State of Iowa v. Miguel Tojin Chivalan

CourtCourt of Appeals of Iowa
DecidedApril 28, 2021
Docket20-0356
StatusPublished

This text of State of Iowa v. Miguel Tojin Chivalan (State of Iowa v. Miguel Tojin Chivalan) 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. Miguel Tojin Chivalan, (iowactapp 2021).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 20-0356 Filed April 28, 2021

STATE OF IOWA, Plaintiff-Appellee,

vs.

MIGUEL TOJIN CHIVALAN, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Wapello County, Kirk A. Daily,

District Associate Judge.

Miguel Chivalan appeals his convictions for interference with official acts

and disarming a peace officer of a dangerous weapon. AFFIRMED.

Dan Vondra of Vondra Law, PLC, North Liberty, and John A. Hathaway of

Malott Law, PLC, Iowa City, for appellant.

Thomas J. Miller, Attorney General, and Martha E. Trout, Assistant Attorney

General, for appellee.

Considered by May, P.J., and Greer and Schumacher, JJ. 2

MAY, Presiding Judge.

Miguel Chivalan appeals his convictions for interference with official acts, in

violation of Iowa Code section 719.1(1)(b) (2018), and disarming a peace officer

of a dangerous weapon, in violation of section 708.13. He claims the district court

erred in instructing the jury. He also claims there was insufficient evidence. We

affirm.

I. Background Facts and Proceedings1

On September 21, 2018, reserve Wapello County Sheriff’s Deputies Jeffrey

Klodt and Mark Smoot encountered a Chevrolet Captiva traveling in the opposite

direction. The driver, later determined to be Chivalan, took a wide turn and almost

hit the deputies’ vehicle. Deputy Smoot had to come to a complete stop in order

to avoid a head-on collision. Deputies Klodt and Smoot attempted to turn around

to initiate a traffic stop of Chivalan’s vehicle. But Chivalan was traveling at a high

rate of speed, and his vehicle was no longer in sight.

A few minutes later, the deputies again found Chivalan’s vehicle driving

erratically. Chivalan nearly hit another vehicle in a convenience store parking lot.

As Chivalan was leaving the parking lot, he pulled out in front of the deputies and

another vehicle. Both vehicles had to stop in order to avoid hitting Chivalan’s

vehicle. The deputies turned on their overhead red and blue lights and pursued

Chivalan’s vehicle.

1We review the evidence in the light most favorable to the verdict. See State v. Warren, 955 N.W.2d 848, 856 (Iowa 2021). 3

Chivalan did not pull over. The speed limit in the area was thirty miles-per-

hour. Dash camera footage from the chase shows the deputies’ vehicle traveling

over fifty miles-per-hour while pursuing Chivalan. The deputies did not catch up

to Chivalan’s vehicle. Due to department policy, the deputies were told not to

pursue Chivalan’s vehicle any further. They slowed down but continued in the

direction of Chivalan’s vehicle.

Soon after, Ottumwa Police Officer Jordan Staton arrived at the address

listed for Chivalan’s vehicle. Officer Staton observed Chivalan’s vehicle come off

the roadway and pull into the driveway. Officer Staton activated his overhead red

and blue lights. Chivalan’s vehicle then entered the garage. The garage door

began to close. Officer Staton parked his patrol car in the driveway, exited his

vehicle, and used his hand to stop the garage door from closing.

Three times Officer Staton told Chivalan to exit his vehicle. When Chivalan

finally exited the vehicle, he refused Officer Staton’s command to leave the garage

and stand in front of Officer Staton’s patrol car. Officer Staton then grabbed

Chivalan in an attempt to pull him out of the garage. Chivalan pulled away from

Officer Staton, ran to the back of the garage, and ran into the house. Officer Staton

followed Chivalan into the house.

