outweighed by the danger of unfair prejudice to the defendant.”

State v. Putnam, 848 N.W.2d 1, 8–9 (Iowa 2014).

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