State of Iowa v. Gustaf Roy Carlson

CourtCourt of Appeals of Iowa
DecidedDecember 18, 2024
Docket23-1467
StatusPublished

This text of State of Iowa v. Gustaf Roy Carlson (State of Iowa v. Gustaf Roy Carlson) 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. Gustaf Roy Carlson, (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 23-1467 Filed December 18, 2024

STATE OF IOWA, Plaintiff-Appellee,

vs.

GUSTAF ROY CARLSON, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Story County, Steven P. Van Marel,

Judge.

A defendant appeals his conviction and sentence for second-degree theft.

THEFT CONVICTION AND HABITUAL-OFFENDER JUDGMENT AFFIRMED;

SENTENCE VACATED; REMANDED FOR FURTHER PROCEEDINGS.

Leah Patton of Patton Legal Services, LLC, Ames, for appellant.

Brenna Bird, Attorney General, and Zachary Miller, Assistant Attorney

General, for appellee.

Considered by Buller, P.J., Sandy, J., and Gamble, S.J.*

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

(2024). 2

GAMBLE, Senior Judge.

A jury convicted Gustaf Roy Carlson for second-degree theft for possessing

a stolen truck. Carson was on parole at the time of his offense. Carson stipulated

he had two prior felony convictions as a habitual offender. The court sentenced

Carson as a habitual offender and ran his sentence consecutive to his parole

revocation. Carson appeals his conviction and sentence.

Carlson argues the district court erred in (1) denying his motion for judgment

of acquittal when the State had presented insufficient evidence to convict him,

(2) allowing the prosecutor to burden shift by questioning him on his failure to

produce a bill of sale and later commenting on that failure during closing, (3) failing

to comply with habitual-offender stipulation requirements such that his stipulation

to his prior convictions was not knowing and voluntary, (4) failing to provide any

reason supporting its consecutive sentence order, and (5) refusing to set a hearing

on Carlson’s challenge to restitution. We affirm both Carlson’s conviction and the

district court’s judgment on his habitual-offender enhancement, but we vacate his

sentence and remand to the district court for proceedings consistent with this

opinion.

I. Background Facts and Proceedings

In March 2023, Carlson was stopped by Ames Police Officer Steven Spoon

while driving a 2007 Dodge Dakota in Ames. Officer Spoon stopped Carlson

because the truck did not match the vehicle to which the license plates were

registered. When Officer Spoon informed Carlson that the plates did not match,

Carlson said “he’d just bought the truck.” Carlson did not have the title or a bill of 3

sale on hand and has not produced those documents since the date of the initial

stop.

Officer Spoon then walked around to the front of the car to record the VIN

from the vehicle’s windshield. Some papers were wedged in the windshield and

blocked the place where the VIN should have been located. After Carlson

removed those papers, it became apparent that the VIN had been removed.

Officer Spoon confirmed that “the entire [VIN] plate, including the rivets, were

missing.” Carlson stated the VIN had also been removed from the door jams—he

suggested the previous owner had removed them. The vehicle was also missing

the stereo. The truck’s registered owner testified that when she went to pick up

the truck from impound “[t]he dash inside had been, like, popped off, and the stereo

had been taken out, and there was wires exposed.” She also testified that the

stereo had been intact and undamaged before the vehicle was stolen.

Carlson had the other passengers in the vehicle take some bags of items in

the truck before Officer Spoon detained Carlson. Carlson was released from

detainment and then later arrested on a warrant outside of his residence. The

truck was stolen in January, and the registered owner testified that the truck

Carlson was driving belonged to her.

Carlson was charged with second-degree theft as a habitual offender. At

trial, Officer Spoon testified that mismatched plates are consistent with a vehicle

having been stolen. The State asked Officer Spoon if Carlson had ever produced

the purchase paperwork and Carlson’s attorney objected, arguing that the State

was burden shifting: 4

Q. And as far as the title, you mentioned that there would have signatures on the title? A. Yes. Q. Was Mr. Carlson able to produce any of that documentation to you? A. No. Q. What did he tell you or did he provide any sort of excuse about that? A. He told me that it was at home. Q. But you specifically asked him for this paperwork; correct? A. Yes. Q. To this day, we’re in June now, end of June, and this traffic stop was— [CARLSON’S ATTORNEY]: Objection, Your Honor. COURT: Pardon me? [CARLSON’S ATTORNEY]: Objection, Your Honor. It’s shifting the burden. COURT: Objection’s overruled. BY [THE PROSECUTOR]: Q. To this day, have you been provided by any party any title or bill of sale relating to the sale of that vehicle? A. No.

In closing and rebuttal, the State again addressed Carlson’s failure to produce

documentation:

The bill of sale or title was never produced. [Carlson] said, I have a bill of sale. I have a title. I have the paperwork from purchasing this vehicle. The officer testified he had an opportunity to retrieve that paperwork when he was released from jail and no such bill of sale or title has ever been produced. Why? You can infer from that fact that there is no bill of sale or title. .... Now, defense asked a question, how can he get the paperwork when he’s in jail? Okay. So let’s—let’s assume this is true, that he has no idea that he’s going to be charged with theft. He gets out of jail, he goes home, and then they come and arrest him for the theft of the vehicle and they say, you’re under arrest for stealing that vehicle. At that point he doesn’t say woah, woah, woah, wait, wait, what if I show you the title? Let me get the title. It’s in the back. I’m at the house now. I’m just in the alley behind [my] house. The title’s inside. Let me go grab it. Doesn’t do that. And while he’s in the jail communicating with his defense attorney talking about how he’s going to defend this case, whether he’s going to testify or not, he doesn’t say, can you just go home, grab the title? That would really clear things up if we just showed the prosecution the title. That doesn’t happen. No title was presented in the case from either party, no title was presented to the officer who investigated this case because the title doesn’t exist. Because the bill of sale doesn’t exist. If it did, you would have seen it. 5

After closing, Carlson moved for a mistrial based on the State’s alleged burden

shifting during trial and closing. The district court denied that motion and the jury

convicted Carlson as charged. Carlson admitted having two prior felony

convictions which removed any need for trial on his habitual-offender status.

Before accepting that admission, the court informed Carlson of the following:

All right. So Mr. Carlson, you do have a right to have a jury trial on those prior convictions, and it’d be just like the trial we’ve had today on the theft charge where the State would have to prove that you have those two prior convictions. And you have an absolute right to have the jury do that, or if you want to you may go ahead and admit that you have those two prior convictions, and we’ll just proceed from there.

In its order entering the guilty verdict, the district court advised Carlson of the

requirement to move in arrest of judgment to preserve appeals relating to his plea.

At sentencing, Carlson argued his theft and parole-revocation sentences

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State of Iowa v. Gustaf Roy Carlson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-gustaf-roy-carlson-iowactapp-2024.