State v. Koat
| Decision Date | 23 November 2021 |
| Docket Number | 20-1162 |
| Parties | STATE of Iowa, Plaintiff-Appellee, v. Dobol Rial KOAT, Defendant-Appellant. |
| Court | Iowa Court of Appeals |
Martha J. Lucey, State Appellate Defender, and Shellie L. Knipfer, Assistant Appellate Defender, for appellant.
Thomas J. Miller, Attorney General, and Kyle Hanson, Assistant Attorney General, for appellee.
Considered by Tabor, P.J., and Greer and Badding, JJ.
Dobol Koat challenges his conviction for first-degree murder in the stabbing death of William Dut. Neighbors spotted Dut's body in an alley one-half block from the studio apartment where he had been staying with Koat. On appeal, Koat raises three issues. First, Koat contends the district court should have suppressed his statements to police. Second, he argues the State did not offer sufficient evidence to prove his identity as the killer. And third, Koat insists the court should have excluded testimony he was burning clothes in the alley before Dut's murder. Because the district court properly overruled Koat's suppression motion in part, the State offered strong circumstantial evidence of his guilt, and the evidentiary ruling on the burned clothes was not an abuse of discretion, we affirm.
In early October 2019, Dut finished serving a prison sentence for operating while intoxicated, third offense, and moved in with Koat in his Council Bluffs studio apartment. But this arrangement wouldn't last. Less than one month later, passersby discovered Dut's body, wrapped in a sheet, left in the alley near Koat's apartment. Early Monday morning, October 28, two neighbors saw a hand protruding from the bundled sheet but thought the body was a Halloween prop and did not stop. Later that morning, another neighbor checked to see if he could wake the person. He found no pulse. With a fingerprint match, investigators identified the deceased as Dut. When they went to Koat's apartment, they found blood smeared on the door and dried on the concrete walkway. They knocked, but no one answered.
After obtaining a search warrant, police entered, guns drawn, finding a "very calm" Koat sitting in the apartment. Detective Ron Branigan noticed: "Everything in the apartment seemed to be in order." But beneath the outward order was a bloody crime scene. The bed was made with a flat sheet matching the fitted sheet wrapped around Dut's body. When investigators flipped the mattress, they found concentrated blood stains. They also noted "smeared blood on the floor, wiped down blood." Similar streaks of blood appeared on the windowsill near the bed. Their UV light showed strands of what appeared to be blood on a mop in the apartment. Investigators also documented blood spatter on the walls and ceiling. DNA testing confirmed the blood belonged to Dut.
The prevalence of blood in the apartment bespoke the brutality of Dut's injuries. An autopsy detected a dozen stab wounds to Dut's head and neck. One deep gash to his neck extended all the way to his spine. The medical examiner believed the perpetrator used a serrated knife to inflict those stab wounds. But the medical examiner found Dut had no defensive wounds, documenting only a small abrasion on the victim's right hand. Dut also suffered a fractured cheek bone, sternum, and skull from blunt force trauma. This array of injuries led to the State's theory: "Almost certainly William Dut was attacked while he was sleeping."
The parties debated the timing of that attack. Koat focused on the medical examiner's testimony about rigor mortis. When she conducted the autopsy on Tuesday morning, October 29, she noticed "moderate" rigor mortis in all of Dut's extremities. She explained "one of the signs of death is rigor mortis, ... that is as the chemicals that are available to the body for energy begin to dissipate with cell death, then the muscles tighten." She testified rigor mortis generally appears within hours after death and reaches its maximum "in the neighborhood of twelve hours, plus or minus." The condition usually dissipates between thirty-six and seventy-two hours after death, according to the medical examiner. But she also testified rigor mortis is affected by many factors and can be slowed by cool temperatures.1
The State advanced its theory that Koat killed Dut on Friday night, October 25. To support that timing, the prosecutor presented evidence that Dut was planning to move and the property manager showed him a vacant apartment late Friday afternoon. But Dut appeared distressed when the manager's office closed before he could pay the deposit. In a phone conversation around 8:30 p.m., Dut told a friend about plans to move into a new apartment. His friend never heard from Dut again, despite calling and sending messages. An active Facebook user, Dut last accessed the social media network early Friday morning.
