State of Iowa v. Joseph Wayne Hanson Jr.

CourtCourt of Appeals of Iowa
DecidedJune 19, 2024
Docket23-0286
StatusPublished

This text of State of Iowa v. Joseph Wayne Hanson Jr. (State of Iowa v. Joseph Wayne Hanson Jr.) 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. Joseph Wayne Hanson Jr., (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 23-0286 Filed June 19, 2024

STATE OF IOWA, Plaintiff-Appellee,

vs.

JOSEPH WAYNE HANSON JR., Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Lee (South) County, Wyatt Peterson,

Judge.

Joseph Hanson Jr. appeals the denial of his motion to continue.

REVERSED AND REMANDED FOR NEW TRIAL.

R.E. Breckenridge of Breckenridge Law P.C., Ottumwa, for appellant.

Brenna Bird, Attorney General, and Katherine Wenman, Assistant Attorney

General, for appellee.

Considered by Tabor, P.J., Ahlers, J., and Danilson, S.J.*

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

(2024). 2

DANILSON, Senior Judge.

Joseph Hanson Jr. appeals his convictions for possession of a controlled

substance (methamphetamine) with the intent to deliver, possession of a firearm

by a felon, possession of a controlled substance (marijuana) with the intent to

deliver, and two counts of failure to affix a drug tax stamp. Hanson argues that the

district court abused its discretion when it denied his motion to continue trial. We

agree with Hanson and remand for a new trial.

I. Background Facts & Prior Proceedings

Hanson worked as a confidential informant for the local law enforcement’s

narcotics task force. On April 22, 2022, an officer pulled Hanson over and

discovered drugs, drug paraphernalia, and a firearm in Hanson’s vehicle. The

State filed a trial information charging Hanson with possession with intent to deliver

methamphetamine, possession of a firearm by a felon, possession with intent to

deliver marijuana, two counts of tax stamp violation, and possession of a controlled

substance (diazepam).1 On April 28, defense counsel filed an appearance.

On May 31, Hanson pled not guilty and demanded a speedy trial. Six days

later, Hanson filed a “motion to dismiss counsel” requesting a different attorney.

On June 17, the public defender’s office, which was representing Hanson,

internally reassigned the case to public defender, Curtis Dial. However, attorney

Dial was out of the country until July 10. Following a July 11 pretrial conference,

the district court set trial for July 26.

1 The State later dismissed the charge for possession of a controlled substance

(diazepam). 3

Hanson and his trial counsel were first able to communicate about the case

on July 15. The day before trial was to begin, July 25, Hanson filed a motion to

continue. In the motion, Hanson explained that due to the reassignment of his

case that he had only met with his current counsel three times, he needed time to

subpoena a cellular provider to obtain text messages with the narcotics task force,

and that he was willing to waive his speedy trial rights. The trial judge refused to

hear the motion on July 25 because the motion was not on the schedule for the

day, so the motion was heard just prior to the start of the trial the next morning.

Defense counsel explained that he and Hanson had only been able to work

on Hanson’s defense for eleven days. Hanson needed the text messages with the

narcotics task force to mount his defense, they had been unable to obtain them

without a subpoena, and the charges were quite serious. Counsel also stressed

that Hanson was willing to waive his speedy trial rights and the unusual delays in

this case were not Hanson’s fault.

The court denied the motion noting the speedy trial demand previously filed,

the fact that Dial was assigned the case on June 17, and that the jurors were

already arriving at the courthouse. Hanson complained that his counsel was

unaware that he was working as a confidential informant and was not well versed

in the unique facts of his case. Hansen also reminded the court that Dial had been

unavailable because he was out of town and stated, “there is no way I can have a

fair trial.” Attorney Dial was asked by the court how long the trial would last, and

Dial stated he did not know, explaining “[w]e were provided a witness—or an

exhibit list this morning. I haven’t been shown those documents or those exhibits 4

yet. Nothing has been uploaded to review, so I need time to look at all those

possible exhibits. I think there were quite a few.”

Hanson then requested to represent himself because he believed counsel

could not represent him without knowing the facts of the case and his unique

defense. During the court’s colloquy regarding Hanson’s ability and intention to

represent himself, Hanson explained that he suffers from ADHD but was not taking

his prescribed medication because the jail considered it a controlled substance

and would not permit him to take it. The court ultimately granted Hanson’s request

to represent himself and appointed Dial as standby counsel for him.

The case proceeded to a jury trial, and the jury found Hanson guilty on all

counts. He now appeals, challenging the district court’s denial of his motion to

continue.

II. Standard of Review

We review the denial of a motion to continue for an abuse of discretion.

State v. Miller, 480 N.W.2d 894, 895 (Iowa 1992). “A . . . ruling on a motion for

continuance ‘will not be interfered with on appeal unless it clearly appears that the

trial court has abused its discretion, and an injustice has resulted therefrom.’”

State v. Grimme, 338 N.W.2d 142, 144 (Iowa 1983) (citation omitted).

III. Discussion

Iowa Rule of Criminal Procedure 2.9(2), as effective at the time of trial,

provided that “[t]he date assigned for trial shall be considered firm. Motions for

continuance are discouraged. A motion for continuance shall not be granted 5

except upon a showing of good and compelling cause.”2 Hanson poses the critical

question, “What is ‘good and compelling cause?’” We can inform him that the facts

and circumstances of this particular case did in fact amount to good and compelling

cause and the district court abused its discretion when denying the motion to

This motion to continue arose following unique events, none of which were

the fault of Hanson. The public defender’s office internally reassigned his case to

a new attorney, Dial, but that attorney was out of the country. As a result, Dial did

not have enough time or opportunity to familiarize himself with the facts of this case

including Hanson’s unusual defense that he was actually working within his role as

a confidential informant at the time he was stopped. Moreover, Hanson and his

counsel needed additional time to issue subpoenas to gather evidence from the

cell phone he used to communicate about his confidential-informant work.

Attorney Dial was also only provided the State’s witness and exhibit list the morning

of the trial and had not yet examined the exhibits.

Our supreme court has long held that requiring defense counsel to proceed

to trial where defense counsel has inadequate time to prepare for trial defeats

justice and is an abuse of discretion. State v. French, 35 N.W.2d 1,14 (Iowa 1948)

(noting two days was not sufficient time). Further, our supreme court has

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Related

Orcutt v. State
173 N.W.2d 66 (Supreme Court of Iowa, 1969)
State v. Miller
480 N.W.2d 894 (Supreme Court of Iowa, 1992)
State v. Grimme
338 N.W.2d 142 (Supreme Court of Iowa, 1983)
State v. French
35 N.W.2d 1 (Supreme Court of Iowa, 1948)

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