State v. Leon Kurtis Shivers

CourtCourt of Appeals of Iowa
DecidedFebruary 21, 2018
Docket16-1989
StatusPublished

This text of State v. Leon Kurtis Shivers (State v. Leon Kurtis Shivers) 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 v. Leon Kurtis Shivers, (iowactapp 2018).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 16-1989 Filed February 21, 2018

STATE OF IOWA, Plaintiff-Appellee,

vs.

LEON KURTIS SHIVERS, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Webster County, Kurt L. Wilke,

Judge.

The defendant appeals from his conviction for vehicular homicide by

operating while intoxicated. AFFIRMED.

Mark C. Smith, State Appellate Defender, and Martha J. Lucey, Assistant

Appellate Defender, for appellant.

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

Attorney General, for appellee.

Considered by Vogel, P.J., and Potterfield and Mullins, JJ. 2

POTTERFIELD, Judge.

Leon Shivers appeals from his conviction for vehicular homicide by

operating while intoxicated. He maintains the trial court erred when it denied his

request to instruct the jury on spoliation. He also claims trial counsel provided

ineffective assistance. Specifically, he maintains trial counsel (1) should have

objected to certain jury instructions and proposed different, updated instructions

based on the Restatement (Third) of Torts; (2) failed to object to inadmissible

hearsay; and (3) failed to object to an expert’s testimony about the ultimate fact at

issue for the jury to determine—whether the car accident was the cause of the

decedent’s death. He argues he was prejudiced by each of counsel’s alleged

errors individually and cumulatively.

I. Background Facts and Proceedings.

The undisputed facts establish that John McCartney was driving to the

grocery store on the evening of April 4, 2016, when his vehicle was struck in the

intersection of a four-way stop by a Dodge Journey. At the time of impact, the

Dodge Journey was traveling at a speed of fifty-two miles per hour. In the seconds

leading up to impact, the Dodge Journey was traveling in excess of seventy-two

miles per hour; the speed limit on the portion of road was twenty-five miles per

hour. The Dodge Journey was owned by Shivers’s girlfriend and her mother.

McCartney suffered subdural brain bleeds on both the right and left side of

his brain, and he was airlifted to a Des Moines hospital for brain surgery. In the

days following surgery, McCartney regained consciousness one time to the extent

that he was able to squeeze the hands of family members when prompted.

McCartney was otherwise unconscious and, at some point, he stopped responding 3

to pain. The family decided to place McCartney in hospice care, and he died on

April 22.

Shivers was apprehended at the scene after two witnesses stated they saw

him exit the driver’s side of the Dodge Journey. He denied being the driver. His

blood alcohol content—taken approximately four hours after the crash—tested at

.169. In May, the State charged Shivers with vehicular homicide by operating while

intoxicated.

At the November 2016 trial, Shivers disputed he was the driver of the Dodge

Journey and that the crash was the ultimate cause of McCartney’s death, as his

death occurred approximately eighteen days after the incident and only after the

family chose to forgo life-sustaining medical treatment.

The jury convicted Shivers as charged, and he was sentenced to an

indeterminate prison term not to exceed twenty-five years.

Shivers appeals.

II. Discussion.

A. Spoliation Instruction.

Standard of Review. The Iowa Supreme Court has now clarified that an

alleged instructional error for failure to give a spoliation instruction is reviewed for

correction of error at law. While the court previously applied an abuse of discretion

standard for denial of a spoliation instruction in the context of a discovery sanction,

see State v. Langlet, 283 N.W.2d 330, 335 (Iowa 1979), and for review of the form

of the instruction, see State v. Piper, 663 N.W.2d 894, 915 (Iowa 2003), overruled

on other grounds by State v. Hanes, 790 N.W.2d 545, 550 (Iowa 2010), the abuse-

of-discretion standard of review “does not extend to all refusals to give a requested 4

jury instruction.” Alcala v. Marriott Intern., Inc., 880 N.W.2d 699, 707 (Iowa 2016).

Unless there is a discretionary component, the court now applies the typical review

of alleged instructional error for correction of error at law. Id. (“Thus, we clarify

today that absent the discretionary component present in [State v.] Langlet, [283

N.W.2d 330 (Iowa 1979),] we review refusals to give a requested jury instruction

for correction of errors at law”).

Merits. A spoliation instruction is “a direction to the jury that it could infer

from the State’s failure to preserve [evidence] that the evidence would have been

adverse to the State.” State v. Vincik, 398 N.W.2d 788, 795 (Iowa 1987). The jury

should be instructed on spoliation when substantial evidence supports the

following: “(1) the evidence was ‘in existence’; (2) the evidence was ‘in the

possession of or under control of the party’ charged with its destruction; (3) the

evidence ‘would have been admissible at trial’; and (4) ‘the party responsible for

its destruction did so intentionally.’” State v. Hartsfield, 681 N.W.2d 626, 630 (Iowa

2004) (quoting Langlet, 283 N.W.2d at 335).

[T]he defendant need only generate a jury question on four specific factors in order to meet the requirements for a spoliation inference. If substantial evidence has been introduced on each element, then, as we said in State v. Ueding, 400 N.W.2d 550, 552 (Iowa 1987) a spoliation instruction “should be given”. Our conclusion that spoliation instructions should be given when supported by the record is particularly appropriate given the potential for constitutional due process implications arising from the State’s intentional destruction of evidence.

Id.

There is substantial evidence that the Dodge Journey existed and that the

State was in control of the vehicle for a short time after the accident. The Iowa

State Trooper who performed the technical investigation of the crash testified he 5

examined the vehicle on April 5, the day following the accident. He took

photographs and opened the driver’s door. Afterward, he released the vehicle to

its owners, who “usually let their insurance companies take care of it from there.”

The mother of Shivers’s girlfriend testified the vehicle was “released to the

insurance company” from the place to which it had been towed following the

accident. There was no further testimony about what happened to the vehicle after

April 5, when the insurance company took control.

Shivers maintains his “defense centers on the functionality of the driver’s

door,” comparing his contention he was a passenger in the vehicle with that of two

of the State’s witnesses who testified they saw Shivers exit the front, driver’s side

door after the crash.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
State v. Ueding
400 N.W.2d 550 (Supreme Court of Iowa, 1987)
State v. Piper
663 N.W.2d 894 (Supreme Court of Iowa, 2003)
State v. Vincik
398 N.W.2d 788 (Supreme Court of Iowa, 1987)
State v. Tate
710 N.W.2d 237 (Supreme Court of Iowa, 2006)
State v. Hartsfield
681 N.W.2d 626 (Supreme Court of Iowa, 2004)
State v. Langlet
283 N.W.2d 330 (Supreme Court of Iowa, 1979)
State v. Johnson
784 N.W.2d 192 (Supreme Court of Iowa, 2010)
State of Iowa v. James Phillip Morgan
877 N.W.2d 133 (Court of Appeals of Iowa, 2016)
State of Iowa v. Allen Bradley Clay
824 N.W.2d 488 (Supreme Court of Iowa, 2012)
State Of Iowa Vs. Robert L. Hanes
790 N.W.2d 545 (Supreme Court of Iowa, 2010)
State v. Keys
901 N.W.2d 837 (Court of Appeals of Iowa, 2017)

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