State of Iowa v. Chad Reese Bennett

CourtCourt of Appeals of Iowa
DecidedAugust 30, 2023
Docket22-0192
StatusPublished

This text of State of Iowa v. Chad Reese Bennett (State of Iowa v. Chad Reese Bennett) 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. Chad Reese Bennett, (iowactapp 2023).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 22-0192 Filed August 30, 2023

STATE OF IOWA, Plaintiff-Appellee,

vs.

CHAD REESE BENNETT, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Marion County, Dustria A. Relph,

Judge.

Chad Bennett challenges the sufficiency the evidence supporting his

convictions and the district court’s refusal to recuse herself. AFFIRMED.

Erin M. Carr of Carr Law Firm, P.L.C., Des Moines, for appellant.

Brenna Bird, Attorney General, and Israel Kodiaga, Assistant Attorney

General, for appellee.

Considered by Ahlers, P.J., Badding, J., and Mullins, S.J.*

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

(2023). 2

AHLERS, Presiding Judge.

Chad Bennett was charged with sexual abuse of a ten-year-old girl. To

maintain confidentiality, we will call the girl Holly, though that is not her real name. 1

In conjunction with the charges, a no-contact order was issued prohibiting Bennett

from contacting Holly personally or through third parties. Despite the no-contact

order, while Bennett was in jail awaiting trial on the sexual-abuse charges he and

his mother hatched a plan to try to get Holly to recant her allegations against

Bennett. The plan was hatched via text messages2 exchanged between Bennett

(from jail) and his mother (who was not in jail). The plan called for the mother to

contact Holly to try to get her to say Bennett did not sexually abuse her. After the

plan was put into action and then discovered, the State charged Bennett with

stalking,3 conspiracy to commit stalking,4 tampering with a witness,5 and

conspiracy to tamper with a witness.6 Bennett’s mother was charged similarly as

a co-defendant.

Bennett waived his right to a jury trial in favor of a bench trial. The district

court found Bennett guilty on all four counts.7 He appeals. He contends the

1 We used a random-name generator to come up with the name Holly. 2 The evidence at trial established that the jail housing Bennett had a communication system that enabled inmates to use a kiosk in the jail to send electronic messages to people outside jail. The people on the outside could then communicate back to inmates via electronic message using the same system. For ease of reference, we will refer to these electronic messages as text messages. 3 See Iowa Code §§ 708.11(2), .11(3)(a) (2020) (a class “C” felony as a third

offense). 4 See Iowa Code §§ 706.1(1), .3(2) (a class “D” felony). 5 See Iowa Code § 720.4 (an aggravated misdemeanor). 6 See Iowa Code §§ 706.1(1), .3(3) (an aggravated misdemeanor). 7 Bennett was tried jointly with his mother, who did not waive her right to a jury trial.

The mother’s case is not before us in this appeal. 3

evidence is insufficient to support the guilty findings on all four counts and the

district court erred by refusing to recuse herself.

I. Sufficiency of the Evidence

We begin our discussion of Bennett’s sufficiency challenge by rejecting two

themes that permeate his arguments on appeal. The first theme is that Bennett

did not commit the crimes charged because all he did was try to get Holly to testify

to the “truth.” Of course, Bennett’s concept of truth is a narrative in which Bennett

did not sexually abuse Holly—the opposite of the narrative Holly told authorities

that resulted in the sexual-abuse charges against Bennett. We reject Bennett’s

suggestion that he is somehow insulated from criminal culpability for his efforts to

try to get Holly to change her narrative simply by labeling his preferred narrative

as “the truth.” See State v. Halleck, 308 N.W.2d 56, 59 (Iowa 1981) (“To improperly

influence a witness is not limited to asking a witness to lie.”).

The second theme we reject is Bennett’s portrayal of isolated pieces of

evidence from the record as fact. We reject this theme because it asks us do the

opposite of what our standard of review requires us to do. In reviewing the

sufficiency of the evidence in a bench trial we view the district court’s findings as

we would a jury verdict, meaning we are bound by the district court’s finding of guilt

if it is supported by substantial evidence. State v. Warren, 955 N.W.2d 848, 857

(Iowa 2021). Evidence supporting a guilty finding is substantial if, when viewed in

the light most favorable to the State, it could convince a rational fact finder that the

defendant is guilty beyond a reasonable doubt. Id. As the standard of review

requires us to view the evidence in the light most favorable to the State, we reject

Bennett’s efforts to have us view the evidence in the light most favorable to him. 4

With this standard of review in mind, we address the sufficiency of the

evidence supporting each of the four charges of which Bennett was found guilty.

A. Stalking

On the stalking charge, the State charged Bennett as a principal or as an

aider and abettor. As a result, the State was required to prove:

1. Bennett or someone he aided and abetted purposefully engaged in

a course of conduct directed at Holly that would cause a reasonable person

to feel terrorized, frightened, intimidated, or threatened; and

2. Bennett knew or should have known that a reasonable person would

feel terrorized, frightened, intimidated, or threatened by the course of

conduct.

See Iowa Code § 708.11(2). As it relates to the facts of this case, “course of

conduct” means maintaining a visual or physical proximity to a person without

legitimate purpose on two or more occasions. See id. § 708.11(1)(b), (d).

Viewed in the light most favorable to the guilty finding, the evidence

establishes that Bennett and his mother exchanged text messages in which they

put together the plan to have the mother contact Holly to try to get her to say

Bennett did not sexually abuse Holly. Preying on Bennett’s belief that Holly was

religious, the plan included telling Holly she would go to hell if she didn’t tell the

truth—again, with the understanding that Bennett’s version of the truth was that he

did not sexually abuse Holly. The plan also included having the mother entice

Holly to talk to her by giving Holly specific types of candy that Bennett knew Holly

favored and offering to let Holly see Bennett’s kittens. The plan included details

about opportunities the mother should engineer to run into Holly. Those 5

opportunities included trying to find Holly at a city-sponsored Halloween event,

driving around the neighborhood where Holly lived around school-closing time,

hanging out at Holly’s neighbor’s house (Holly is a neighbor to Bennett’s brother)

until Holly could be spotted, and trying to get Bennett’s nephew (a neighbor to

Holly) to offer to buy a treat at a local coffee shop if Holly would come with him

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Related

State v. Biddle
652 N.W.2d 191 (Supreme Court of Iowa, 2002)
State v. Smith
242 N.W.2d 320 (Supreme Court of Iowa, 1976)
State v. Millsap
704 N.W.2d 426 (Supreme Court of Iowa, 2005)
State v. Halleck
308 N.W.2d 56 (Supreme Court of Iowa, 1981)
State v. LaPointe
418 N.W.2d 49 (Supreme Court of Iowa, 1988)
State v. Sinclair
582 N.W.2d 762 (Supreme Court of Iowa, 1998)

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