Chivalan began yelling for another individual within the house. Officer

Staton deployed his taser twice, but Chivalan got back up both times. After the

second time, Chivalan pulled the taser cartridge from Officer Staton’s hands. This

made the taser unusable. Officer Staton and Chivalan physically struggled for a

short time. Officer Staton was able to push Chivalan away. Officer Staton then 4

drew his firearm. Chivalan ran upstairs, farther into the house. At that point, other

officers arrived to assist Officer Staton. They found Chivalan in an upstairs

bedroom. After more resistance, Chivalan was placed in handcuffs.

The State charged Chivalan with interference with official acts causing

bodily injury, in violation of section 719.1(1)(e); disarming a peace officer of a

dangerous weapon, in violation of section 708.13; and eluding, in violation of

section 321.279(2). A jury convicted Chivalan of interference with official acts,

disarming a peace officer of a dangerous weapon, and eluding. Chivalan appeals.

II. Jury Instructions

We begin with Chivalan’s challenge to the jury instructions. Our review is

for “correction of errors at law.” Alcala v. Marriott Int’l, Inc., 880 N.W.2d 699, 707

(Iowa 2016) (noting we “review refusals to give a requested jury instruction for

correction of errors at law”).

Chivalan’s challenge focuses on his convictions for disarming a police

officer under section 708.13 and interference with official acts under section 719.1.

Both statutes protect “a peace officer” when she or he is “in the performance of

any act which is within the scope of the lawful duty or authority of that officer.”

Chivalan complains that the jury instructions “merely recited” this element from the

statutes.2 In Chivalan’s view, “the district court needed to further define this phrase

2 This requirement appeared in jury instruction 17, the marshalling instruction for disarming a peace officer. It did not appear in jury instruction 24, the marshalling instruction for interference with official acts, which only required the State to prove (1) “Chivalan knew Jordan Staton was a peace officer who was attempting to arrest him”; (2) Chivalan “knowingly resisted or obstructed Jordan Staton in arresting him”; and (3) Chivalan’s actions “resulted in a bodily injury to Jordan Stanton [sic].” But this difference does not alter our analysis or ultimate conclusion. 5

and clarify that the officer needed to have a warrant, consent, or probable cause

and exigent circumstances in order to lawfully enter [his] home and arrest him and

thus be acting within the scope of the officer’s lawful authority.” In other words,

Chivalan contends both statutes required the State to prove beyond a reasonable

doubt that the officer’s entry of the house was consistent with the requirements of

“[t]he Fourth Amendment of the U.S. Constitution.”3 Chivalan contends the district

court erred by refusing his proposed instructions, which included language

addressing those requirements.4

We disagree. It is true the district court must “give a requested jury

instruction if it correctly states the applicable law” governing a question the jury

must decide “and is not embodied in other instructions.” Id. at 707 (citation

omitted). It is also true that, even when instructions “repeat[] what the statute

says,” they can still be inadequate if failure to define a statutory term results in an

3 Chivalan also refers to the state law counterpart, “article one, section eight of the Iowa Constitution.” But Chivalan does not suggest a separate state law standard. So, for ease of reference, we refer to both provisions collectively as the Fourth Amendment.

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Related

State v. Polly
657 N.W.2d 462 (Supreme Court of Iowa, 2003)
State v. Thomas
262 N.W.2d 607 (Supreme Court of Iowa, 1978)
State v. McFarland
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State v. Legg
633 N.W.2d 763 (Supreme Court of Iowa, 2001)
State v. Cook
330 N.W.2d 306 (Supreme Court of Iowa, 1983)
State of Iowa v. John Robert Hoyman
863 N.W.2d 1 (Supreme Court of Iowa, 2015)
State of Iowa v. Dontay Dakwon Sanford
814 N.W.2d 611 (Supreme Court of Iowa, 2012)
State of Iowa v. Jeffrey Alan Soboroff
798 N.W.2d 1 (Supreme Court of Iowa, 2011)

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State of Iowa v. Miguel Tojin Chivalan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-miguel-tojin-chivalan-iowactapp-2021.