State of Iowa v. Bryan O'Neil Watkins

CourtCourt of Appeals of Iowa
DecidedDecember 18, 2024
Docket22-1968
StatusPublished

This text of State of Iowa v. Bryan O'Neil Watkins (State of Iowa v. Bryan O'Neil Watkins) 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. Bryan O'Neil Watkins, (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 22-1968 Filed December 18, 2024

STATE OF IOWA, Plaintiff-Appellee,

vs.

BRYAN O'NEIL WATKINS, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Black Hawk County, David P.

Odekirk, Judge.

A defendant appeals his convictions for two counts of assault causing bodily

injury, second-degree sexual abuse, and willful injury causing serious injury as a

habitual offender. AFFIRMED IN PART, REVERSED IN PART, AND

REMANDED.

Gary Dickey of Dickey, Campbell, & Sahag Law Firm, PLC, Des Moines, for

appellant.

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

Attorney General, for appellee.

Considered by Badding, P.J., Langholz, J., and Danilson, S.J.*

*Senior judge assigned by order pursuant to Iowa Code section 602.9206

(2024). 2

DANILSON, Senior Judge.

Criminal charges were filed against Bryan Watkins upon claims he brutally

attacked his then paramour over the course of several hours.1 The State’s

amended trial information charged Watkins with assault domestic abuse by

strangulation causing bodily injury (count I), second-degree sexual abuse (count

II), willful injury causing serious injury (count III), and assault domestic abuse

causing serious injury (count IV). Following a jury trial wherein Watkins

represented himself, the district court entered judgment and sentence against

Watkins as follows: count I—assault causing bodily injury as a lesser-included

offense; count II—sexual abuse in the second degree; count III—willful injury

causing serious injury as a habitual offender; and count IV—assault causing bodily

injury as a lesser-included offense.

Watkins raises three claims on appeal, (1) his waiver of trial counsel was

not knowing, intelligent, and voluntary; (2) his convictions should have merged;

and (3) count III should not be enhanced by the habitual-offender enhancement.

Following our review of the record, we affirm in part, reverse in part, and remand

for entry of a corrected sentencing order.

I. Waiver of Trial Counsel

We begin with Watkins’s claim that he did not knowingly, intentionally, and

voluntarily waive is right to trial counsel. As this claim is rooted in the U.S.

Constitution, our review is de novo. State v. Johnson, 756 N.W.2d 682, 686 (Iowa

2008). “The Sixth Amendment safeguards to an accused who faces incarceration

1 We do not detail the underlying facts that gave rise to Watkins’s convictions as

they are not relevant to Watkins’s appellate challenges. 3

the right to counsel at all critical stages of the criminal process.” Iowa v. Tovar,

541 U.S. 77, 80–81 (2004). It also guarantees a defendant the right to self-

representation. Farretta v. California, 422 U.S. 806, 807 (1975). The constitutional

right to counsel is effective until waived by a defendant. Hannon v. State, 732

N.W.2d 45, 52 (Iowa 2007). “In other words, before the right to self-representation

attaches, defendants must elect to proceed without counsel by a knowing,

intelligent, and voluntary waiver of their right to counsel.” State v. Jones, No. 19-

0494, 2020 WL 3264377, at *3 (Iowa Ct. App. June 17, 2020) (citing Faretta, 422

U.S. 835–36).

The waiver of the right to counsel “must be made with an apprehension of

the nature of the charges, the statutory offenses included within them, the range

of allowable punishments thereunder, possible defenses to the charges and

circumstances in mitigation thereof, and all other facts essential to a broad

understand of the whole matter.” State v. Cooley, 608 N.W.2d 9, 15 (Iowa 2000)

(quoting Von Moltke v. Gillies, 332 U.S. 708, 724 (1948)). Such is necessary to

ensure that the waiver is knowing. Id. The defendant must also be “admonished

as to the usefulness of an attorney at that particular proceeding and made

cognizant of the danger in continuing without counsel.” Id. A waiver that does not

meet these criteria cannot be considered voluntary and intelligent. See id.

