State of Iowa v. Sean Christopher Bright

CourtCourt of Appeals of Iowa
DecidedJanuary 9, 2025
Docket23-1951
StatusPublished

This text of State of Iowa v. Sean Christopher Bright (State of Iowa v. Sean Christopher Bright) 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. Sean Christopher Bright, (iowactapp 2025).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 23-1951 Filed January 9, 2025

STATE OF IOWA, Plaintiff-Appellee,

vs.

SEAN CHRISTOPHER BRIGHT, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Linn County, Elizabeth Dupuich,

Judge.

A defendant convicted for failing to appear at sentencing in a separate

criminal matter appeals the district court’s denial of his motion for new trial.

AFFIRMED.

Webb L. Wassmer of Wassmer Law Office, PLC, Marion, for appellant.

Brenna Bird, Attorney General, and David Banta, Assistant Attorney

General, for appellee.

Considered by Greer, P.J., Langholz, J., and Telleen, S.J.*

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

(2025). 2

TELLEEN, Senior Judge.

I. Background

This case begins where another was supposed to end. In 2022, Sean Bright

pled guilty to a criminal charge for possessing a firearm. Bright was released on

bond pending a sentencing hearing set for January 3, 2023, in Linn County. But

when that day arrived, he wasn’t in the courtroom. According to Bright, he was

somewhere in northern Georgia, out of gas and short on money. The State says

he was hiding. A jury found Bright guilty of failing to appear in violation of Iowa

Code section 811.2(8) (2023). Bright appeals the denial of his motion for new trial,

arguing the weight of the evidence shows his absence was involuntary.

II. Discussion

Our rules of criminal procedure permit a district court to order a new trial if

the jury’s verdict is contrary to the weight of the evidence. Iowa R. Crim.

P. 2.24(2)(b)(7) (2023). A new trial is appropriate “only in the extraordinary case

in which the evidence preponderates heavily against the verdict rendered.” State

v. Ernst, 954 N.W.2d 50, 60 (Iowa 2021). “The question for the court is not whether

there was sufficient credible evidence to support the verdict rendered or an

alternative verdict, but whether a greater amount of credible evidence suggests

the verdict rendered was a miscarriage of justice.” State v. Ary, 877 N.W.2d 686,

706 (Iowa 2016) (cleaned up). In answering that question, the district court may

weigh the evidence and consider the credibility of witnesses. Id. Our review is for

abuse of discretion. Ernst, 954 N.W.2d at 60.

A criminal defendant released pending entry of judgment may be convicted

of a new offense if the defendant “willfully fails to appear” in court as ordered. Iowa 3

Code § 811.2(8). We have interpreted a willful failure to mean “a deliberate or

intended violation, as distinguished from an accidental, inadvertent, or negligent

violation of an order.” State v. Brown, No. 01-0742, 2002 WL 22184, at *1 (Iowa

Ct. App. Jan. 9, 2002) (per curiam). Bright contends the trial evidence weighs

heavily against a finding of willfulness—primarily based on his own testimony

about a series of mishaps that left him stranded out-of-state on the day of his

sentencing. We begin with Bright’s version of events.

1. Bright’s Account

Bright testified that on December 26, 2022, he decided to take a trip to

Florida. He wanted to cross skydiving off his “bucket list.” Bright and his wife had

been saving for a getaway, and so they boarded their vehicle with $1800 cash and

left Cedar Rapids for the coast. By the 28th, they had reached Alabama. It was

there that the couple realized both of their phones were missing. According to

Bright, they hadn’t been “using [the phones] at all, but [they] did tear the truck

apart” in an unsuccessful attempt to find them.

Bright and his wife arrived in the Viero Beach area on December 31. Some

fellow skydivers at the hotel where they stayed told them about a jump site in

nearby Sebastian, Florida. The next morning—New Year’s Day—Bright took his

leap. A commemorative certificate was admitted at trial. The thrill was over by

noon, and the couple turned back toward Iowa. To Bright’s recollection, the return

trip from Florida was supposed to take about seventeen hours. He planned to be

back by the afternoon of January 2, well in advance of his January 3 sentencing.

He testified that he “fully” and “absolutely” intended to be in court. 4

Bright claims misfortune intervened. According to his testimony, the couple

stopped for gas just past the Georgia border, and they learned their money was

missing. Bright’s account as to what happened next was muddled. On direct

examination, he alleged the “first thing” he did was pawn a laptop for $50 of gas

money. When asked on cross about how he found a pawn shop open on New

Year’s Day, Bright revised his account—explaining that, after learning the money

was gone, he and his wife spent the night in a Walmart parking lot before setting

out for a pawnshop on the morning of January 2.

Bright testified that when the laptop money ran dry, he and his wife pawned

some jewelry for another three-quarters tank, which carried them as far as northern

Georgia. But at that point, the couple was “dead in the water.” They were out of

gas, and they “didn’t have really anything else to get rid of.” According to Bright,

they spent ten days stuck in place. Neither Bright nor his wife ever attempted to

alert Bright’s attorney or seek the assistance of his friends or relatives in Iowa.

Eventually, the couple was able to sell some camping gear for nearly enough

money to make it home. A handout from a gas station owner took them the last

100 miles. Bright was taken into custody forty-five minutes after returning to Cedar

Rapids.

2. The State’s Case

The State’s lead witness was Tammy O’Connor, whose company posted

the $5000 bond securing Bright’s pre-sentence release. O’Connor testified

regarding the routine reminders her office sent Bright and his wife by text message

regarding approaching court dates in Bright’s case. Bright had been “very good

about checking in.” But when O’Connor sent Bright a message on December 30 5

to confirm his upcoming sentencing, he didn’t respond. O’Connor tried to reach

Bright by phone. The parties agree that Bright called O’Connor on December 31

to confirm he was aware of his court date.

O’Connor testified that, on January 2, several of Bright’s friends and family

members informed her that he had sold his truck and left town for Florida.

O’Connor also saw a Facebook post describing the couple as missing persons.

Concerned that Bright planned to skip bail, O’Connor circulated her own post

stating she believed Bright was “on the run” and requesting information as to his

whereabouts. O’Connor’s post was shared over 900 times. On January 19, she

received a tip that Bright was back in Cedar Rapids. O’Connor located Bright the

same day and turned him over to police.

The State also introduced recordings of jail calls placed by Bright on the day

of his arrest. In one of the calls, Bright’s daughter informs him she was questioned

by federal investigators. Bright asks, “you didn’t tell them anything, did you?” In

another, Bright’s wife—who was also questioned—tells Bright that the FBI knew

about a TracFone with a Florida number that Bright used to contact family and

friends in Iowa.

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Related

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