State of Iowa v. Garret James Wassom

CourtCourt of Appeals of Iowa
DecidedOctober 30, 2024
Docket23-1891
StatusPublished

This text of State of Iowa v. Garret James Wassom (State of Iowa v. Garret James Wassom) 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. Garret James Wassom, (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 23-1891 Filed October 30, 2024

STATE OF IOWA, Plaintiff-Appellee,

vs.

GARRET JAMES WASSOM, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Clay County, Andrew Smith, Judge.

A defendant directly appeals from three misdemeanor convictions,

challenging whether five exhibits were improperly excluded from trial. APPEAL

DISMISSED IN PART AND AFFIRMED IN PART.

Jack Bjornstad of Jack Bjornstad Law Office, Spirit Lake, for appellant.

Brenna Bird, Attorney General, and Sheryl Soich, Assistant Attorney

General, for appellee.

Considered by Schumacher, P.J., and Buller and Langholz, JJ. 2

LANGHOLZ, Judge.

After a night out celebrating his birthday, Garret Wassom beat his girlfriend.

The State charged him with three misdemeanors. Before trial, the State moved to

exclude five exhibits showing brief moments of contact between Wassom and the

victim months after the event. The district court agreed the evidence was irrelevant

and excluded the exhibits from trial. Wassom was ultimately convicted of false

imprisonment and two counts of simple assault.

Wassom directly appeals these convictions, arguing he is entitled to a new

trial because the district court erroneously excluded the five exhibits. But Wassom

has no right to directly appeal his two simple assault convictions because a

defendant convicted of simple misdemeanors under district-court procedures only

has a right to seek discretionary review. And even treating his filings here as an

application for discretionary review, Wassom received substantial justice, so we

deny discretionary review and dismiss his appeals from the simple assault

convictions for lack of jurisdiction.

As for false imprisonment, most of Wassom’s arguments are constitutional

arguments never made to the district court. So they are not preserved for our

review. And the district court did not abuse its discretion when excluding the

exhibits as irrelevant. That the victim may have briefly interacted with Wassom

two, five, or eight months after the event does not make any material fact relating

to false imprisonment more or less probable. We thus affirm Wassom’s false-

imprisonment conviction. 3

I. Factual Background and Proceedings

Late one evening in January 2023, Wassom and his girlfriend were driving

home from Wassom’s birthday celebration. Wassom became angry about a social

media post showing the girlfriend’s legs. Feeling unsafe, the girlfriend tried to pull

over and leave the car. But as she opened the door, Wassom grabbed her

sweatshirt hood and pulled her back into the car. Wassom refused to let her leave

the car—at one point restraining her with his arm around her neck in what a witness

described as a “chokehold”—until he noticed a bystander nearby. Wassom then

released her, and she left the car.

Wassom followed her out and punched the back of her head into a

snowbank. He then drove off—leaving her injured in the dark—but later returned

for her. Back in the car, Wassom drove so erratically the girlfriend was thrown into

the dashboard and windows. The girlfriend called 911, which further angered

Wassom. He then shoved his arm into her throat and began strangling and

punching her. Wassom eventually stopped and the girlfriend fled the car, leaving

her keys and phone inside. The girlfriend spotted a nearby house with its porch

light on and rang the doorbell, searching for help. The homeowner let her in and

called law enforcement.

The State charged Wassom with assault with a dangerous weapon, false

imprisonment, and assault causing bodily injury. Before trial, the State moved in

limine to exclude five exhibits, which showed communications or contact between

Wassom and the victim months after the event (and in violation of a no-contact

order). Wassom argued the exhibits were relevant because they showed the two

“remained in a relationship” and the victim was no longer scared of Wassom. The 4

court excluded the exhibits, reasoning the months-later interactions had “no

bearing on” whether Wassom assaulted or falsely imprisoned the victim in January.

After a three-day trial, the jury convicted Wassom of false imprisonment—a

serious misdemeanor—and two lesser-included offenses of assault—simple

misdemeanors. See Iowa Code §§ 708.1(2), 708.2(6), 710.7 (2023). Wassom

now directly appeals these convictions, arguing that the district court erroneously

excluded his exhibits and he is thus entitled to a new trial.

II. Discretionary Review of Simple Assault Convictions

Before we consider the merits of Wassom’s appeal, we must first assure

ourselves of jurisdiction. Wassom has no right to directly appeal his two assault

convictions because they are simple misdemeanors tried under district-court

procedures. See Iowa Code § 814.6(1)(a)(1); Tyrrell v. Iowa Dist. Ct., 413

N.W.2d 674, 675 (Iowa 1987). Rather, Wassom should have applied for

discretionary review of those convictions, stating “with particularity the grounds

upon which discretionary review should be granted.” Iowa R. App. P. 6.106(1)(e).

He did not. So to salvage his appeal, he asks that we treat his filings as if he had

sought the proper form of review. See Iowa R. App. P. 6.151. And while Wassom

does not specify any grounds for that request, we presume he seeks discretionary

review because the district court’s limine ruling deprived him of “substantial

justice.” Iowa R. App. P. 6.106(2).

We deny discretionary review of the two simple assault convictions. For

starters, Wassom chiefly relies on constitutional arguments that were never made

below. That Wassom did not receive constitutional rulings he never requested is

not a substantial injustice. And Wassom has likewise failed to show the district 5

court’s routine relevance ruling was so untenable that it warrants an exceptional

grant of discretionary review. We therefore dismiss his attempted appeal from the

two assault convictions for lack of appellate jurisdiction. Cf. State v. Patterson,

984 N.W.2d 449, 454 (Iowa 2023) (dismissing attempted appeal of restitution order

in a dismissed simple misdemeanor case after denying certiorari and discretionary

review).

III. Evidentiary Challenge to False Imprisonment Conviction

Turning to Wassom’s false-imprisonment conviction, he argues the district

court erred by excluding his exhibits and the error justifies a new trial. The exhibits

show five brief moments of contact or communications between Wassom and the

victim in March, June, and September of 2023.

Again, much of Wassom’s case on appeal turns on constitutional arguments

never made to the district court. “It is a fundamental doctrine of appellate review

that issues must ordinarily be both raised and decided by the district court before

we will decide them on appeal.” Meier v. Senecaut, 641 N.W.2d 532, 537

(Iowa 2002). Wassom argues he had no duty to raise his constitutional grievances

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Related

Meier v. SENECAUT III
641 N.W.2d 532 (Supreme Court of Iowa, 2002)
Tyrrell v. Iowa District Court
413 N.W.2d 674 (Supreme Court of Iowa, 1987)
In the Interest of K.C.
660 N.W.2d 29 (Supreme Court of Iowa, 2003)

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State of Iowa v. Garret James Wassom, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-garret-james-wassom-iowactapp-2024.