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State of Iowa v. Mawea Rial Koat
Citation: Not availableDocket: 18-1984
Court: Court of Appeals of Iowa; January 22, 2020; Iowa; State Appellate Court
Original Court Document: View Document
Mawea Koat was convicted of operating while intoxicated (third offense) after a jury trial. He subsequently filed a motion for a new trial, claiming that the verdict was against the weight of the evidence, which the district court denied. On appeal, Koat argued that the court abused its discretion in denying the motion and that it applied an incorrect standard in its ruling. The appellate court reviews such denials for abuse of discretion, which occurs only under clearly untenable or unreasonable grounds. A verdict can be overturned if it is contrary to the weight of the evidence, indicating a miscarriage of justice may have occurred. Koat specifically challenged the evidence supporting the claim that he was under the influence of alcohol while operating the vehicle. Evidence presented included testimony from Officer Brady Farrington, who conducted a traffic stop after noticing Koat's vehicle had a broken rear-license-plate light and the owner had an out-of-state arrest warrant. During the stop, Koat exited the vehicle and failed to follow commands. Farrington noted Koat's slurred speech, bloodshot eyes, and the smell of alcohol, leading him to conclude that Koat was intoxicated. Koat refused to perform field sobriety tests and declined both preliminary and chemical breath tests. The only evidence at trial consisted of Farrington's testimony and video footage from his patrol car and body camera. The appellate court ultimately affirmed the district court's decision. The district court did not abuse its discretion in denying Koat's motion for a new trial, as the verdict aligned with the weight of the evidence, which is not an uncommon situation. Farrington’s testimony was found to be consistent and credible, supported by squad-car and body-camera footage that corroborated Koat's actions. Koat argued that the court failed to recognize that a greater amount of credible evidence supported a guilty finding, citing that the court only stated there was "sufficient" evidence. However, the court's lengthy discussion on the new-trial standard indicated it did not apply a sufficiency-of-the-evidence standard to Koat’s motion. The court affirmed that the trial court's discretion should be exercised in the interest of justice, stating that a new trial could be granted only if the verdict was against the weight of the evidence and a miscarriage of justice may have occurred. Ultimately, the district court concluded that, despite the close nature of the evidence, it supported the jury's finding. The court correctly applied the weight-of-the-evidence standard, leading to the affirmation of the denial of Koat's motion for a new trial.