State of Iowa v. Michael Craig Glynn

CourtCourt of Appeals of Iowa
DecidedSeptember 18, 2024
Docket23-1646
StatusPublished

This text of State of Iowa v. Michael Craig Glynn (State of Iowa v. Michael Craig Glynn) 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. Michael Craig Glynn, (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 23-1646 Filed September 18, 2024

STATE OF IOWA, Plaintiff-Appellee,

vs.

MICHAEL CRAIG GLYNN, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Boone County, John R. Flynn,

Judge.

Michael Glynn appeals his convictions for first-degree arson, possession of

ammunition by a prohibited person, and third-degree burglary. AFFIRMED.

Katherine R.J. Scott of New Point Law Firm, PLC, Ames, for appellant.

Brenna Bird, Attorney General, and Genevieve Reinkoester, Assistant

Attorney General, for appellee.

Considered by Schumacher, P.J., and Buller and Langholz, JJ. 2

SCHUMACHER, Presiding Judge.

Michael Glynn appeals his convictions for first-degree arson, possession of

ammunition by a prohibited person, and third-degree burglary. He challenges the

district court’s denial of his motion to change venue and the sufficiency of the

evidence supporting his convictions. Upon our review, we affirm.

I. Background Facts and Prior Proceedings

In 2013, P.M. met Michael Glynn. Their relationship became romantic, and

within two years Glynn moved into P.M.’s home. The couple married in 2020, but

by January 2023, the relationship had soured. P.M. asked Glynn to move out early

that year, and she filed for divorce shortly thereafter.

Glynn did not respond well to the dissolution proceedings. He threatened

self-harm after P.M. asked him to move out. Despite her requests that Glynn stay

away, Glynn showed up twice at P.M.’s home and physically assaulted her.

Glynn’s conduct became so concerning, P.M.’s adult son stayed with her as often

as he could. P.M. eventually obtained a temporary no-contact order against Glynn,

but the string of text messages sent to P.M. in the days after the order was granted

showed a disregard for the court order.

The relationship’s collapse led to the events of May 1, 2023. Early that

afternoon, a neighbor who was aware of the no-contact order saw Glynn walking

up P.M.’s driveway toward the house. P.M. was not home at the time. The

neighbor called P.M.’s son, who in turn called law enforcement. Officers

responded to the property soon after. As they approached the home, they

observed Glynn inside the residence. The officers backed up and established a

perimeter. 3

Officers made phone contact with Glynn, but he refused to leave the home.

He threatened to blow up the house, said he intended to die alone in the home

because of the home’s significance to P.M., and began breaking windows.

Roughly an hour after officers first arrived on the scene, a burning box that officers

believed contained shotgun ammunition was tossed out a window of the home.

Within minutes, officers observed smoke billowing from the home. Officers

apprehended Glynn as he ran from P.M.’s burning home.

Although firefighters managed to put out the blaze, the damage to the home

was extensive, and P.M.’s garage partially collapsed. And after the wind fanned

the fire to a neighbor’s property, the neighbor’s garage burned and was a total loss.

The physical evidence that remained was too damaged for the fire marshal to

determine the cause of the fire.

The State charged Glynn in Boone County—where P.M.’s home was

located. Glynn moved to change venue two weeks before the start of trial, claiming

an impartial jury could not be seated in Boone County because of pretrial publicity

and prejudice. The district court denied the motion and a jury trial commenced in

July 2023. Following trial, the jury returned verdicts, finding Glynn guilty of the

charges below relevant to this appeal: first-degree arson, possession of

ammunition by a prohibited person, and third-degree burglary. Glynn appeals.

II. Change of Venue

Glynn asserts the district court improperly denied his motion to change

venue. The State claims that either Glynn failed to preserve error—contending the

district court’s pre-trial order regarding venue change was not a final order—or, in

the alternative, Glynn waived his objection to venue. 4

A. Error Preservation

Preserving an issue for appeal ordinarily requires the issue to have been

first raised to and ruled on by the district court. Lamasters v. State, 821 N.W.2d

856, 862 (Iowa 2012).

