State of Iowa v. Jason Michael Pirie

CourtSupreme Court of Iowa
DecidedMarch 7, 2025
Docket23-0434
StatusPublished

This text of State of Iowa v. Jason Michael Pirie (State of Iowa v. Jason Michael Pirie) is published on Counsel Stack Legal Research, covering Supreme Court 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. Jason Michael Pirie, (iowa 2025).

Opinion

In the Iowa Supreme Court

No. 23–0434

Submitted January 21, 2025—Filed March 7, 2025

State of Iowa,

Appellee,

vs.

Jason Michael Pirie,

Appellant.

On review from the Iowa Court of Appeals.

Appeal from the Iowa District Court for Greene County, Joseph McCarville,

judge.

A defendant seeks further review of the court of appeals decision affirming

his conviction and sentence for third-degree theft. Decision of Court of Appeals

and District Court Judgment Affirmed.

Christensen, C.J., delivered the opinion of the court, in which all justices

joined.

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

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

General, for appellee. 2

Christensen, Chief Justice.

A jury convicted the defendant of third-degree theft after a store’s video

footage captured the defendant placing a bottle of liquor under his shirt and

leaving the store without paying for it. On appeal, he raises multiple challenges

to his conviction and sentence. These include challenges to the district court’s

denial of his motion to recuse and motion for new trial. The defendant also

maintains that the district court erred by admitting hearsay in the form of a

police officer’s testimony that the defendant’s two friends provided a consistent

version of events that differed from what the defendant told him about the day

of the reported theft. Finally, the defendant challenges both the sentence

imposed and the district court’s choice to conduct the sentencing hearing

remotely because the judge tested positive for COVID-19. The court of appeals

rejected the defendant’s arguments and affirmed his conviction and sentence.

On further review, we agree.

The defendant presented no evidence that the judge’s previous

representation of him years before this case provided the judge with any

extrajudicial information resulting in bias or prejudice. And while the officer’s

testimony about the friends’ version of events was indirect hearsay, it was not

prejudicial to the defendant because it was cumulative. Plus, there was already

overwhelming evidence of the defendant’s guilt. Additionally, the district court

properly denied the defendant’s motion for new trial based on the alleged

unavailability of a witness to testify because he failed to raise it until after the

jury returned its verdict. Similarly, the defendant waited to object to the remote

nature of his sentencing until appeal, thereby failing to preserve error on this

claim. Finally, the district court did not abuse its discretion by sentencing the 3

defendant to consecutive prison sentences for his theft charge and a probation

violation.

I. Background Facts and Proceedings.

On August 3, 2022, a Hy-Vee manager in Jefferson noticed that a bottle of

silver Patrón tequila had disappeared without being paid for, prompting him to

review the store’s security camera video footage. The footage revealed an

individual who police later identified as Jason Pirie manipulating the packaging

on a bottle in the store’s alcohol section before seemingly placing it under his

shirt and leaving the store. Pirie never went through the checkout line, and

additional footage shows him walking to his car in the parking lot with an

unidentifiable item in his hand. The bottle was not accounted for by any

purchase in the store’s records, and staff discovered discarded Patrón packaging

consistent with the packaging for the bottle that went missing.

Officer Nick Johnson responded to the store’s call and reviewed the

footage. The next day, he encountered Pirie with two friends in the parking lot of

a different store. The same friends had arrived at Hy-Vee with Pirie but split up

while they were inside the store. One of the two friends was wearing the same

shirt as the one he was pictured in at Hy-Vee, and the group was using the same

car that was pictured on the store’s surveillance camera. Recognizing Pirie as

the man who appeared to take the Patrón on the video footage despite Pirie’s

denial of being at Hy-Vee the day before, Officer Johnson sought an arrest

warrant. The State charged Pirie with third-degree theft, an aggravated

misdemeanor, for taking property not exceeding $750 while having two prior

theft convictions. See Iowa Code § 714.2(3) (2022).

Six days before Pirie’s trial was set to begin, he filed a motion to recuse the

district court judge. In a hearing on the motion that same day, Pirie testified that 4

the judge had represented him in criminal matters in 2005 and 2016 before

becoming a judge. When Pirie’s attorney asked why he thought the judge would

treat Pirie unfairly, Pirie stated, “Just a comment that he made to [my attorney]

a year ago when I pled guilty to . . . this charge I’m on probation [for] right now.”

Pirie clarified that the judge had indicated it was a “[g]ood thing I took the deal

because [the judge] knows me and it wasn’t going to be good,” and Pirie worried

that the judge would “find me guilty no matter what.”

The district court denied the motion, noting that Pirie filed the motion

essentially on the eve of the January 24, 2023 trial despite that judge’s

involvement in the case since October 5, 2022. It also explained,

I’m not denying I said something along the lines of it’s a good thing he took the deal. I don’t think that shows bias. I think it shows that apparently he got a good deal. And it also -- I don’t recall the specifics, but it may also show that the defense attorney . . . did a good job for Mr. Pirie because in my view of the case, possibly I would have granted him a harsher sentence not because of any prior representation, but because of the facts of that particular case. . . . The trial next week is to a jury. I think the only possible bias or prejudice that could be present in that situation would be -- would come up at sentencing.

At trial, the jury heard testimony from the Hy-Vee manager who reviewed

the store’s camera footage and reported the theft to the police. The jury also

observed multiple videos and still images from this footage. Additionally, Officer

Johnson testified about his response to the reported theft, including his

encounter with Pirie and his friends the day after the theft.

During Officer Johnson’s testimony, the prosecutor asked him whether

Pirie’s friends provided him “with different versions of events.” Pirie objected,

arguing that anything the two friends told Officer Johnson was inadmissible

hearsay. The district court overruled the objection, reasoning, “The only reason 5

the question is being asked is to see if they were consistent with each other,

regardless of the truth. So for those reasons it’s not hearsay.”

The prosecutor subsequently asked Officer Johnson whether the two men

“provide[d] you with consistent versions of events.” This led to the following

exchange between the prosecutor and Officer Johnson:

[Prosecutor:] Did you then interview the Defendant?

[Officer Johnson:] Yes, ma’am.

[Prosecutor:] Did the Defendant tell you where he was the day before?

[Officer Johnson:] No, ma’am.

[Prosecutor:] Did he deny being at Hy-Vee the day before?

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