State of Iowa v. Wour Nathanial Magang

CourtCourt of Appeals of Iowa
DecidedFebruary 8, 2023
Docket21-1535
StatusPublished

This text of State of Iowa v. Wour Nathanial Magang (State of Iowa v. Wour Nathanial Magang) 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. Wour Nathanial Magang, (iowactapp 2023).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 21-1535 Filed February 8, 2023

STATE OF IOWA, Plaintiff-Appellee,

vs.

WOUR NATHANIAL MAGANG, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Polk County, David M. Porter, Judge.

A defendant appeals his convictions and sentences. AFFIRMED.

Martha J. Lucey, State Appellate Defender, and Rachel C. Regenold,

Assistant Appellate Defender, for appellant.

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

General, for appellee.

Considered by Tabor, P.J., and Schumacher and Chicchelly, JJ. 2

SCHUMACHER, Judge.

Wour Magang appeals his convictions and sentences for second-degree

robbery and first-degree burglary. Magang contends the court wrongly admitted

footage from a police officer’s body camera. He claims his convictions are not

supported by sufficient evidence and claims the district court utilized the wrong

standard when considering his motion for a new trial. He also claims the court

abused its discretion during sentencing. We find the court properly admitted the

officer’s body camera footage. Sufficient evidence supports Magang’s convictions.

The district court did not use the wrong standard when deciding Magang’s motion

for a new trial. And the court did not abuse its discretion in sentencing.

Accordingly, we affirm.

I. Background Facts & Proceedings

The events underpinning Magang’s convictions occurred in the early

morning hours of August 25, 2019. Around 2:55 a.m., Janet Leon called 911 to

report a burglary. She reported that as she opened the door to let her friend leave,

two men entered her home with guns. They stole her safe, which contained money

and credit cards, then ran away through the parking lot. She reported that she was

“bleeding like crazy” because her “head’s fucking gashed in.”

Police responded to the scene about six minutes after Leon called 911.

Upon arriving, Officer Jordan Ulin found Leon bloodied and wandering around

outside her apartment. Ulin’s body camera showed Leon mumbling and calling for

her cat, which escaped during the burglary. Without prompting, Leon showed the

officer where the safe used to be located. She reported both men had guns and

provided physical descriptions of the men. Officer Ulin testified that the wounds to 3

Leon’s head were consistent with being struck by a firearm, which he referred to

as “pistol-whipping.”

While Officer Ulin stayed with Leon, Officer Ryan Neumann canvased the

area. He encountered two individuals in the apartment’s parking lot who advised

him that a “large black man with dreads” had run through the lot shortly before the

officer’s arrival, matching the previous description provided by Leon. He followed

the path they directed him on, eventually encountering a woman sitting in a vehicle.

She informed Officer Neumann that she had seen multiple males running away,

carrying something large.

Officer Dustin Wing and K-9 Bingo picked up a scent around Leon’s

apartment and followed it to another apartment building about a block-and-a-half

away. The path Bingo took was similar to the one described by witnesses as to

the direction where one or more men had fled. Bingo alerted at the front of unit 6

of the apartment building. A man emerged from the apartment, said, “Oh shit,”

and quickly shut the door. Officer Wing was able to see multiple men and one

female inside the apartment. One of the men was large, shirtless, and had a

hairstyle similar to the one described by previous witnesses. Officer Wing testified

the man’s appearance was consistent with that of Magang. Several of the

apartment’s occupants demanded a police supervisor be present.

Officer Neumann moved toward a main road to flag down his supervisor.

While doing so, he noticed Magang moving through a tree line area. Magang fit

the description provided by witnesses. Magang informed Neumann that he was

urinating in this area because he was drunk. He reported he was staying at his

girlfriend’s home in the area, although he could not provide an address. Neumann 4

searched Magang, finding about $260 in cash as well as multiple credit cards. Two

of the cards belonged to Leon. Magang was arrested.

The State charged Magang with first-degree robbery and first-degree

burglary. Trial was held August 2 and 3, 2021. Leon did not testify, citing the

trauma further involvement in the case would cause her. The jury found Magang

guilty of second-degree robbery, in violation of Iowa Code section 711.3 (2019),

and first-degree burglary, in violation of section 713.3.

Magang filed a motion for a new trial. Magang’s motion for new trial claimed

the verdict was contrary to the law or evidence. The motion for a new trial also

claimed the jury was tainted. He also filed a motion in arrest of judgment, asserting

the same claims as his motion for a new trial. The court denied both motions.

Magang was sentenced to ten years in prison for the robbery conviction and

twenty-five years in prison for the burglary conviction. The district court ordered

the burglary and robbery sentences to run consecutively. Magang appeals.

II. Discussion

Magang contests the admissibility of Officer Ulin’s body camera footage.

He also claims evidence was insufficient to support either of his convictions. He

claims the court used the wrong standard when considering his motion for new

trial. And he contends the court abused its discretion during sentencing.

A. Bodycam Footage

Magang challenges the admissibility of Officer Ulin’s body camera footage.

He asserts Leon’s statements were inadmissible hearsay. He also claims the

footage is unduly prejudicial. The district court found Leon’s statements in Officer

Ulin’s body camera footage were admissible pursuant to the excited utterance 5

exception to the hearsay rule. The admissibility of evidence is generally reviewed

for an abuse of discretion. State v. Dessinger, 958 N.W.2d 590, 597 (Iowa 2021).

“We review hearsay claims, however, for corrections of errors at law. The

correction for errors at law standard is applicable in determining whether evidence

that would generally be prohibited as hearsay comes in under a hearsay

exception.” Id. (internal citation omitted).

1. Hearsay

Leon’s statements to Officer Ulin, including statements describing the

suspects and the fact that they stole her safe, are hearsay, meaning an out of court

assertion used to prove the truth of the matter asserted. See id. at 599; Iowa R.

Evid. 5.801(c). Thus, the admissibility of those statements turns on whether an

exception to hearsay applies. See Iowa R. Evid. 5.802. The district court cited the

excited utterance exception to hearsay when it found Leon’s statements

admissible. See id. 5.803(2). That exception permits a court to admit hearsay

statements “relating to a startling event or condition, made while the declarant was

under the stress of excitement [that it] caused.” Id. To determine the applicability

of the exception, we consider:

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Ellis
578 N.W.2d 655 (Supreme Court of Iowa, 1998)
State v. Delaney
526 N.W.2d 170 (Court of Appeals of Iowa, 1994)
State v. Criswell
242 N.W.2d 259 (Supreme Court of Iowa, 1976)
State v. Shanahan
712 N.W.2d 121 (Supreme Court of Iowa, 2006)
State v. Formaro
638 N.W.2d 720 (Supreme Court of Iowa, 2002)
State v. Atwood
602 N.W.2d 775 (Supreme Court of Iowa, 1999)
State v. Taylor
596 N.W.2d 55 (Supreme Court of Iowa, 1999)
State v. Harper
770 N.W.2d 316 (Supreme Court of Iowa, 2009)
State of Iowa v. Donald James Hill
878 N.W.2d 269 (Supreme Court of Iowa, 2016)
State of Iowa v. Christopher Craig Thompson
837 N.W.2d 180 (Supreme Court of Iowa, 2013)
State of Iowa v. Karen Sue Huston
825 N.W.2d 531 (Supreme Court of Iowa, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
State of Iowa v. Wour Nathanial Magang, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-wour-nathanial-magang-iowactapp-2023.