State of Iowa v. Jason Michael Pirie

CourtCourt of Appeals of Iowa
DecidedAugust 21, 2024
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 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. Jason Michael Pirie, (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 23-0434 Filed August 21, 2024

STATE OF IOWA, Plaintiff-Appellee,

vs.

JASON MICHAEL PIRIE, Defendant-Appellant. ________________________________________________________________

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

Judge.

The defendant challenges his conviction and sentence for third-degree

theft. AFFIRMED.

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

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

General, for appellee.

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

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

(2024). 2

PER CURIAM.

Jason Pirie challenges his conviction and sentence for third-degree theft,

an aggravated misdemeanor. He argues (1) the judge should have granted his

motion to recuse based on the judge’s prior representation of Pirie in two criminal

matters and a recent statement made by the judge that raised a question regarding

his impartiality; (2) the district court erred in allowing hearsay testimony from a

police officer during the criminal trial; (3) the district court should have granted his

motion for new trial based on the unavailability of a material witness; (4) the district

court violated his rights by conducting a remote sentencing proceeding without first

obtaining his waiver of the right to in-person sentencing; and (5) the district court

abused its discretion by sentencing him to a consecutive prison term for the crime

of stealing $55 worth of alcohol.

I. Background Facts and Proceedings.

Pirie was charged by trial information with third-degree theft for taking

property not exceeding $750 while having two prior theft convictions. See Iowa

Code § 714.2(3) (2022). It was alleged that Pirie stole a bottle of Patrón tequila

that retailed for $54.99 (before tax) from a local grocery store. Pirie pled not guilty,

and the case was set for a jury trial to begin on January 24, 2023.

Six days before trial was scheduled to start, Pirie filed a motion asking the

judge to recuse himself. The district court heard the motion the same day. Pirie

testified, stating that the judge represented him in criminal matters in 2016 and

2005—before being appointed to the bench. Pirie was asked why he believed that

impacted the judge’s ability to be impartial; he responded: “Just a comment that

[the judge] made to [Pirie’s attorney] a year ago when I pled guilty to this case, to 3

this charge I’m on probation on right now.” Pirie was told the judge said it was a

“good thing [he] took the deal because [the judge] knows [him] and it wasn’t going

to be good.” The judge orally denied the motion from the bench, noting the motion

was filed “essentially on the eve” of trial. The judge continued:

I don’t think I have a conflict. 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 [a]ttorney . . . 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.

Pirie’s case was tried to a jury on January 24, 2023.

The State presented evidence that a local grocery store called the police

after realizing there was a bottle of silver Patrón tequila that went missing without

being paid for on August 3, 2022. A manager from the grocery store reviewed

videos from security cameras in and around the store before ultimately turning over

copies of the footage to the police. Multiple videos and still images from the

footage were admitted at trial and shown to the jury. The videos showed a person

alleged to be Pirie in the liquor section of the store carrying an item with bright

green packaging—which the manager testified was consistent with that of the

missing tequila—before putting it down on a shelf, manipulating the packaging,

and then briefly walking away. When Pirie returned a few seconds later, he made

a grab for the shelf and then seemed to place something under his shirt. The

manager testified that he tracked Pirie on the various cameras around the store

and that Pirie exited the store without ever going through a check out. While a still

image showed Pirie exiting the store by himself without anything in his hands, a 4

video of Pirie in the parking lot showed him holding an item in his right hand.

Eventually, Pirie and two other men—Jason and Cody—left the parking lot in a red

car. During cross-examination, Pirie’s attorney pointed out that Cody did make

purchases and leave with a shopping bag, and the grocery store employee was

unable to tell the jury what Cody purchased.

Officer Nick Johnson testified that, on August 4, he came across Pirie,

Cody, and Jason after responding to the grocery store’s call. One of the two men

was wearing the same shirt as the day before, and they appeared to be driving the

same red car as was seen on the grocery store surveillance cameras. During

Officer Johnson’s testimony, the prosecutor asked if the two men with Pirie

provided Officer Johnson “with different versions of events.” Pirie objected,

arguing the question called for inadmissible hearsay. Then the following exchange

took place between the prosecutor and Officer Johnson:

Q. So you interviewed [Cody and Jason]; is that right? A. Yes, ma’am. Q. And they—and you asked them about their presence the day before; is that right? A. Yes, ma’am. Q. Did they provide you with consistent versions of events? A. Yes, ma’am. Q. Did you then interview the [d]efendant? A. Yes, ma’am. Q. Did the [d]efendant tell you where he was the day before? A. No, ma’am. Q. Did he deny being at [the grocery store] the day before? A. Yes, ma’am. Q. Was his statement consistent or inconsistent with the version of events provided to you by [the other two men]? A. Inconsistent.

Pirie then lodged another objection, arguing that the prosecutor was “trying to use

that as a way to show an inconsistency with [Pirie] in this particular matter by

saying that this is testimony that they gave and that is a true statement.” Defense 5

counsel continued, “I don’t have the opportunity to cross examine either of these

two witnesses here today and that would become a hearsay.” The district court

again overruled the objection.

The jury found Pirie guilty of theft, and he stipulated to prior two theft

convictions.1

Pirie filed a motion for new trial, asserting that a material witness who could

not be located and subpoenaed before trial was now available.

The district court held the combined hearing on the motion for new trial and

sentencing remotely. The court also conducted a probation revocation hearing.2

The court indicated it was doing so because the judge tested positive for COVID-

19. Pirie testified at the hearing that he wanted Jason to testify on his behalf at

trial, stating he was a “key witness that was supposed to be there.” According to

Pirie, the State subpoenaed Jason, and Pirie found him the night before trial and

“attempted to try to get him to attend” trial. Noting Pirie did not subpoena Jason

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Related

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State v. Williams
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State v. Judkins
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State v. Smith
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State v. Millsap
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State v. Thomas
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State v. Newman
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State v. Formaro
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Tindell v. State
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State v. Tobin
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State v. Steltzer
288 N.W.2d 557 (Supreme Court of Iowa, 1980)
State v. Cooley
587 N.W.2d 752 (Supreme Court of Iowa, 1998)
State v. Sailer
587 N.W.2d 756 (Supreme Court of Iowa, 1998)
United States v. Mitchell
377 F. Supp. 1312 (District of Columbia, 1974)
In Re Buss' Estate
26 N.W.2d 700 (South Dakota Supreme Court, 1947)

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State of Iowa v. Jason Michael Pirie, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-jason-michael-pirie-iowactapp-2024.