The error-preservation dispute concerns whether the district court ruled on

the motion to change venue. The State argues that there was no final ruling on

the motion, highlighting the district court order’s language of being willing to revisit

the decision after voir dire. The State’s position asks us to treat the venue-change

ruling the same as a conditional ruling on a motion in limine.1 Under that view, if a

district court ruling that denies venue change acknowledges that jury selection may

expose information persuading the court to conclude differently, error preservation

would require a renewed motion after voir dire.

In opposition to the State’s position, Glynn argues State v. Robinson, 389

N.W.2d 401 (Iowa 1986) holds that a defendant need not renew a motion to change

venue after voir dire if an initial motion was made and ruled on, even when the

court is willing to reconsider should future developments raise doubts over the

trial’s fairness. See Robinson, 389 N.W.2d at 402–03 (noting the district court, in

its initial venue change ruling, stated it would re-examine its decision should voir

dire raise concerns over the ability to provide a fair trial in that venue).

1 Claims of error on evidentiary rulings are not preserved when there has been

only a conditional ruling on a motion in limine. See Quad City Bank & Tr. v. Jim Kircher & Assocs., 804 N.W.2d 83, 91–92 (Iowa 2011) (finding no preserved error when the appellant failed to “offer the testimony contained in the offer of proof,” thus depriving the trial court the ability to make a ruling on admissibility). 5

In the alternative, the State cites two unreported cases by this court as the

foundation for the State’s argument that Glynn waived the objection by not

renewing it. Neither case is sufficiently analogous to the facts before this court to

persuade us to extract a rule applicable here, so we assume without deciding that

Glynn preserved error on this issue and turn to the merits of Glynn’s claim.

B. Abuse of Discretion

Glynn argues the pretrial publicity following his arrest was so pervasive and

inflammatory that the district court was obligated to presume the existence of

prejudice in any jury selected from Boone County. Glynn offered a handful of local

media articles to support his claim.

We apply de novo review to a district court’s denial of a motion to change

venue and will reverse only upon finding an abuse of discretion. State v. Siemer,

454 N.W.2d 857, 860 (Iowa 1990).

The existence and pervasiveness of pretrial publicity alone is insufficient to

compel a court to grant a motion for venue change. State v. Morgan, 559 N.W.2d

603, 611 (Iowa 1997). A defendant must show either actual or presumptive

prejudice arising therefrom. Id. Entitlement to a venue change based on a

presumptive prejudice claim requires the defendant prove “that the publicity

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Walker
600 N.W.2d 606 (Supreme Court of Iowa, 1999)
State v. Evans
671 N.W.2d 720 (Supreme Court of Iowa, 2003)
State v. Caldwell
385 N.W.2d 553 (Supreme Court of Iowa, 1986)
State v. Harris
436 N.W.2d 364 (Supreme Court of Iowa, 1989)
State v. Keopasaeuth
645 N.W.2d 637 (Supreme Court of Iowa, 2002)
State v. Robinson
389 N.W.2d 401 (Supreme Court of Iowa, 1986)
State v. Nitcher
720 N.W.2d 547 (Supreme Court of Iowa, 2006)
State v. Veverka
271 N.W.2d 744 (Supreme Court of Iowa, 1978)
State v. Wilkens
346 N.W.2d 16 (Supreme Court of Iowa, 1984)
State v. Morgan
559 N.W.2d 603 (Supreme Court of Iowa, 1997)
State v. Siemer
454 N.W.2d 857 (Supreme Court of Iowa, 1990)
State v. Wilson
406 N.W.2d 442 (Supreme Court of Iowa, 1987)
State v. Spargo
364 N.W.2d 203 (Supreme Court of Iowa, 1985)
State of Iowa v. Tremayne Latoine Thomas
847 N.W.2d 438 (Supreme Court of Iowa, 2014)
State of Iowa v. Robert Lynn Vaughan
859 N.W.2d 492 (Supreme Court of Iowa, 2015)
State of Iowa v. Mario Guerrero Cordero
861 N.W.2d 253 (Supreme Court of Iowa, 2015)
State v. Ferguson
6 N.W.2d 856 (Supreme Court of Iowa, 1942)
Lynn G. Lamasters Vs. State of Iowa
821 N.W.2d 856 (Supreme Court of Iowa, 2012)
State of Iowa v. Dontay Dakwon Sanford
814 N.W.2d 611 (Supreme Court of Iowa, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
State of Iowa v. Michael Craig Glynn, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-michael-craig-glynn-iowactapp-2024.