State of Iowa v. Enoc Alvarenga

CourtCourt of Appeals of Iowa
DecidedNovember 17, 2022
Docket22-0181
StatusPublished

This text of State of Iowa v. Enoc Alvarenga (State of Iowa v. Enoc Alvarenga) 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. Enoc Alvarenga, (iowactapp 2022).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 22-0181 Filed November 17, 2022

STATE OF IOWA, Plaintiff-Appellee,

vs.

ENOC ALVARENGA, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court of Dubuque County, Michael J. Shubatt,

Judge.

Enoc Alvarenga appeals his convictions for enticing a minor and indecent

contact with a child. AFFIRMED.

Martha J. Lucey, State Appellate Defender, and Theresa R. Wilson,

Assistant Appellate Defender, for appellant.

Thomas J. Miller, Attorney General, and Louis S. Sloven, Assistant Attorney

General, for appellee.

Considered by Vaitheswaran, P.J., and Greer and Schumacher, JJ. 2

VAITHESWARAN, Presiding Judge.

A jury found Enoc Alvarenga guilty of enticing a minor and indecent contact

with a child. The district court sentenced him to prison for terms not exceeding ten

and two years respectively, to be served consecutively.

On appeal, Alvarenga contends the district court abused its discretion in

(1) denying his motion in limine to exclude evidence of his arrest and (2) imposing

consecutive sentences.

I. Limine Ruling

Alvarenga’s pretrial motion in limine sought to prevent the State “from

introducing details of [his] arrest.” He asserted evidence “that he resisted and/or

attempted to flee . . . would cause the jury to improperly conclude that [he] was

avoiding law enforcement due to the allegations stemming from the instant case”

or might force him “to reveal a prior bad act.” Citing Iowa Rule of Evidence 5.403,

he argued the evidence, while relevant, was “substantially outweighed by unfair

prejudice.” At a hearing on the motion, the prosecutor noted that Alvarenga was

arrested on a warrant on the underlying charges and his “attempt[] to flee” was

evidence of his “consciousness of guilt” that was “something for the jury to

consider.” Alvarenga responded that admission of the evidence would put the

defense in “an unfair situation.” The district court denied the motion, reasoning the

evidence placed the defense in “a difficult situation” rather than an “unfair

situation,” requiring a strategic decision on how to respond. The court stated trial

strategy was an insufficient ground to exclude evidence that “would normally come

in.” 3

At trial, an officer with the Dubuque Police Department testified he was at a

convenience store to check on an abandoned vehicle. He ran the plate, which

came back to Alvarenga, who he “knew to have an active warrant for his arrest.”

Momentarily, he “observed [Alvarenga] walking toward[] [him] in the direction of his

vehicle.” He “grabbed onto [Alvarenga’s] right arm and said, hey, you got warrants

for your arrest and went to go place him into handcuffs.” As he did so, Alvarenga

“pulled his arms away” and both individuals “went to the ground.” According to the

officer, “[t]here was a struggle on the ground there for a second” and Alvarenga

got away, and ran “along the front of the store again while [he] still had a hold of

[Alvarenga’s] shirt.” The officer kicked Alvarenga’s “feet from underneath him,”

and “he tripped and fell.”

Alvarenga did not lodge a trial objection to this testimony. He did object to

the offer of surveillance footage from the convenience store, citing “the objection

that was previously made” during pretrial motions. The district court noted and

overruled the objection, and the video was played. On cross-examination,

Alvarenga elicited an admission from the officer that people could run for any

number of reasons. He did not refer to the prior bad act that undergirded his motion

in limine.

On appeal, Alvarenga essentially reprises the argument he made at the

hearing on his motion. The State responds that he failed to preserve error.

“Generally denial of a motion in limine does not preserve error for appellate

review.” State v. Thoren, 970 N.W.2d 611, 620–21 (Iowa 2022). But if the motion

“declares the evidence admissible or inadmissible, it is ordinarily a final ruling and

need not be questioned again during trial.” Id. at 621. 4

We conclude the district court made a final ruling on the motion in limine.

Although the court initially questioned how the State would admit evidence of the

arrest warrant, it ultimately decided to assume “that there was a warrant [and] that

[Alvarenga] ran.” Based on that assumption, the court unequivocally ruled the

flight evidence was admissible. See Quad City Bank & Tr. v. Jim Kircher &

Assocs., P.C., 804 N.W.2d 83, 90–91 (Iowa 2011) (“The court did not equivocate

or state it would reconsider its ruling at trial” and, “[a]ccordingly, the court’s ruling

had the effect of a definitive evidentiary ruling.”). Because the ruling left scant, if

any, room for doubt as to the admissibility of the flight evidence, Alvarenga had no

obligation to object to the evidence at trial in order to preserve error.

As for the scope of the final ruling, we are persuaded it covered the

probative value and prejudicial effect of the evidence under Iowa Rule of Evidence

5.403 as well as potential limits on the use of prior bad acts evidence under Iowa

Rule of Evidence 5.404(b). Because Alvarenga raised these arguments in the

district court, he preserved error. We proceed to the merits.

“It is well-settled law that the act of avoiding law enforcement after a crime

has been committed may constitute circumstantial evidence of consciousness of

guilt that is probative of guilt itself.” State v. Wilson, 878 N.W.2d 203, 211 (Iowa

2016) (citations omitted). At the same time, the evidence has to be treated “with

caution.” Id. at 212. “[T]he probative value of evidence showing a defendant

avoided apprehension turns on the circumstances under which the avoidance

occurred.” Id. at 213. Specifically, “[f]or any valid inference of guilt to be drawn by

the jury from flight evidence, the district court must assure itself there is some 5

evidence in the record to support the inferential chain between the defendant’s act

of avoidance and consciousness of guilt for the crime charged.” Id.

[T]he inferential chain connecting an act of flight to guilt for the crime charged can reasonably be drawn only when the timing of the act suggests the sudden onset or the sudden increase of fear in the defendant’s mind that he or she will face apprehension for, accusation of, or conviction of the crime charged.

Id. (internal quotations and citation omitted). “The immediacy requirement is

important. It is the instinctive or impulsive character of the defendant’s behavior,

like flinching, that indicates fear of apprehension and gives evidence of flight such

trustworthiness as it possesses.” Id. That said, “establishing immediacy is less

critical to establishing the probative value of flight when the evidence conclusively

establishes the defendant knew he or she was suspected of the charged crime at

the time of flight.” Id. at 214. Once a district court admits such evidence, it is for

the jury to decide whether to credit the inferential chain leading from a particular

act of the defendant to guilt for the crime charged.” Id. at 215.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Parker
747 N.W.2d 196 (Supreme Court of Iowa, 2008)
State v. Sullivan
679 N.W.2d 19 (Supreme Court of Iowa, 2004)
State v. August
589 N.W.2d 740 (Supreme Court of Iowa, 1999)
State of Iowa v. John Arthur Wilson
878 N.W.2d 203 (Supreme Court of Iowa, 2016)
Quad City Bank & Trust v. Jim Kircher & Associates, P.C.
804 N.W.2d 83 (Supreme Court of Iowa, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
State of Iowa v. Enoc Alvarenga, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-enoc-alvarenga-iowactapp-2022.