State of Iowa v. Nikolas A. Stephens

CourtCourt of Appeals of Iowa
DecidedJune 5, 2019
Docket18-1149
StatusPublished

This text of State of Iowa v. Nikolas A. Stephens (State of Iowa v. Nikolas A. Stephens) 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. Nikolas A. Stephens, (iowactapp 2019).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 18-1149 Filed June 5, 2019

STATE OF IOWA, Plaintiff-Appellee,

vs.

NIKOLAS A. STEPHENS, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Hardin County, Kurt J. Stoebe,

Judge.

Nikolas Stephens appeals his conviction of leaving the scene of an accident

resulting in death. AFFIRMED.

David R. Johnson of Brinton, Bordwell & Johnson, Clarion, for appellant.

Thomas J. Miller, Attorney General, and Louis S. Sloven, Assistant Attorney

General, for appellee.

Considered by Vogel, C.J., Bower, J., and Scott, S.J.*

*Senior judge assigned by order pursuant to Iowa Code section 602.9206 (2019). 2

SCOTT, Senior Judge.

A jury found Nikolas Stephens guilty of leaving the scene of an accident

resulting in death stemming from an incident in which Stephens collided with a

pedestrian on a dark highway in the late-evening hours of September 12, 2015,

while traveling in the neighborhood of sixty miles per hour. Stephens appeals his

conviction, contending: (1) the court abused its discretion in excluding evidence

the pedestrian victim was impaired by drugs or alcohol at the time of the collision,

(2) the court erred in declining to provide instructions to the jury concerning the

victim’s negligence, and (3) the court abused its discretion in admitting the content

of a text message as evidence because it was irrelevant and prejudicial.1 We

consider his arguments in turn.

I. Victim Impairment

Prior to trial, the State filed a motion in limine requesting any evidence

concerning the alleged use of alcohol or drugs on the part of the victim on the

evening in question to be excluded as irrelevant. Stephens filed a resistance,

arguing the victim’s intoxication “made it more likely that Stephens did not see him”

1 In relation to his final argument, Stephens alleges the State engaged in prosecutorial error by violating the court’s pretrial limine ruling that prohibited the State from eliciting opinion testimony from law enforcement witnesses that Stephens was trying to avoid them. Stephens acknowledges the claim of prosecutorial error was not preserved for our review, and he appears to concede his counsel’s failure to object was a “strategy decision,” thus negating any potential claim of ineffective assistance of counsel. He nevertheless requests that we conclude on the merits that the State committed prosecutorial error and take that circumstance into consideration in assessing his claim concerning the alleged improperly admitted text message. We decline his request to consider the merits of an unpreserved issue on appeal. If he so wishes, Stephens may raise his claim as a claim of ineffective assistance of counsel in a postconviction-relief proceeding. See Iowa Code § 822.2(1)(a) (2015); see also State v. Fountain, 786 N.W.2d 260, 263 (Iowa 2010) (“Ineffective-assistance-of-counsel claims are an exception to the traditional error- preservation rules.”). 3

because the victim may have been stumbling or otherwise ambulating in an

intoxicated fashion on the roadway. The court heard the motion the morning of

trial. The State generally argued the victim’s impairment had no bearing on

whether Stephens committed the elementary acts of the crime. Stephens argued

“the sobriety or intoxication of the pedestrian makes” it more probable that he

“literally walked right in front of a moving vehicle.” The court granted the State’s

motion in limine. Stephens made two offers of proof during trial relative to evidence

concerning the victim’s intoxication, but the court declined to modify its ruling.

Following the jury’s guilty verdict, Stephens raised the issue in a motion for a new

trial, arguing evidence of the victim’s intoxication was relevant and exclusion of the

same violated his right to a fair trial. The court overruled the motion.

