978 N.W.2d 107
Iowa Ct. App.2022Background
- Nathan Ray Tesch was charged with third‑degree burglary and fourth‑degree theft after a safe was stolen from a Spencer clinic; charges were consolidated and tried together.
- Trial informations were filed Oct. 16, 2019 (theft) and Jan. 22, 2020 (burglary); trial ultimately occurred Feb. 2, 2021.
- Tesch filed two motions to dismiss for lack of a speedy trial, arguing COVID‑19 court closures and other State actions caused an unconstitutional delay of over one year.
- Iowa Supreme Court issued supervisory orders during COVID‑19 modifying speedy‑trial deadlines; district court relied on those orders in rejecting Tesch’s rule‑based and constitutional claims.
- The district court found pandemic shutdowns and a witness quarantine valid reasons for delay; it also found Tesch asserted his right but failed to show actual prejudice.
- Jury convicted Tesch of both counts; he appealed raising federal and state speedy‑trial claims and challenging the relevance and sufficiency of evidence on the safe’s value.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Federal speedy‑trial (Sixth Amendment) | Delay ~1 year was short, largely caused by pandemic and valid reasons, so no constitutional violation | Delay was excessive; pandemic orders cannot abrogate constitutional speedy‑trial rights | No violation: delay presumptively prejudicial but short; pandemic supervisory orders and witness quarantine were valid reasons; defendant failed to show actual prejudice |
| State speedy‑trial (Iowa Const. art I, § 10) | Same as federal: pandemic measures justified delay; supervisory orders appropriate | Iowa Constitution is broader; counting earlier criminal complaint adds delay and supports violation | No violation: even adding the earlier complaint time, delay not so onerous to violate state constitution |
| Relevance/sufficiency of value evidence for fourth‑degree theft | Office manager’s testimony that replacement value was $619 was relevant and substantial evidence | Testimony about a new safe was irrelevant without proof of depreciation/condition for a 16‑year‑old safe; insufficient to show value > $300 | Admissible and sufficient: jury instruction allowed replacement value; testimony supported the value element; conviction affirmed |
Key Cases Cited
- Barker v. Wingo, 407 U.S. 514 (1972) (sets four‑factor balancing test for speedy‑trial claims)
- Doggett v. United States, 505 U.S. 647 (1992) (delay may be presumptively prejudicial)
- State v. Watson, 970 N.W.2d 302 (Iowa 2022) (discusses Iowa Supreme Court COVID‑19 supervisory orders)
- State v. Basquin, 970 N.W.2d 643 (Iowa 2022) (upholds court’s authority to issue COVID‑19 supervisory orders balancing defendant rights and public safety)
- State v. Sanford, 814 N.W.2d 611 (Iowa 2012) (appellate standard for upholding jury verdict when substantial evidence supports it)
- State v. Castaneda, 621 N.W.2d 435 (Iowa 2001) (definition of relevance under Iowa evidence rules)
- Godfrey v. State, 962 N.W.2d 84 (Iowa 2021) (judicial estoppel prevents a party from asserting a position contrary to one previously successfully taken)