State of Iowa v. Daniel Louis Chandler
16-0925
| Iowa Ct. App. | Jul 19, 2017Background
- On a winter night an officer stopped Daniel Chandler, who had a temporary restricted license the officer knew required an Intoxilyzer and limited driving (work-related only); officer knew Chandler worked for a lawn-care company and had stopped him before.
- Officer saw Chandler with a passenger around 10:30 p.m., checked his license, instructed him out of the car, and searched him; marijuana was found and Chandler scuffled and was arrested.
- Chandler was charged with third-offense possession of a controlled substance (with habitual-offender enhancement) and interference with official acts causing bodily injury.
- Chandler moved to suppress the evidence, arguing the stop lacked reasonable suspicion; the district court denied the motion.
- Chandler consented to a trial on the minutes of evidence (which summarized prior convictions); the court convicted and applied sentencing enhancements.
- On appeal Chandler challenged the suppression ruling, alleged double jeopardy based on post-trial proceedings, and argued the State failed to sufficiently prove prior convictions for enhancements.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the stop was supported by reasonable suspicion | Officer had specific & articulable facts: known temporary restricted license, time of night (10:30 p.m.), passenger present, winter season, and occupation inconsistent with being home from work | Stop was based on a mere hunch about violation of the restricted-license terms | Court affirmed: facts gave reasonable suspicion to stop the vehicle |
| Whether double jeopardy was violated by post-trial handling of enhancements | No double jeopardy: guilt on offenses and enhancements were resolved in the single proceeding (trial on the minutes) | Court subjected him to double jeopardy by re-determining guilt later | Court rejected defendant’s claim: no second trial or additional evidence taken; counsel acknowledged both issues were resolved at the minutes trial |
| Whether State proved prior convictions for sentencing enhancements | State: defendant agreed to trial on the minutes, which included summaries of priors; defendant waived additional proof | Chandler: State failed to prove priors sufficiently; he tried to preserve record by not stipulating to priors | Court held defendant waived the challenge by agreeing to trial on the minutes and not requiring witnesses or proof of priors |
| Whether bifurcation under Iowa R. Crim. P. 2.19(9) was required | State: bifurcation rule inapplicable where parties agree to proceed on minutes | Chandler: argued the court should have bifurcated trial on priors from guilt phase | Court: rule applies only absent agreement; parties agreed to resolve everything on the minutes, so no error |
Key Cases Cited
- Navarette v. California, 134 S. Ct. 1683 (2014) (reasonable-suspicion standard for investigatory stops)
- Illinois v. Wardlow, 528 U.S. 119 (2000) (officer must articulate more than an inchoate hunch)
- Terry v. Ohio, 392 U.S. 1 (1968) (foundation for investigatory stop analysis)
- State v. Pals, 805 N.W.2d 767 (Iowa 2011) (Iowa reasonable-suspicion standards for stops)
- State v. Tague, 676 N.W.2d 197 (Iowa 2004) (specific and articulable facts required for stop)
- Justices of Boston Mun. Ct. v. Lydon, 466 U.S. 294 (1984) (double jeopardy application to states discussion)
- State v. Huss, 657 N.W.2d 447 (Iowa 2003) (double jeopardy principles)
- State v. Franzen, 495 N.W.2d 714 (Iowa 1993) (state constitutional double jeopardy authority)
- State v. Johnson, 770 N.W.2d 814 (Iowa 2009) (rule on bifurcation and parties' agreement)