State of Iowa v. Justin Krutsinger
16-0963
| Iowa Ct. App. | May 3, 2017Background
- On Feb. 27, 2015, Justin Krutsinger crashed his Chevrolet into a Pontiac on Highway 6, killing the other driver; crash data showed Krutsinger was driving 116 mph and did not brake.
- Open and partially consumed alcoholic beverages were found in Krutsinger’s car; a urine test later showed a .200 alcohol level.
- Multiple bystanders, officers, EMS personnel, and hospital staff observed signs of intoxication; Krutsinger was agitated and briefly handcuffed at the hospital.
- Troopers advised Krutsinger of Miranda rights and discussed a preliminary breath test and implied consent; Krutsinger at times asked about calling a lawyer, but ultimately declined and provided a urine sample.
- Krutsinger moved to suppress evidence, arguing violation of Iowa Code § 804.20 (right to make telephone calls). He was convicted of homicide by vehicle while intoxicated (Iowa Code § 707.6A(1)) and appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officers violated § 804.20 by denying Krutsinger a reasonable opportunity to call an attorney | State: officers afforded Krutsinger the chance to call, and he declined or waived the call | Krutsinger: he asked to call an attorney and was not given reasonable opportunity or assistance (phone/phone book) | Court: No violation; exchanges showed he declined or waived the call and was offered ability to call |
| Whether any alleged § 804.20 violation required suppression of evidence | State: no statutory right was denied, so suppression not warranted | Krutsinger: suppression required because statutory right was impaired | Court: No suppression — right not invoked or was waived |
| Whether evidence was sufficient to prove causation for homicide by vehicle while intoxicated | State: strong evidence of intoxication and dangerous driving (speed, no braking) causally linked to death | Krutsinger: crash resulted from a dissociative episode from PTSD, not intoxication | Court: Evidence substantial; jury could reject dissociation defense and find intoxication caused death |
| Whether the jury could properly weigh conflicting expert and lay testimony on impairment and dissociation | State: jury entitled to weigh credibility and accept State’s evidence | Krutsinger: expert testimony raised reasonable doubt about causation | Court: Jury credibility determinations upheld; conflicts for jury to resolve |
Key Cases Cited
- Lamoreux v. State, 875 N.W.2d 172 (Iowa 2016) (standard of review for statutory interpretation and suppression rulings)
- Walker v. State, 804 N.W.2d 284 (Iowa 2011) (substantial-evidence standard for suppression fact findings)
- Hicks v. State, 791 N.W.2d 89 (Iowa 2010) (§ 804.20 requires reasonable opportunity to contact attorney but not affirmative notice)
- Adams v. State, 810 N.W.2d 365 (Iowa 2012) (State must prove causal connection between intoxicated driving and death)
- Tyler v. State, 873 N.W.2d 741 (Iowa 2016) (discussion of causation principles in vehicular homicide)
- Showens v. State, 845 N.W.2d 436 (Iowa 2014) (standard of review for sufficiency of evidence)
- Thornton v. State, 498 N.W.2d 670 (Iowa 1993) (jury may accept or reject witness testimony and assess credibility)
- Hutchison v. State, 721 N.W.2d 776 (Iowa 2006) (credibility and weight of evidence are for the jury)