State of Iowa v. Dontay Dakwon Sanford
2012 Iowa Sup. LEXIS 68
Iowa2012Background
- Sanford was convicted of first-degree burglary for entering Mills’ automobile during a violent incident in a Kum & Go parking lot in Waterloo.
- The State alleged Mills’ car qualified as an occupied structure under Iowa Code 702.12, a key element of first-degree burglary.
- Harrington sought refuge inside Mills’ car during the assault; assailants unlocked doors and attacked, leading to Mills’ fatal injuries.
- The jury was instructed that Mills’ car could be an occupied structure if it was occupied for the purpose of carrying on activity therein.
- Sanford challenged the sufficiency of the evidence and sought dismissal/mistrial and a new trial on several grounds.
- The district court denied the amended-information motion and related defenses; the verdict and sentence were upheld on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Mills’ car was an occupied structure under 702.12 | State: car was occupied for activity (self-defense/assault) and thus qualifies | Sanford: no activity within car; not an occupied structure | Yes; car occupied for activity, sufficient evidence supports occupancy |
| Admission of edited police interview video and related evidentiary rulings | State: proper admission; defense objections waived by failure to object | Sanford: edited video prejudicial; prejudicial error | Claims waived; no reversible error identified |
| Pro se claims of mistrial and jury-deliberation evidence | State: no prosecutorial misconduct; jurors followed instructions | Sanford: mistrial warranted; juror-deliberations tainted | Not persuaded; no reversible error |
Key Cases Cited
- State v. Pace, 602 N.W.2d 764 (Iowa 1999) (defines occupancy and activity requirements for occupied structures)
- State v. Buss, 325 N.W.2d 384 (Iowa 1982) (occupancy of passenger compartment of land vehicle)
- State v. Williams, 409 N.W.2d 187 (Iowa 1987) (amended definitions; includes land vehicles in occupancy rule)
- State v. Davis, 671 N.W.2d 28 (Iowa 2003) (recognizes occupancy of car's passenger compartment)
- Newman v. State, 313 N.W.2d 484 (Iowa 1981) (enclosed area interpretation prompted legislative update)
- State v. Keopasaeuth, 645 N.W.2d 637 (Iowa 2002) (sufficiency and occupancy considerations in burglary)
- State v. Nitcher, 720 N.W.2d 547 (Iowa 2006) (standard for reviewing sufficiency of evidence)