State of Iowa v. Samuel Gurisho Kabo

CourtCourt of Appeals of Iowa
DecidedOctober 30, 2024
Docket23-1780
StatusPublished

This text of State of Iowa v. Samuel Gurisho Kabo (State of Iowa v. Samuel Gurisho Kabo) 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. Samuel Gurisho Kabo, (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 23-1780 Filed October 30, 2024

STATE OF IOWA, Plaintiff-Appellee,

vs.

SAMUEL GURISHO KABO, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Jasper County, William A. Price,

Judge.

Samuel Gurisho Kabo appeals from his conviction for eluding. AFFIRMED.

John C. Heinicke of Kragnes & Associates, P.C., Des Moines, for appellant.

Brenna Bird, Attorney General, and Louis S. Sloven, Assistant Attorney

General, for appellee.

Considered by Tabor, C.J., and Chicchelly and Sandy, JJ. 2

CHICCHELLY, Judge.

Samuel Gurisho Kabo appeals his conviction after a jury found him guilty of

eluding. Because the court did not err in its jury instructions ruling and substantial

evidence supports Kabo’s conviction, we affirm.

I. Background Facts and Proceedings.

On August 28, 2022, Sergeant Tracy Cox of the Jasper County Sheriff’s

Office observed a vehicle driving eighty-six miles per hour in a

sixty-five-mile-per-hour zone. Cox followed the speeding driver in a marked law

enforcement vehicle and initiated his emergency lights. When the vehicle did not

stop, Cox also initiated his sirens and asked dispatch for assistance. Deputies

from Marshall County Sheriff's Office joined the chase, also in marked law

enforcement vehicles and with their emergency lights on. The vehicle eventually

did stop twice. Both times, several officers from both Jasper and Marshall

Counties exited their vehicles, drew their firearms, and commanded the driver to

exit the vehicle in accordance with their training. Both times, the driver took off.

After several miles, Cox performed a successful PIT maneuver.1 Again,

several officers exited their vehicles, drew their firearms, and made verbal

commands to the driver to exit the vehicle and get on the ground. Notwithstanding

being held at gunpoint, the driver did not respond to the officers’ instructions.

Instead, he walked around to the rear of his vehicle to check for damage. A

1 We have previously described a PIT maneuver or “Precision Intervention Technique” as “a driving technique used by police officers that is designed to halt a fleeing motorist by hitting his or her car at a specific point to throw the car into a spin and brings it to a stop.” State v. Shears, No. 16-1665, 2017 WL 6034626, at *3 n.2 (Iowa Ct. App. Dec. 6, 2017) (Tabor, J., dissenting). 3

Marshall County deputy deployed a taser on the driver, and the officers arrested

him.

The State charged the driver, who was later identified as Kabo, with

eluding–willful failure to stop for law enforcement. At trial, the State presented

video evidence of the chase and corroborating testimony from Cox. Kabo testified

in his own defense through an interpreter.2 He stated that while the video “depicted

what occurred that evening,” he did not understand what was happening. He

maintained he was not speeding and did not know police were following him

despite the close proximity. He further claimed that when he pulled over both

times, the officers commanded him to go.

Before the case was submitted to the jury, Kabo proposed a substitute

willfulness instruction, which the district court denied. The jury found Kabo guilty

of eluding. He appeals.

II. Jury Instructions.

Kabo challenges the jury instructions, arguing his preferred “willfulness”

instruction should have been given to prevent prejudice. “We generally review a

district court’s refusal to give a requested jury instruction for errors at law.” State

v. Davis, 975 N.W.2d 1, 8 (Iowa 2022) (citation omitted). To support his position,

Kabo generally argues the disputed instruction was prejudicial because it is not a

uniform instruction approved by the Iowa State Bar Association Uniform Jury

Instruction committee and was “too far removed” from the accompanying

2 Kabo is a refugee from Ethiopia and speaks no English. 4

general-intent instruction.3 He also claims the court erred by relying on

unpublished authorities in its ruling.

First, Kabo concedes that the trial court is not required to use uniform jury

instructions. See id. at 9–10 (not requiring courts to abide by a particular “model

or form in formulating instructions” (citation omitted)). Therefore, his claim that the

instructions were required to expressly include specific uniform language is

incorrect. And his claim that we must then presume prejudice lacks supporting

authority.4 But even if we did find a presumption of prejudice, this can be overcome

by the overwhelming evidence against Kabo, which we address as part of the

sufficiency of the evidence. See State v. Kraai, 969 N.W.2d 487, 497 (Iowa 2022)

(overcoming a presumption of prejudice “when the jury received ‘strong evidence’

of a defendant’s guilt” (citation omitted)).

Second, Kabo argues that the jury instructions were somehow improper

because they were “too far removed.” Specifically, he questions the jury’s ability

to read Instruction No. 13 regarding general intent, move onto the marshalling

instruction at No. 14, and then apply the general intent instruction to the definition

of “willfulness” in No. 15. But “we presume juries follow instructions.” State v.

3 He also contends that because the court did not include specific language, the

court effectively “direct[ed] a verdict for the State on the question of willfulness.” But he does not expand on this argument. See Iowa R. App. P. 6.903(2)(a)(8)(3) (waiving issues inadequately argued on appeal). Further, the case he cites in support of this proposition, State v. Gordon, is inapposite. See 560 N.W.2d 4, 6 (Iowa 1997) (analyzing definitions of “bodily injury” in the Model Penal Code). 4 Kabo actually does cite an authority for this assertion, but it does not exist. The

case name does not match its given citation, and in any case, he provides limited analysis. See Iowa R. App. P. 6.904(2)(a) (requiring parties to cite cases using “a Bluebook-type citation”), 6.903(2)(a)(8)(3) (waiving issues that fail to cite supporting authority). 5

Hanes, 790 N.W.2d 545, 552 (Iowa 2010). Further, “[w]e consider the jury

instructions as a whole rather than in isolation to determine whether they correctly

state the law.” Davis, 975 N.W.2d at 8 (citation omitted). “Read together, the jurors

were informed that to convict [Kabo], they were required to find he was consciously

aware of the officer’s signals to stop and that his failure to stop was voluntary, and

not by mistake or accident.”5 State v. Tubbs, No. 10-0758, 2011 WL 768756, at *3

(Iowa Ct. App. Mar. 7, 2011). These instructions were neither conflicting nor

confusing to the jury. Compare id. (finding the above instructions “sufficient”

because they adequately instruct on general intent), with State v. Benson,

919 N.W.2d 237, 245 (Iowa 2018) (including conflicting intent instructions

“render[s] the instructions confusing and misleading”).

Finally, Kabo relies on our appellate rules to argue that the court erred

because it relied on an unpublished decision. See Iowa R. App. P. 6.904(2)(a)(2)

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Related

State v. Williams
695 N.W.2d 23 (Supreme Court of Iowa, 2005)
State v. Gordon
560 N.W.2d 4 (Supreme Court of Iowa, 1997)
State Of Iowa Vs. Robert L. Hanes
790 N.W.2d 545 (Supreme Court of Iowa, 2010)
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. Samuel Gurisho Kabo, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-samuel-gurisho-kabo-iowactapp-2024.