Stephens echoes his relevancy claims on appeal. We review district court

rulings on relevance of evidence for an abuse of discretion, our most deferential

standard of review. State v. Tipton, 897 N.W.2d 653, 691 (Iowa 2017); see State

v. Roby, 897 N.W.2d 127, 137 (Iowa 2017). An abuse of discretion occurs when

the court exercises its discretion on grounds or for reasons clearly untenable or to

an extent clearly unreasonable. Tipton, 897 N.W.2d at 691. Relevant evidence is

generally admissible. Iowa R. Evid. 5.402. Evidence is relevant if (1) “[i]t has any

tendency to make a fact more or less probable than it would be without the

evidence” and (2) “[t]he fact is of consequence in determining the action.” Iowa R.

Evid. 5.401.

The jury was instructed the State was required to prove as an element of

the crime that Stephens, at the time of the accident, “knew the accident resulted in

injury or death to another person” or “knew the accident was of such a nature that 4

a reasonable person would anticipate that injury or death had occurred to another

person.” Stephens essentially argues the alleged fact that the victim was impaired

was relevant to whether Stephens saw him and knew or had reason to know he hit

a person. However, as the State points out, Stephens “is unable to explain how

[the victim’s] level of intoxication could have made him easier [or] harder to

recognize as a human.” The video footage of the collision shows the victim to be

walking upright in the roadway in the seconds before the collision. Upon the

evidence presented at trial, we see no relevance of the victim’s intoxication on the

issue of whether Stephens knew or had reason to anticipate the accident resulted

in death or injury to another. We therefore affirm the district court on this point.

In any event, rulings excluding evidence only require reversal “if the error

affects a substantial right of the party.” Iowa R. Evid. 5.103(a).

To determine whether a substantial right of a party has been affected when a nonconstitutional error occurs, we employ harmless error analysis and ask: “Does it sufficiently appear that the rights of the complaining party have been injuriously affected by the error or that he has suffered a miscarriage of justice?”

State v. Paredes, 775 N.W.2d 554, 571 (Iowa 2009) (quoting State v. Sullivan, 679

N.W.2d 19, 29 (Iowa 2004)). Upon our review of the evidence presented, we

answer that question in the negative. The State presented an abundance of

evidence from which a rational jury could easily conclude Stephens knew or had

reason to anticipate the accident resulted in death or injury to another.

II. Jury Instructions

Next, Stephens argues the court erred in declining to provide instructions to

the jury concerning the victim’s alleged negligence. Appellate review of the district

court’s refusal to give requested jury instructions is for legal error. State v. Benson, 5

919 N.W.2d 237, 242 (Iowa 2018). At trial, Stephens requested the court to

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Related

State v. Stallings
541 N.W.2d 855 (Supreme Court of Iowa, 1995)
State v. McCall
754 N.W.2d 868 (Court of Appeals of Iowa, 2008)
State v. Fountain
786 N.W.2d 260 (Supreme Court of Iowa, 2010)
State v. Schuler
774 N.W.2d 294 (Supreme Court of Iowa, 2009)
State v. Newell
710 N.W.2d 6 (Supreme Court of Iowa, 2006)
State v. Bennett
503 N.W.2d 42 (Court of Appeals of Iowa, 1993)
State v. Martinez
679 N.W.2d 620 (Supreme Court of Iowa, 2004)
State v. Sullivan
679 N.W.2d 19 (Supreme Court of Iowa, 2004)
Young v. Gregg
480 N.W.2d 75 (Supreme Court of Iowa, 1992)
State v. Paredes
775 N.W.2d 554 (Supreme Court of Iowa, 2009)
State of Iowa v. John Robert Hoyman
863 N.W.2d 1 (Supreme Court of Iowa, 2015)
State of Iowa v. Christopher Ryan Lee Roby
897 N.W.2d 127 (Supreme Court of Iowa, 2017)
State of Iowa v. Eddie Tipton
897 N.W.2d 653 (Supreme Court of Iowa, 2017)
State of Iowa v. Kelvin Plain Sr.
898 N.W.2d 801 (Supreme Court of Iowa, 2017)
State of Iowa v. Owen F. Benson
919 N.W.2d 237 (Supreme Court of Iowa, 2018)

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State of Iowa v. Nikolas A. Stephens, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-nikolas-a-stephens-iowactapp-2019.