State of Iowa v. Robert Leroy Peterson Jr.

CourtCourt of Appeals of Iowa
DecidedJanuary 10, 2024
Docket22-1157
StatusPublished

This text of State of Iowa v. Robert Leroy Peterson Jr. (State of Iowa v. Robert Leroy Peterson 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. Robert Leroy Peterson Jr., (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 22-1157 Filed January 10, 2024

STATE OF IOWA, Plaintiff-Appellee,

vs.

ROBERT LEROY PETERSON JR., Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Linn County, Justin Lightfoot, Judge.

Robert Peterson appeals from his conviction and sentence for arson in the

second degree. AFFIRMED.

Martha J. Lucey, State Appellate Defender, and Ashley Stewart, Assistant

Appellate Defender, for appellant.

Brenna Bird, Attorney General, and Thomas J. Ogden, Assistant Attorney

General, for appellee.

Considered by Tabor, P.J., Badding, J., and Vogel, S.J.*

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

(2024). 2

VOGEL, Senior Judge.

Robert Peterson appeals from his conviction and sentence for arson in the

second degree. He argues the district court improperly admitted opinion testimony

and bad-acts evidence and the court abused its discretion in sentencing him to a

ten-year term of incarceration. We find the court acted within its discretion in

admitting all challenged evidence and imposing the sentence, and we affirm.

I. Background Facts and Proceedings

As of October 17, 2020, Peterson and his wife, Ronnee O’Brien, lived

together in a house in Cedar Rapids. According to O’Brien’s testimony, she

returned home from work shortly after midnight on this date. Their “marriage was

in trouble” at this point due to Peterson’s alcohol use, so she typically slept in an

upstairs bedroom while Peterson slept in the basement. Peterson was waiting for

her when she entered the house, and he was “belligerently drunk” and often

unintelligible. “[A]fter listening to him berate” her for some time and briefly laying

down on the downstairs bed, she fled the home to spend the night at her adult

son’s home.

Exterior security video shows O’Brien leaving her home shortly after 1:30

that morning, followed by Peterson leaving the home around 2:50 a.m. At 2:56

a.m., the video first shows smoke pushing out of the base of the home, which

grows into a fire and dies out around 5:40 a.m. The video shows Peterson

returning to the damaged home around 6:10 a.m. O’Brien testified the home was

so heavily damaged in the fire that it had to be demolished and she was unable to

recover any of her personal property. 3

Peterson was charged with arson in the second degree. He proceeded to

a five-day trial in March and April 2022, after which the jury found him guilty as

charged. The court sentenced him to a term of incarceration not to exceed ten

years. He now appeals.

II. Standard of Review

We generally review evidentiary rulings for an abuse of discretion. State v.

Tyler, 867 N.W.2d 136, 152 (Iowa 2015). We also review a sentence for abuse of

discretion when the sentence is within the bounds of the constitution and the Iowa

Code. State v. Headley, 926 N.W.2d 545, 549 (Iowa 2019).

III. Analysis

To convict Peterson of arson in the second degree, the marshalling

instruction required the State to prove he caused a fire in or near certain property

on or around October 17, 2020, and he “acted with the specific intent to destroy or

damage such property” or “acted with the knowledge that such property would

probably be destroyed or damaged.” See Iowa Code §§ 712.1, .3 (2020) (defining

arson and arson in the second degree). Peterson’s primary trial strategy was to

argue the State failed to prove he started the fire with the required intent,

emphasizing during closing the State’s witnesses could not conclusively identify

the cause of the fire. On appeal, Peterson raises three evidentiary arguments and

appeals his sentence, which we address in turn.

A. Fire Investigator Opinion

One of the witnesses at trial was Captain Paul Koenig, an investigator with

the Cedar Rapids Fire Department. Peterson filed a motion in limine seeking to

prevent Captain Koenig from testifying about the credibility of Peterson or any 4

witness or offering an “opinion that is not sufficiently based upon scientific,

technical, or other specified knowledge, but rather relies upon statements from

[Peterson] and other witnesses.” In response, the court ruled that Captain Koenig

was allowed to testify the house fire was caused by an act of a person, but he

could not testify the fire was intentionally set, as opposed to accidentally set, or

that Peterson had started the fire. However, the court added that it “did not have

the benefit of any proffer testimony from Captain Koenig regarding the basis for

his conclusion that the fire was intentional.” During the trial, the State again

requested Captain Koenig be allowed to testify the fire was intentionally set, or

“incendiary.” The court affirmed its limine order that Captain Koenig “cannot say

that this was an intentionally set fire.” The court and the attorneys then had the

following exchange to clarify the order:

THE COURT: . . . . I think he can say that this was caused, in his opinion, by an act by a person. And that as I said earlier, mattresses don’t naturally start on fire and, therefore, there had to have been some act by a person, whether that person intentionally wanted to set the mattress on fire or was smoking in a bed and the cigarette fell. I don’t see anything in the expertise portion of his reports or his testimony that indicates how he can rule out one or the other, other than just that he didn’t find things like a lighter maybe or cigarettes or something like that. And then certainly, [prosecutor], I think you can argue based on all of those facts that this clearly was an intentional fire. So I don’t know that I’m saying he can’t use the word incendiary. Part of the definition of incendiary is that there’s fire where there shouldn’t be, and I think he can testify to that. But there has to be the caveat that he is not testifying as to what [Peterson’s] objective intent was. And so that’s probably something that [the prosecutor] would need to have him explain in his testimony or certainly [defense counsel] would have him explain. Any questions about the Court’s ruling, [prosecutor]? PROSECUTOR: Can say incendiary, can define it, but then I can ask the follow-up question, but you’re not testifying to his objective intent or you’re not testifying to what [Peterson’s] intent was 5

at the time that this fire got lit. Am I saying that correctly or am I missing something? THE COURT: I’m saying he can’t—I’m not saying he can’t say the word incendiary, but I don’t believe he can rule out, yes. I don’t believe he can rule out accidental causes and say that [Peterson] had a subjective intent to start the fire. PROSECUTOR: If in defining incendiary, he defines it without implying that that intentional act belonged to [Peterson], he can still define what an incendiary is versus what an accidental is? THE COURT: I think he can define all four of the categories. PROSECUTOR: Okay. And then just here’s what I looked at when I was doing my investigation— THE COURT: Right. PROSECUTOR: —only more fancy.

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

Related

Schrier v. State
347 N.W.2d 657 (Supreme Court of Iowa, 1984)
State v. Plaster
424 N.W.2d 226 (Supreme Court of Iowa, 1988)
State v. Formaro
638 N.W.2d 720 (Supreme Court of Iowa, 2002)
State v. Sullivan
679 N.W.2d 19 (Supreme Court of Iowa, 2004)
Soo Line Railroad v. Iowa Department of Transportation
521 N.W.2d 685 (Supreme Court of Iowa, 1994)
State v. Taylor
689 N.W.2d 116 (Supreme Court of Iowa, 2004)
State of Iowa v. Ricky Lee Putman
848 N.W.2d 1 (Supreme Court of Iowa, 2014)
State of Iowa v. Hillary Lee Tyler
867 N.W.2d 136 (Supreme Court of Iowa, 2015)
State Of Iowa Vs. Calvin Clarence Nelson, Jr.
791 N.W.2d 414 (Supreme Court of Iowa, 2010)
State of Iowa v. Evan Paul Headley
926 N.W.2d 545 (Supreme Court of Iowa, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
State of Iowa v. Robert Leroy Peterson Jr., Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-robert-leroy-peterson-jr-iowactapp-2024.