State of Iowa v. James Edwin Brown

• Court: Court of Appeals of Iowa
• Decided: September 4, 2025
• Docket: 24-1431
• Status: Published

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 24-1431 Filed September 4, 2025

STATE OF IOWA, Plaintiff-Appellee,

vs.

JAMES EDWIN BROWN, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Scott County, Tom Reidel (motion to

dismiss) and Jeffrey C. McDaniel (sentencing), Judges.

A criminal defendant appeals the district court’s order denying his motion to

dismiss. AFFIRMED.

Daniel M. Northfield, Urbandale, for appellant.

Brenna Bird, Attorney General, and Louis S. Sloven, Assistant Attorney

General, for appellee.

Considered without oral argument by Schumacher, P.J., and Buller and

Sandy, JJ. 2

SANDY, Judge.

The State has a duty to provide a defendant with a speedy trial, but that

duty “does not require that [the State] play a game of hide-and-go-seek with him.”

State v. Brandt, 253 N.W.2d 253, 259 (Iowa 1977) (citation omitted).

James Edwin Brown appeals the district court’s order denying his motion

to dismiss. Brown contends that the State violated his right to speedy trial, and

that there was no good cause to delay his trial date past the one-year speedy

trial deadline. He argues the district court abused its discretion by denying his

motion to dismiss and granting the State’s motion to continue trial one month

beyond the speedy trial deadline.

We conclude the district court properly found good cause to delay Brown’s

trial. The district court did not abuse its discretion in denying Brown’s motion to

dismiss. We affirm.

I. Background Facts and Proceedings

On May 2, 2023, Brown was arrested, and a month later indicted by trial

information, with a class “B” felony under Iowa Code section 124.401(1)(b)(7)

(2023), and two class “D” felonies under Iowa Code sections 706.3 and 453B.12.

Brown was arraigned on June 8, which began his one-year speedy trial clock under

Iowa Rule of Criminal Procedure 2.33(2)(c). Brown did not waive his ninety-day

speedy trial right under Iowa Rule of Criminal Procedure 2.33(2)(b), so the district

court set a pretrial conference for July 7. The district court’s order notified Brown

that he needed to attend the pretrial conference. Brown posted bond the next day.

Brown subsequently failed to appear at the July 7 pretrial conference, prompting

the district court to issue a bench warrant for his arrest. The clerk of court mailed 3

Brown a notice of order for bond forfeiture, but the letter was returned as

undeliverable. Between June and August, the State amended Brown’s trial

information to add two co-defendants.

On March 11, 2024, Brown was arrested by the Davenport Police

Department, eight months after he had failed to appear. On March 15, Brown

waived his ninety-day speedy trial right, and the Court set a trial date for May 20.

On March 25, the State filed a motion to continue and re-set Brown’s trial date to

coincide with his co-defendants.1 Brown’s counsel did not file a resistance to the

motion to continue, and on April 14, the district court granted the State’s motion.2

The court re-set the trial for July 8. Brown filed a motion to dismiss on June 18,

alleging that the July 8 trial date violated his right to speedy trial under

rule 2.33(2)(c).

This appeal followed.

II. Standard of Review

We review district court rulings on “motion[s] to dismiss based on speedy-

trial grounds for an abuse of discretion. However, that discretion is a narrow one,

as it relates to circumstances that provide good cause for delay of the trial.” State

v. McNeal, 897 N.W.2d 697, 704 (Iowa 2017) (citation omitted). The burden is on

the State to show good cause for delay. Brandt, 253 N.W.2d at 255 (citation

omitted).

1 Neither Brown nor any of his co-defendants filed a motion to sever. 2 We are aware there is some ambiguity and debate about whether Brown resisted

setting the trial date outside the one-year deadline, given his failure to file a resistance as directed by the court. 4

III. Analysis

Brown asserts that there was no good cause to delay his trial past the one-

year speedy trial deadline. Under Iowa Rule of Criminal Procedure 2.33(2)(c), “[a]ll

criminal cases must be brought to trial within one year after the defendant’s initial

arraignment pursuant to rule 2.8 unless an extension is granted by the court, upon

a showing of good cause.”

Trial may proceed outside of the one-year speedy trial deadline “if the State

proves (1) the defendant waived speedy trial, (2) the delay was attributable to the

defendant, or (3) good cause existed for the delay.” State v. Jentz, 853

N.W.2d 257, 269 (Iowa Ct. App. 2013). We inquire into whether the events that

delayed the progress of the case were attributable to the defendant or other good

cause for delay as a matter of practical necessity. Id. at 270. A defendant’s own

actions may constitute good cause for delay. State v. Orte, 541 N.W.2d 895, 898

(Iowa Ct. App. 1995).

Brown argues that the district court’s desire to try him with his co-defendants

is not good cause for delay past the one-year speedy trial deadline. Brown further

argues his counsel’s failure to resist the State’s motion to continue his trial past the

one-year speedy trial date is not good cause for delay. We disagree.

Brown asks us to ignore the poignant reality that he absconded and evaded

law enforcement for over eight months while his speedy trial clock was ticking. In

Jentz, we held that there was good cause to delay the one-year speedy trial

deadline after a defendant fled the state, incurred additional charges in Florida,

and was held in Florida for prosecution as his trial date passed in Iowa. 853 5

N.W.2d at 271. A defendant will not be rewarded with a dismissal of his case

because his own actions prohibited his ability to attend his own proceedings.

Similarly to Jentz, delay in Brown’s trial date can be attributed to his own

actions. A finding of good cause generally depends on the strength of “only one

factor: the reason for the delay.” See McNeal, 897 N.W.2d at 704 (citation

omitted). The logic of Jentz applies to the present case. Brown absconded and

evaded law enforcement for over eight months, a period equal to about two-thirds

of his speedy trial window. If a defendant absconds and evades arrest past their

speedy trial deadline, or to the eve of his trial date, should they be rewarded with

a dismissal of their charges? We think not. By absconding and evading law

enforcement, Brown gave the district court good cause to delay his trial one month

beyond the speedy trial deadline. The State has a duty to provide a defendant

with a speedy trial, but that duty “does not require that [the State] play a game of

hide-and-go-seek with him.” Brandt, 253 N.W.2d at 259 (citation omitted).

Moreover, the degree of the delay is an important consideration. Id. Here,

the delay is relatively minimal. The district court delayed Brown’s trial by one

month past his one-year speedy trial deadline to conserve judicial resources.

Given the surrounding circumstances of Brown’s eight-month sojourn, the State

carried its burden and the district court properly found good cause for the delay of

one month. Further, the one-month delay did not prejudice Brown.

IV. Conclusion

The district court properly found good cause for delay, and the court did not

abuse its discretion in denying Brown’s motion to dismiss. We, therefore, affirm.

AFFIRMED.