State of Iowa v. Delandres Thompson, 15-1463

On Oct. 17, 2014 police observed a silver Pontiac Grand Prix driving at high speed and heard gunshots; a pursuit was authorized under the department’s policy related to shots fired.
The vehicle crashed into a tree, sideswiped and struck squad cars, a passenger fled, officers fired at the driver, and a .45 semi-automatic was found near the crash site.
Thompson was found hiding in a house, arrested, and initially charged that day with driving while barred; keys to the Grand Prix were found where he hid.
Additional felony charges (second-degree criminal mischief, assault on a police officer with a dangerous weapon, and felony eluding) were filed later (trial information filed Jan. 7, 2015) arising from the Oct. 17 incident.
At trial Thompson stipulated he was the driver; defense moved in limine to exclude evidence of gunshots (denied). During trial Thompson voluntarily failed to return from lunch; the court found he absented himself and proceeded in his absence.
A jury convicted Thompson of the charged felonies; he appealed raising speedy-indictment, admissibility of gunshot testimony, and right-to-be-present/continuance claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Speedy-indictment (45‑day rule)	State: the 45‑day clock started on the arrest for the driving-while-barred charge; subsequent felony information filed timely relative to their arrests	Thompson: Oct. 17 arrest triggered the 45‑day clock for all offenses from that incident (Wing reasonable-person test)	Affirmed — separate prosecution for different offenses not barred; Wing analysis not controlling where separate charge was filed for a different offense already prosecuted (Dennison/Penn‑Kennedy framework applies)
Admissibility of testimony about gunshots	State: testimony about hearing/observing shots was relevant to explain officers’ decision to pursue under pursuit policy; probative value outweighs prejudice	Thompson: gunshot evidence unfairly prejudicial and not admissible because he wasn’t charged with firearms offenses	Affirmed — trial court did not abuse discretion; gunshot testimony was relevant to explain pursuit, not unduly prejudicial; any error harmless given stipulations and video evidence
Proceeding after defendant left during trial (continuance)	State: trial may proceed when defendant voluntarily absents; court made reasonable inquiry and gave opportunity to locate defendant	Thompson: court should have further inquired and granted continuance; absence violated right to be present	Affirmed — court correctly found Thompson voluntarily absent, denial of continuance proper, and proceeding in absence constitutional

State v. Wing, 791 N.W.2d 243 (Iowa 2010) (reasonable‑person test for assessing whether an arrest occurred)
State v. Penn‑Kennedy, 862 N.W.2d 384 (Iowa 2015) (clarifies Wing does not alter framework where multiple charges arise from same episode)
State v. Dennison, 571 N.W.2d 492 (Iowa 1997) (separate prosecutions for different offenses after an arrest are permissible)
State v. Lyons, 210 N.W.2d 543 (Iowa 1973) (rejects an elements‑only test; allows probative evidence that tells a complete story)
State v. Alberts, 722 N.W.2d 402 (Iowa 2006) (motion in limine preserves issue when ruling is final and declares evidence admissible or inadmissible)
State v. Martin, 704 N.W.2d 665 (Iowa 2005) (admission of prejudicial evidence may be harmless where guilt proven overwhelmingly)