State of Iowa v. Marcus Antino Hall
16-0957
| Iowa Ct. App. | Jul 19, 2017Background
- On Sept. 18, 2015, a Des Moines officer observed Marcus Hall driving a gold sedan with an allegedly malfunctioning brake light; the officer activated emergency lights to stop him.
- Hall did not stop and fled; a state trooper joined the pursuit. Officers observed multiple traffic violations during the chase (failure to yield to emergency vehicle, speeding (over 80 in a 30), reckless driving, and eluding).
- Hall eventually stopped in his apartment-complex parking lot and was arrested. Video recordings of the pursuit were admitted at trial.
- The State charged Hall with eluding (Iowa Code §321.279(3)), operating while intoxicated (OWI, §321J.2(2)(a)), and driving while barred; Hall pleaded guilty to driving-while-barred but was tried on the other two counts.
- Hall moved to suppress, arguing the initial stop lacked probable cause because his brake lights were functioning; the district court denied suppression. After a jury trial, Hall was convicted of eluding and OWI and renewed a motion for judgment of acquittal, which the court denied.
- The Court of Appeals considered (1) whether the activation of lights and attempted stop constituted a seizure and whether probable cause existed to stop for a defective brake light, and (2) sufficiency of evidence for eluding and OWI convictions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether activation of emergency lights and attempted traffic stop was a seizure | The show of authority (lights) did seize Hall and officers had probable cause to stop for a defective brake light | Hall argued he was seized without probable cause because his brake lights were functioning | Court: The lights constituted a seizure; officer had probable cause to stop based on observed malfunctioning bulb under §321.387 |
| Whether probable cause existed to stop for a brake-light violation | Officer observed (and testified to) a nonworking bulb in the driver-side brake lamp, satisfying §321.387; State met burden by preponderance | Hall disputed the brake-light malfunction; dash-cam was inconclusive | Court: Credited officer testimony; stop justified by probable cause |
| Sufficiency of evidence for OWI conviction | Officers observed erratic driving, odor of marijuana, watery/dilated eyes, and one officer performed field evaluation indicating cannabis impairment; Hall admitted smoking marijuana earlier | Hall offered alternative explanations and contested officers’ observations | Court: Evidence sufficient when viewed in State’s favor; jury could credit officers over Hall |
| Sufficiency of evidence for eluding conviction under §321.279(3) | Officers were uniformed, driving marked vehicles, gave visual/audible signals; Hall fled, exceeded speed limit by 25+ mph, and was under influence | Hall contested facts and evidence reliability | Court: Evidence sufficient—elements (marked vehicle, visual/audible signal, speed, and OWI) supported conviction |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (1968) (show of authority and seizure analysis)
- United States v. Mendenhall, 446 U.S. 544 (1980) (reasonable person test for seizure)
- State v. Pals, 805 N.W.2d 767 (Iowa 2011) (probable cause for traffic stops)
- State v. Tague, 676 N.W.2d 197 (Iowa 2004) (State’s burden to prove probable cause for stop)
- State v. Sanford, 814 N.W.2d 611 (Iowa 2012) (standard for reviewing sufficiency of evidence)