Douglas Evander St. Cyr v. State of Iowa, 20-0628

Background

Two consolidated bench-trial matters: (1) traffic stop that produced methamphetamine and a driving-while-barred charge; (2) subsequent arrest after St. Cyr failed to appear, during which he rammed an undercover van, fled, abandoned a vehicle with contraband, and was later captured.
Officer stopped St. Cyr for allegedly no registration plates at night; a Nebraska dealer in‑transit paper registration was taped to the rear window but not seen by the officer as he approached.
While speaking to St. Cyr the officer observed suspected methamphetamine and discovered St. Cyr’s license was suspended; district court denied suppression and admitted the evidence.
After St. Cyr missed his trial, a warrant issued; in attempting to effectuate the warrant, officers boxed an SUV believed to be St. Cyr’s; St. Cyr accelerated, rammed the unmarked van twice, fled, and later abandoned the SUV containing contraband.
St. Cyr was convicted on multiple counts arising from both incidents (including possession of methamphetamine, driving while barred, failure to appear, assault with a dangerous weapon (lesser included), leaving the scene, possession of ammunition, driving while suspended).
Appeal issues: (1) suppression of evidence from the traffic stop; (2) sufficiency of evidence for failure to appear; (3) sufficiency for assault with a dangerous weapon; (4) whether necessity or compulsion justified his conduct.

Issues

Issue	State's Argument	St. Cyr's Argument	Held
Lawfulness of traffic stop / motion to suppress	Officer had an objectively reasonable basis for the stop despite mistake about plates; discovery of contraband before any resolution justified continued detention	Officer was stopped in error because valid in‑transit sticker was displayed; officer unreasonably prolonged stop by not checking rear window first	Denial of suppression affirmed — officer’s mistake was objectively reasonable and contraband was observed before the mistake was discovered
Sufficiency — failure to appear	Notice was mailed to St. Cyr’s address, counsel was notified, and St. Cyr evaded arrest for months — supports willfulness	Lack of proof St. Cyr actually received notice; no proof of willful failure to appear	Conviction affirmed — substantial evidence supports willful failure to appear
Sufficiency — assault with a dangerous weapon	Repeatedly ramming the van (including while the driver was exiting) shows intent to cause injury or place officer in fear	Collisions were incidental to an attempt to flee, not intentional assaultive conduct	Conviction (lesser included offense) affirmed — substantial evidence of assaultive intent
Necessity / compulsion defenses	State: defendant created the danger, had alternatives, and no well‑grounded fear of imminent serious injury; statutory bar to compulsion when defendant intentionally/recklessly caused injury	St. Cyr: shot at / imminent danger justified ramming and fleeing; acted under compulsion/necessity	Defenses rejected — St. Cyr failed to generate fact questions; statutory compulsion exclusion applies because his conduct caused physical injury

Key Cases Cited

State v. Lloyd, 701 N.W.2d 678 (Iowa 2005) (officer’s reasonable mistake of fact can justify a stop)
State v. Coleman, 890 N.W.2d 284 (Iowa 2017) (stop must end once the reason for the stop is resolved)
State v. Salcedo, 935 N.W.2d 572 (Iowa 2019) (investigatory stop must be tailored to the traffic infraction and related safety inquiries)
State v. Warren, 955 N.W.2d 848 (Iowa 2021) (officers may extend a stop if reasonable suspicion of another crime develops)
Rodriguez v. United States, 575 U.S. 348 (2015) (authority for seizure ends when tasks tied to traffic infraction are— or reasonably should have been—completed)
Terry v. Ohio, 392 U.S. 1 (1968) (two‑part Terry inquiry: justification at inception and scope reasonably related to circumstances)
United States v. Mendoza, 691 F.3d 954 (8th Cir. 2012) (officer safety can justify certain investigatory approaches; factual comparison invoked in suppression analysis)