State of Iowa v. William Lee Coleman

CourtCourt of Appeals of Iowa
DecidedJune 29, 2022
Docket21-1008
StatusPublished

This text of State of Iowa v. William Lee Coleman (State of Iowa v. William Lee Coleman) 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. William Lee Coleman, (iowactapp 2022).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 21-1008 Filed June 29, 2022

STATE OF IOWA, Plaintiff-Appellee,

vs.

WILLIAM LEE COLEMAN, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Adams County, Elisabeth

Reynoldson, Judge.

William Coleman appeals his convictions for interference with official acts

and assault on a peace officer. AFFIRMED.

Richard Hollis, Des Moines, for appellant.

Thomas J. Miller, Attorney General, and Thomas J. Ogden, Assistant

Attorney General, for appellee.

Considered by Vaitheswaran, P.J., and Tabor and Badding, JJ. 2

VAITHESWARAN, Presiding Judge.

William Coleman appeals his convictions, following a jury trial, for

interference with official acts and assault on a peace officer. Coleman contends

the district court erred in denying his second suppression motion and in refusing

to submit his requested jury instruction on a defense of justification.

I. Background Facts and Proceedings

The Adams County Sheriff’s Department received a report of a car accident.

A deputy sheriff spoke to eye witnesses, who told him a vehicle was “going [at] a

high rate of speed, missed the stop sign, . . . missed another sign, . . . and then

crashed into the ditch.” The deputy found the vehicle unoccupied and determined

it was owned by Coleman. According to the witnesses, Coleman said he was

going to his brother’s house and left the scene. They described what Coleman

was wearing.

Meanwhile, Coleman called dispatch. The deputy returned the call and told

him to come to the scene of the accident. Coleman demurred. The deputy ordered

the car towed, then called Coleman back again, “[b]ecause he was involved in an

accident and [the deputy] was trying to figure out what was going on and if there

was something more than just a simple accident.” Coleman again declined to

disclose his whereabouts, as did family members.

Shortly thereafter, the deputy decided to follow a vehicle driven by

Coleman’s mother. He stopped the vehicle for a cracked taillight. The ensuing

encounter was captured on video.

Coleman was in the front passenger seat. The deputy repeatedly ordered

him out of the vehicle, his tone and language escalating, as Coleman refused to 3

comply with the order. The deputy called for back-up and told Coleman, “I’ll bust

the window if that’s what you want.” As he continued to exhort Coleman to get out

of the vehicle, Coleman hit the deputy’s hand. When backup arrived, the

passenger window was broken, and officers forcibly removed Coleman from the

vehicle.

The State charged Coleman with interference with official acts while

attempting to inflict serious injury, in violation of Iowa Code section 719.1(1)(f)

(2019), and assault on a peace officer, in violation of sections 708.1 and 708.3A(4).

Coleman filed two motions to suppress and a motion to dismiss, all of which were

denied. A jury found Coleman guilty of the lesser-included offense of interference

with official acts and assault on a peace officer.

On appeal, Coleman (A) challenges the district court’s ruling on his second

suppression motion and (B) argues the jury instructions “should have included [his]

justification defense.”

II. Analysis

A. Suppression Motion

“Both the Fourth Amendment to the United States Constitution and article I,

section 8 of the Iowa Constitution grant people a right of protection against

unreasonable searches and seizures of ‘their persons, houses, papers, and

effects.’” State v. Hunt, ___ N.W.2d ___, ___, 2022 WL 1592167, at *2 (Iowa

2022) (quoting U.S. Const. amend. IV; Iowa Const. art. I, § 8). “These rights

safeguard people against warrantless searches and seizures by the government,

with carefully drawn exceptions.” Id. A temporary detention of individuals during 4

a traffic stop amounts to a seizure of persons within the meaning of the Fourth

Amendment. See State v. Hauge, 973 N.W.2d 453, 458–59 (Iowa 2022).

Coleman does not challenge the validity of the deputy’s initial traffic stop.

See id. at 458. Nor does he argue for a distinct analysis under the Iowa

Constitution. Cf. id. at 459–60 (declining the defendant’s request to decide

whether a heightened standard should be adopted under the Iowa Constitution);

State v. Price-Williams, 973 N.W.2d 556, 562 (Iowa 2022) (same). Accordingly,

we will confine our analysis to the Fourth Amendment.

Coleman preliminarily notes that the deputy’s “sole purpose in ordering

[him] out of the car was to further his investigation.” Cf. Hauge, 973 N.W.2d at 459

(noting the parties “agree that [the deputy’s] order for [the defendant] to exit the

vehicle was lawful under the Fourth Amendment”). But, as the court noted in

Hauge, the United States Supreme Court has “held an officer may order a vehicle

passenger out of the vehicle during the course of a routine traffic stop for any

reason regardless of whether the officer has reason to suspect foul play or

anything problematic about the passenger.” Id. (citing Maryland v. Wilson, 519

U.S. 408, 414–15 (1997). And, as the State notes, the Iowa Supreme Court has

adopted an objective test for assessing the reasonableness of traffic stops,

although it has not foreclosed an evaluation of an officer’s subjective motivations

in determining whether a traffic stop occurred. See State v. Brown, 930 N.W.2d

840, 849-50, 854 (Iowa 2019).

This case differs from Wilson and Hauge in that the deputy was not

investigating the driver’s traffic violation when he ordered Coleman out of the car.

Rather, because the officer’s primary focus was on removing Coleman from the 5

vehicle, the officer must have probable cause, or at least reasonable suspicion, for

that seizure.

Coleman contends the deputy “failed to provide a reasonable articulable

suspicion that [he] was intoxicated at the time of the accident” and his “concern

was based on mere suspicion, nothing more.” But Coleman is faced with recent

precedent undercutting his argument. In Price-Williams, the court stated, “An

officer may have reasonable suspicion to order a passenger out of the vehicle

based on a combination of the officer’s past experience with the passenger” and

present acts. 973 N.W.2d at 562. As noted at the outset, witnesses told the deputy

that Coleman traveled at an excessive rate of speed before crashing his vehicle.

The crash occurred shortly before the deputy ordered Coleman out of his mother’s

vehicle. The circumstances and timing of the crash afforded the deputy

reasonable suspicion to investigate the accident, whether or not he possessed

identifiable indicia of intoxication. See Brown, 930 N.W.2d at 846 (citing the

defendant’s concession “that the officer’s subjective motivations are irrelevant

under the Fourth Amendment to the United States Constitution so long as there is

probable cause to support the stop”). On our de novo review of the record, we

conclude the district court appropriately denied Coleman’s second suppression

motion.

B. Jury Instruction

At trial, Coleman objected to the district court’s “failure to include absence

of justification in the Court’s draft, as an element of proof required for conviction.”

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Related

Maryland v. Wilson
519 U.S. 408 (Supreme Court, 1997)
State v. Bedard
668 N.W.2d 598 (Supreme Court of Iowa, 2003)
State v. Delay
320 N.W.2d 831 (Supreme Court of Iowa, 1982)
State v. Rains
574 N.W.2d 904 (Supreme Court of Iowa, 1998)
State v. Sharkey
311 N.W.2d 68 (Supreme Court of Iowa, 1981)
State of Iowa v. Scottize Danyelle Brown
930 N.W.2d 840 (Supreme Court of Iowa, 2019)
State v. Hudson
895 N.W.2d 486 (Court of Appeals of Iowa, 2016)

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