To ensure that a defendant has such understanding, the district court should

engage in an extensive colloquy. Our supreme court has endorsed the colloquy

outlined in Spencer v. Ault, 941 F. Supp. 832, 843–44 (N.D. Iowa 1996), to ensure

a defendant wishing to represent themselves appreciates the impact of their waiver 4

of the right to counsel. State v. Martin, 608 N.W.2d 445, 450 (Iowa 2000). That

model colloquy includes the following questions:

(a) Have you ever studied law? (b) Have you ever represented yourself or any other defendant in a criminal action? (c) You realize, do you not, that you are charged with these crimes: (Here state the crimes with which the defendant is charged.) (d) You realize, do you not, that if you are found guilty of the crime charged in Count I the court . . . could sentence you to as much as __ years in prison and fine you as much as $__? (Then ask him a similar question with respect to each other crime with which he may be charged in the indictment or information.) (e) You realize, do you not, that if you are found guilty of more than one of those crimes this court can order that the sentences be served consecutively, that is, one after another? (f) You realize, do you not, that if you represent yourself, you are on your own? I cannot tell you how you should try your case or even advise you as to how to try your case. (g) Are you familiar with the [Iowa] Rules of Evidence? (h) You realize, do you not, that the [Iowa] Rules of Evidence govern what evidence may or may not be introduced at trial and, in representing yourself, you must abide by those rules? (i) Are you familiar with the [Iowa] Rules of Criminal Procedure? (j) You realize, do you not, that those rules govern the way in which a criminal action is tried in federal court? (k) You realize, do you not, that if you decide to take the witness stand, you must present your testimony by asking questions of yourself? You cannot just take the stand and tell your story. You must proceed question by question through your testimony. (l ) (Then say to the defendant something to this effect): I must advise you that in my opinion you would be far better defended by a trained lawyer than you can be by yourself. I think it is unwise of you to try to represent yourself. You are not familiar with the law. You are not familiar with court procedure. You are not familiar with the rules of evidence. I would strongly urge you not to try to represent yourself. (m) Now, in light of the penalty that you might suffer if you are found guilty and in light of all of the difficulties of representing yourself, is it still your desire to represent yourself and to give up your right to be represented by a lawyer? (n) Is your decision entirely voluntary on your part? (o) If the answers to the two preceding questions are in the affirmative, you should then say something to the following effect: “I 5

find that the defendant has knowingly and voluntarily waived his right to counsel.

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Related

Blockburger v. United States
284 U.S. 299 (Supreme Court, 1931)
Von Moltke v. Gillies
332 U.S. 708 (Supreme Court, 1948)
Faretta v. California
422 U.S. 806 (Supreme Court, 1975)
Iowa v. Tovar
541 U.S. 77 (Supreme Court, 2004)
State v. Johnson
756 N.W.2d 682 (Supreme Court of Iowa, 2008)
State v. Martin
608 N.W.2d 445 (Supreme Court of Iowa, 2000)
State v. Cooley
608 N.W.2d 9 (Supreme Court of Iowa, 2000)
State v. Bruegger
773 N.W.2d 862 (Supreme Court of Iowa, 2009)
State v. Halliburton
539 N.W.2d 339 (Supreme Court of Iowa, 1995)
State v. Oetken
613 N.W.2d 679 (Supreme Court of Iowa, 2000)
Hannan v. State
732 N.W.2d 45 (Supreme Court of Iowa, 2007)
Spencer v. Ault
941 F. Supp. 832 (N.D. Iowa, 1996)
State of Iowa v. Darion Aubrea Love
858 N.W.2d 721 (Supreme Court of Iowa, 2015)
State of Iowa v. Valentin Velez
829 N.W.2d 572 (Supreme Court of Iowa, 2013)

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