State of Iowa v. Sydney Leiann Slaughter

CourtCourt of Appeals of Iowa
DecidedAugust 9, 2023
Docket22-0892
StatusPublished

This text of State of Iowa v. Sydney Leiann Slaughter (State of Iowa v. Sydney Leiann Slaughter) 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. Sydney Leiann Slaughter, (iowactapp 2023).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 22-0892 Filed August 9, 2023

STATE OF IOWA, Plaintiff-Appellee,

vs.

SYDNEY LEIANN SLAUGHTER, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Black Hawk County, Kellyann M.

Lekar, Judge.

A defendant appeals her conviction for a making a false claim for a slot

machine jackpot. REVERSED AND REMANDED.

Martha J. Lucey, State Appellate Defender, and Vidhya K. Reddy, Assistant

Appellate Defender, for appellant.

Brenna Bird, Attorney General, and Martha E. Trout, Assistant Attorney

General, for appellee.

Considered by Bower, C.J., and Tabor and Greer, JJ. 2

TABOR, Judge.

“So who’s my lucky winner?” This question was standard for the casino

worker who approached Sydney Slaughter and Anthony McNeese after the jackpot

light flashed on their slot machine. As it turns out, that question would later be

posed to a jury as the State charged Slaughter with falsely claiming the jackpot

when McNeese made the wager. See Iowa Code § 99F.15(4)(h) (2020). The jury

found Slaughter guilty. She now alleges four errors: (1) section 99F.15(4)(h) did

not encompass her conduct; (2) the State offered insufficient proof she had the

intent to defraud; (3) the State failed to prove that she did not make a wager

contingent on winning at the slot machine; and (4) the district court allowed a

special agent for the State to testify to the meaning of “wager.”

Because the State did not present sufficient evidence of guilt, we reverse.

I. Facts and Prior Proceedings

In the early morning hours of November 29, 2020, McNeese played a slot

machine at the Isle of Capri Casino and won a $4000 jackpot.1 Slaughter, his

girlfriend, was by his side, and took his seat in front of that machine after the

“candle” on top signaled a jackpot win.2

1 Under Iowa law, when an individual wins $1200 or more in a single game, it is a

taxable event that must be documented; the jackpot winner is identified, and their personal information is collected. Iowa Code § 422.16(1)(d) (“State income tax shall be withheld on winnings in excess of twelve hundred dollars derived from slot machines authorized under chapter 99F.”); see id. § 99F.18. 2 Special Agent John Bergman with the Iowa Division of Criminal Investigation

(DCI) testified that when a single spin on a slot machine returns a jackpot “the machine freezes up and requires human intervention on the part of a casino employee.” 3

Alerted by that signal, slot machine attendant Danielle Rademaker arrived

and asked who won the jackpot. To Rademaker, Slaughter “really seemed kind of

flustered” but said she won the money. Slaughter then filled out the casino’s

paperwork with her name and Social Security number. She designated 95% of the

winnings to be withheld for federal income tax.3 Meanwhile, Rademaker requested

surveillance video of the casino floor, believing she had seen McNeese—not

Slaughter—playing the machine. Confirming Rademaker’s suspicion, the

surveillance team determined that McNeese had been sitting at the machine

before the candle flashed. Slaughter later admitted to casino supervisor Jesse

McCarvel that McNeese had hit the button on the machine. With that information,

Rademaker and McCarvel told McNeese that he had to be the one to claim the

jackpot. So he did, designating $3800 (95% of the winnings) for federal income

tax withholding.

Critical to the prosecution theory, McNeese owed $1386 to the Iowa

Department of Human Services (DHS)4 bureau of collections for child support and

$41,446 to the Linn County Clerk of Court in unpaid fines when he claimed this

jackpot. Those debts qualified as setoffs under Iowa Code section 99F.19(2).5

Casino employees are required to check an electronic database to see if jackpot

winners have such setoffs. See Iowa Code § 99F.19(1)–(2); see also id. § 8A.504.

3 The casino automatically deducts five percent from the jackpot for state taxes.

Special Agent Bergman testified: “The other 95% is up to the patron.” 4 The agency is now known as the Iowa Department of Health and Human Services 5 Iowa Code section 8A.504(1)(d)(1) defines “qualifying debt” to include “[a]ny

debt . . . which the child support recovery unit is otherwise attempting to collect.” Iowa Code section 8A.504(1)(d)(3) also lists “[a]ny debt which is in the form of a liquidated sum due, owing, and payable to the clerk of the district court.” 4

But casino service manager Akaesha Mergen testified that because McNeese

“wanted a hundred percent in taxes taken out,” the casino could not hold any

money for the setoffs.

Another critical piece to this theory was that this jackpot was not a first-time

event for Slaughter or McNeese. In fact, Slaughter won a $2,000 jackpot the

previous night. McCarville attended to that payout and handed Slaughter an “offset

letter”6 notifying her that the casino withheld $1050 that she owed to the Linn

County Clerk of Court. And as for McNeese, he won seven jackpots between July

and November that year.

The State charged Slaughter with making a false claim of winning the

jackpot under Iowa Code section 99F.15(4)(h).7 Before trial, Slaughter moved to

exclude evidence of McNeese’s setoffs. The court overruled her motion. And after

three days of trial, the jury found Slaughter guilty as charged. She now appeals.

II. Analysis

A. Applicable Gambling Statute

The State charged Slaughter under this provision:

A person commits a class “D” felony and, in addition, shall be barred for life from excursion gambling boats and gambling structures under the jurisdiction of this commission, if the person does any of the following: .... h. Claims, collects, or takes, or attempts to claim, collect, or take, money or anything of value in or from the gambling games . . . , with intent to defraud, without having made a wager contingent on winning a gambling game . . . .

6 The parties use the term “offset” interchangeably with the statutory term “setoff.” 7 Special Agent Bergman testified that he also charged McNeese with a gambling

offense. 5

Iowa Code § 99F.15(4)(h). Here, the statute defines “gambling game” as “any

game of chance authorized by the” state racing and gaming commission. Id. §

99F.1(14). The commission has authorized slot machines as a game of chance

for play in casinos. Iowa Admin. Code r. 491-11.5.

On appeal, Slaughter asserts that this language did not proscribe the

actions alleged by the State.8 She argues that paragraph (h) covers only

circumstances when a person claims to win when they have not—or claims a larger

amount than they won—intending to defraud the actual winner or the casino.9

Instead, she claims “the intent to avoid offset obligations” is covered by

paragraph (o), enacted two years after the incident at issue. See 2022 Iowa Acts

ch. 1143, § 7. She also cites paragraph (n) that the legislature added in that 2022

amendment. See id.

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State of Iowa v. Sydney Leiann Slaughter, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-sydney-leiann-slaughter-iowactapp-2023.