State of Iowa v. Michael Paul Eaton

CourtCourt of Appeals of Iowa
DecidedJanuary 11, 2023
Docket21-1405
StatusPublished

This text of State of Iowa v. Michael Paul Eaton (State of Iowa v. Michael Paul Eaton) 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 Paul Eaton, (iowactapp 2023).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 21-1405 Filed January 11, 2023

STATE OF IOWA, Plaintiff-Appellee,

vs.

MICHAEL PAUL EATON, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Black Hawk County, Margaret L.

Lingreen, Judge.

The defendant appeals his conviction for escape. AFFIRMED.

Martha J. Lucey, State Appellate Defender, and Theresa R. Wilson,

Assistant Appellate Defender, for appellant.

Brenna Bird, Attorney General, and Zachary Miller, Assistant Attorney

General, for appellee.

Considered by Vaitheswaran, P.J., Tabor, J., and Blane, S.J.*

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

(2023). 2

BLANE, Senior Judge.

Michael Paul Eaton appeals his conviction for escape. He contends the

district court should have given a different instruction defining arrest, and the

verdict was not supported by substantial evidence that he was under arrest for a

felony or in the custody of a public officer. Because we find the court did not err in

its arrest instruction and substantial evidence supports the conviction, we affirm.

I. FACTS AND PRIOR PROCEEDINGS.

Sheriff Deputy Chad Chase was patrolling in Waterloo when he saw a driver

in a white Charger cover his face while Chase drove by. He followed and

determined the vehicle belonged to a person whose son, Eaton, had an active

warrant for his arrest because of a probation violation on a felony conviction. He

confirmed the photograph of Eaton matched the person he saw trying to hide his

face in the Charger. Eaton’s Charger was stopped in the small parking lot of a

collectibles shop and, after circling a few times, Chase pulled in after him, blocking

the entrance with his patrol vehicle.

Chase testified he exited his vehicle as Eaton was walking toward the shop.

He said, “Michael, stop,” and Eaton changed direction and walked toward the back

of the building. Chase pulled out his taser and followed Eaton behind the building.

Eaton told Chase that he was “not Michael.” Chase said he would shoot if he did

not stop. At the point of his taser, Chase walked Eaton backed to the Charger and

had him sit in the front seat with the door open, which he “figured . . . was the safest

spot at that point.” Eaton’s girlfriend, Heather Glaspie, was in the passenger seat

of the Charger, and Chase asked for her identification. Standing so the car door

remained open, Chase testified Eaton “was detained at that point. He was not 3

going to leave.” While Chase intended to place Eaton in handcuffs, he wanted to

wait for another officer to arrive to do so safely.

Radioing with dispatch, Chase took a few steps toward the back of the car

to get the license plate number. In that short time, Eaton closed and locked the

driver door. The window was about half down, and Chase began “yelling through

the window, telling him to unlock the door, open the door.” But Eaton put the

Charger in reverse and backed out of his parking spot while Chase yelled at him

to stop. Chase stood right outside the driver’s door, pointed his taser at Eaton,

threatened to shoot him, and yelled at him to stop and turn the car off. When Eaton

did not comply, Chase shot him with the taser, which caused Eaton to “stomp on

the gas,” reversing and crashing into Chase’s patrol vehicle. The taser stopped

working after a few seconds. Eaton then put the car in drive and pulled forward

into the parking lot but had no space to exit. Chase followed and shot the taser

again but missed this time. Eaton quickly reversed, driving over the lawn to get

out of the parking lot. Chase followed, this time pointing his gun. Glaspie was

screaming from the passenger seat “don’t shoot.” Chase had to jump out of the

way as Eaton then drove off. Video of most of the event was captured on Chase’s

dashboard camera, but no audio of the incident was recorded. The next day,

officers located the Charger with a broken taillight in a garage and Eaton hiding in

Glaspie’s apartment under a pile of clothing. taser wires were found on the floor

of the Charger.

At trial, Glaspie testified both she and Eaton knew he was wanted on the

warrant. She was waiting in the Charger outside the shop and saw Chase circling

the parking lot. She called Eaton, who was inside the shop, and told him about it, 4

which is when he came out. When asked whether she believed Eaton was “free

to leave that area,” Glaspie testified, “He was obviously being under—put under

arrest for an officer to stop, and he had a warrant . . . .” Another witness from

inside the collectibles shop testified Eaton received a phone call from someone

labeled “Heather” who said, “cops have gone by a couple times, that [Eaton]

needed to get out of there.”

The jury found Eaton guilty of escape as a habitual offender,1 in violation of

Iowa Code section 719.4(1) (2020). Eaton appeals.

II. SCOPE AND STANDARD OF REVIEW.

We review challenges to jury instructions for error of law. State v.

Mathis, 971 N.W.2d 514, 519 (Iowa 2022). We review a sufficiency-of-the-

evidence challenge for the correction of legal error. State v. Lacey, 968

N.W.2d 792, 800 (Iowa 2021). “We will affirm the jury’s verdict when the verdict is

supported by substantial evidence.” Id. “Evidence is substantial when the

quantum and quality of evidence is sufficient to ‘convince a rational fact finder that

the defendant is guilty beyond a reasonable doubt.’” Id. (quoting State v.

Webb, 648 N.W.2d 72, 75–76 (Iowa 2002)). We consider “the evidence in the light

most favorable to the State, including all reasonable inferences that may be fairly

drawn from the evidence.” Id.

1 The jury also found Eaton guilty of driving while barred and the lesser-included offense of interference with official acts resulting in bodily injury but acquitted him of second-degree criminal mischief and assault on a peace officer with a dangerous weapon. 5

III. ANALYSIS.

A. Jury Instruction on “Arrest”

The conviction for escape from custody required the jury to find all of the

following elements:

1. . . . [Eaton] was arrested for a felony. 2. By reason of the arrest, [Eaton] was in the custody of a public officer. 3. [Eaton] intentionally escaped from the custody of the public officer without the permission of the public officer.

Under Iowa Code, an “[a]rrest is the taking of a person into custody when and in

the manner authorized by law, including restraint of the person or the person’s

submission to custody.” Iowa Code § 804.5. The court also gave jurors the

following instruction on arrest:

No formal announcement is required for a law enforcement encounter to constitute an arrest, as long as the person making the arrest sufficiently conveys, either through words or conduct, the intent to perform an arrest. While formal words are not required, in order for a law enforcement encounter to constitute an arrest, what a suspect is told or not told about his arrest status is a factor to be considered when determining whether an arrest has occurred. An escape involves departure from actual custody.

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State of Iowa v. Michael Paul Eaton, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-michael-paul-eaton-iowactapp-2023.