Meanwhile, Koat left work early Friday night, clocking out of his shift at 9:51 p.m., after less than an hour on the job. Just after 11:00 p.m., Koat used Dut's cell phone to call a ride-sharing service to report that he'd forgotten his own phone in a Lyft car. Koat was scheduled to work both Saturday and Sunday nights, but he did not show up. His downstairs neighbor was home sick that weekend but did not hear any movement in Koat's apartment, describing it as "dead quiet."
As it turns out, Koat had left town, traveling to Des Moines on Saturday and buying a new cell phone at a local Cricket store. He then went to Marshalltown, staying overnight at the Motel 6 and watching a football game at the Applebee's bar. Records for Koat's new cell phone showed that he traveled back through Des Moines Sunday night and arrived home in Council Bluffs by the early morning hours of Monday, October 28.
After identifying Dut's body in the alley that morning and discovering evidence of the stabbing in the nearby studio apartment, police focused their investigation on Koat. They interviewed him three times: once the afternoon of October 28 at the apartment, about one hour later at the police station, and again on November 26 at the police station. Koat did not admit killing Dut in these interviews. But the State later pointed to lies that Koat told to the police as evidence of his guilty knowledge.
In early December, the State charged Koat with murder in the first degree, in violation of Iowa Code sections 707.1 and 707.2(1) (2019). He moved to suppress the statements he made to police during the three interviews. The district court suppressed the statements from the first interview, but found Koat's statements from the second interview and much of the third interview were admissible. The case proceeded to trial in February 2020. A jury found Koat guilty as charged. The court sentenced him to life in prison without the possibility of parole. He now appeals.
Koat's three claims call for varying standards of review. First, we review his suppression issue de novo to the extent that he raises constitutional claims. See State v. Hillery , 956 N.W.2d 492, 498 (Iowa 2021). But we review a ruling on promises of leniency under the common law evidentiary test for correction of errors at law. Id. Second, we review his challenge to the sufficiency of the evidence for the correction of legal error. See State v. Schiebout , 944 N.W.2d 666, 670 (Iowa 2020). Third, we review the court's admission of evidence over his relevancy objection for an abuse of discretion. Graber v. City of Ankeny , 616 N.W.2d 633, 638 (Iowa 2000).
Koat moved to suppress statements he made to police during three interviews. Koat argued his statements at the apartment were inadmissible because police did not give him Miranda warnings2 before asking him questions. He sought to exclude his statements from the second and third interviews as continuations of that Miranda violation and as involuntary. The district court suppressed the statements Koat made when police questioned him at the apartment. But the court allowed the State to offer statements Koat made after being Mirandized at the police station before the second interview. As for the third interview, the court allowed the State to offer Koat's statements from the first hour of the interview, but suppressed statements made after he invoked his right to counsel. On appeal Koat alleges all of his statements should have been out. We examine each set of statements in turn.
October 28 at the apartment. Once police had a search warrant, three officers entered, guns drawn, into the apartment that Dut shared with Koat. Police handcuffed Koat, but told him that he was not under arrest as they performed a sweep of the apartment. Detective Branigan recorded a three-minute interview with Koat, asking his name, social security number, work schedule, and when he last saw Dut.3 Koat said he worked the night before and arrived home around 6:30 a.m. Koat claimed he last saw Dut on Thursday, three days earlier. Koat explained they worked different shifts and after work Dut would "hang out with his friends" or visit a girlfriend in Omaha. After that brief interrogation, police transported Koat to the police station.
October 28 at the police station. In the late afternoon, about one hour after their first encounter, police conducted another interview with Koat—this time at the station. Once there, Koat received his Miranda warnings and agreed to speak with the detective.
Koat told the detective that he went to work on Friday night and returned Saturday morning to find Dut gone. Koat claimed to have slept all day Saturday before returning to work that night. When he returned home Sunday morning, according to Koat, he showered, slept, and watched television. He said that Sunday night he took a bus to Omaha to see "one of [his] girls." Koat recalled they went to a bar in the Old Market district. But Koat could not tell the detective the name of the girlfriend or the bar. He estimated...
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