State of Iowa v. Trequan Cosgrove

CourtCourt of Appeals of Iowa
DecidedNovember 30, 2020
Docket19-1236
StatusPublished

This text of State of Iowa v. Trequan Cosgrove (State of Iowa v. Trequan Cosgrove) 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. Trequan Cosgrove, (iowactapp 2020).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 19-1236 Filed November 30, 2020

STATE OF IOWA, Plaintiff-Appellee,

vs.

TREQUAN COSGROVE, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Louisa County, Mark E. Kruse,

Judge.

Trequan Cosgrove appeals the district court order denying his motion to

dismiss the criminal charges against him on speedy trial grounds. AFFIRMED.

Curtis Dial of Law Office of Curtis Dial, Keokuk, for appellant.

Thomas J. Miller, Attorney General, and Timothy M. Hau, Assistant Attorney

General, for appellee.

Considered by Bower, C.J., and May and Ahlers, JJ. 2

AHLERS, Judge.

In this appeal, we are asked to decide whether a defendant’s speedy trial

rights were violated when the defendant successfully requested a mistrial during

his first trial and actively participated in setting a date for the second trial. Finding

no violation of the defendant’s speedy trial rights, we affirm.

I. Background

Trequan Cosgrove was charged with a number of crimes following an

incident in which Cosgrove stabbed two people with a knife. Cosgrove waived his

right to a speedy trial, and the case proceeded to a jury trial. During trial, one of

the State’s witnesses mentioned a DNA report that had been received by the State

but had not been turned over to Cosgrove. Cosgrove moved for a mistrial based

on this previously undisclosed evidence. He also moved to continue the trial

sufficiently far into the future so as to allow him time to have independent DNA

testing conducted, asserting such testing could be beneficial to his defense. In his

motion to continue, Cosgrove stated the independent testing “should take about

90 days.” A hearing on the motions was held. On November 7, 2018, the district

court granted Cosgrove’s motions, declaring a mistrial and rescheduling trial for

April 23, 2019.

Cosgrove filed a motion to dismiss the case on April 9, 2019, two weeks

before trial, arguing he had not waived his speedy trial rights under Iowa Rule of

Criminal Procedure 2.33.1 The court determined defense counsel had agreed to

1 We question whether the applicable rule of criminal procedure is rule 2.33, as cited by Cosgrove and the district court, or rule 2.19(6)(a). Rule 2.19(6)(a) states: The court may discharge a jury because of any accident or calamity requiring it, or by consent of all parties, or when on an amendment a 3

the new trial date set following the mistrial, and denied Cosgrove’s motion.

Cosgrove was found guilty following the second trial, and this appeal followed.

II. Standard of Review

“We review a district court’s ruling on a motion to dismiss on speedy trial

grounds for abuse of discretion.” State v. Taylor, 881 N.W.2d 72, 76 (Iowa 2016).

“When speedy trial grounds are at issue, however, the discretion given to the

district court narrows.” State v. Winters, 690 N.W.2d 903, 907 (Iowa 2005). The

discretion is narrow as it relates to circumstances that provide good cause for delay

of the trial. State v. Campbell, 714 N.W.2d 622, 627 (Iowa 2006).

III. Discussion

Cosgrove argues the State failed to bring him to trial in violation of his

speedy trial rights under Iowa Rule of Criminal Procedure 2.33. In relevant part,

that rule states:

If a defendant indicted for a public offense has not waived the defendant’s right to a speedy trial the defendant must be brought to trial within 90 days after indictment is found or the court must order the indictment to be dismissed unless good cause to the contrary be shown.

continuance is ordered, or if they have deliberated until it satisfactorily appears that they cannot agree. The case shall be retried within 90 days unless good cause for further delay is shown. This rule may more accurately cover the situation following a mistrial than rule 2.33, and applicability of rule 2.19(6)(a) following a mistrial has support in our appellate case law. See, e.g., State v. Phelps, 379 N.W.2d 384, 386–87 (Iowa Ct. App. 1985) (relying on rule 18(6)(a) [later renumbered as rule 2.19(6)(a)] as the rule governing speedy trial following a mistrial). Deciding whether to apply rule 2.19(6)(a) or 2.33 is not critical to the resolution of this case, however, because “retrial of a case that had resulted in a mistrial involved the same speedy trial issues as would a case being brought on an initial indictment or information” and the exceptions that apply to speedy trial issues on retrial are the same as those that apply to an initial indictment or information. Id. at 386. 4

Iowa R. Crim. P. 2.33(2)(b). The speedy trial period resets when the district court

grants a mistrial. See State v. Zaehringer, 306 N.W.2d 792, 794–95 (Iowa 1981)

(requiring a criminal defendant to be retried within ninety after a mistrial); see also

Iowa R. Crim. P. 2.19(6)(a) (same). We have recognized three exceptions to the

speedy trial requirement, namely when “the State proves (1) defendant’s waiver of

speedy trial, (2) delay attributable to the defendant, or (3) ‘good cause’ for the

delay.” State v. Nelson, 600 N.W.2d 598, 600 (Iowa 1999). The State has the

burden to prove one of the exceptions applies. State v. Miller, 637 N.W.2d 201,

204 (Iowa 2001). These exceptions apply to retrial following a mistrial in the same

manner they apply to an initial indictment or information. Phelps, 379 N.W.2d at

386–87. In determining whether there is good cause for a delay, we focus only on

the reason for the delay. Campbell, 714 N.W.2d at 628. “The attending

circumstances bear on that inquiry only to the extent they relate to the sufficiency

of the reason itself.” Id.

Cosgrove maintains he did not waive his rights to a speedy in regard to the

second trial, which occurred more than ninety days after the district court declared

a mistrial. The State argues Cosgrove’s conduct necessarily waived a speedy trial

or, alternatively, the delay is attributable to him because defense counsel

participated in selecting the new trial date and the reason for the delay was

Cosgrove’s desire to have the subject matter of the State’s DNA test independently

tested.

On our review, we conclude the district court did not abuse its discretion by

denying Cosgrove’s motion to dismiss because Cosgrove waived his rights to a

speedy trial. It is true that “mere acquiescence in the setting of a trial date beyond 5

the period for speedy trial does not constitute waiver.” Zaehringer, 306 N.W.2d at

795. However, “acquiescence in the setting of a trial date beyond the speedy trial

period is a factor which may be considered in determining whether a defendant

has waived his speedy trial rights.” Id. The determinative issue is whether

sufficient additional circumstances are present to compel a finding of waiver. Id.

Such circumstances were present here.

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Related

State v. Miller
637 N.W.2d 201 (Supreme Court of Iowa, 2001)
State v. Winters
690 N.W.2d 903 (Supreme Court of Iowa, 2005)
State v. Nelson
600 N.W.2d 598 (Supreme Court of Iowa, 1999)
State v. Phelps
379 N.W.2d 384 (Court of Appeals of Iowa, 1985)
State v. Gansz
403 N.W.2d 778 (Supreme Court of Iowa, 1987)
State v. Zaehringer
306 N.W.2d 792 (Supreme Court of Iowa, 1981)
State v. Campbell
714 N.W.2d 622 (Supreme Court of Iowa, 2006)
State of Iowa v. Deyawna Leanett Taylor
881 N.W.2d 72 (Supreme Court of Iowa, 2016)

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