State v. Crawford

• Docket Number: 22-1509
• Decision Date: 20 December 2023
• Parties: STATE OF IOWA, Plaintiff-Appellee, v. CALVIN MARCEL CRAWFORD, Defendant-Appellant.
• Court: Iowa Court of Appeals

1

STATE OF IOWA, Plaintiff-Appellee,
v.
CALVIN MARCEL CRAWFORD, Defendant-Appellant.

No. 22-1509

Court of Appeals of Iowa

December 20, 2023

Appeal from the Iowa District Court for Story County, Steven P. Van Marel, District Associate Judge.

A defendant challenges the sufficiency of the evidence supporting his conviction.

Martha J. Lucey, State Appellate Defender, and Ella M. Newell, Assistant Appellate Defender, for appellant.

Brenna Bird, Attorney General, Nick Siefert and Kyle Hanson, Assistant Attorneys General, and Kelly Lynch, Law Student, for appellee.

Considered by Bower, C.J., and Ahlers and Chicchelly, JJ.

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AHLERS, Judge

While on patrol during early morning hours, an Ames police officer observed a vehicle traveling at a high rate of speed on a city street. The officer caught up to the vehicle and initiated a traffic stop. As the officer approached the vehicle, the driver, Calvin Crawford, lowered his window about an inch and stuck his driver's license out. Crawford initially explained his car window did not go down any further, but he eventually lowered it more to show his vehicle insurance information displayed on his cell phone. With the car window lowered more, the officer could smell the odor of alcohol coming from Crawford.

The officer told Crawford to step outside of the vehicle and conducted field sobriety testing, including the horizontal gaze nystagmus test (HGN), the vertical gaze nystagmus test (VGN), the nine-step walk and turn, and the one-leg stand. The officer observed no indication of nystagmus when performing the VGN, but he observed six out of six clues of nystagmus when performing the HGN, which the officer later testified was a failing score.^[1] The officer observed three out of eight clues of intoxication when administering the walk-and-turn test-also a failing score as later testified to by the officer. When administering the one-leg stand, the officer observed one of four clues. At that point, the officer arrested Crawford. At the police station, the officer read the implied consent advisory to Crawford multiple times as Crawford shouted at him. Crawford refused to provide a breath sample for alcohol-concentration testing.

3

The State charged Crawford with operating while intoxicated. The case went to trial, and a jury found Crawford guilty of operating while intoxicated.^[2]

Crawford appeals and challenges the sufficiency of the evidence. We review sufficiency-of-evidence claims for correction of errors at law. State v. Crawford, 972 N.W.2d 189, 202 (Iowa 2022). Jury verdicts bind us if they are supported by substantial evidence. Id. Evidence is substantial if it is sufficient to convince a rational factfinder that the defendant is guilty beyond a reasonable doubt. Id. In assessing whether evidence is substantial, "we view the evidence in the light most favorable to the State, including all 'legitimate inferences and presumptions that may fairly and reasonably be deduced from the record evidence.'" Id. (quoting State v. Tipton...