Background
Curtis Lloyd was under investigation for multiple offenses, including felon-in-possession, in 2019 by Waterloo police. Police had previously obtained buccal swabs from Lloyd in an unrelated sex-abuse investigation and informed him they were awaiting DNA results for a charging decision. After a shooting in August 2019, Lloyd was questioned by police at Allen Hospital. DNA results became available in late 2019, leading police to obtain arrest warrants for both the initial case and the felon-in-possession charges.
Following his release from the hospital, police were unable to locate Lloyd despite efforts, publicly identifying him as a “most wanted” suspect and listing him on Cedar Valley Crimestoppers. In 2022, officers learned via social media that Lloyd might be in Wisconsin but failed to pinpoint his location. The county attorney filed a trial information for the gun charge in July 2022. In 2024, Arizona authorities apprehended Lloyd on a nationwide warrant, and he was extradited to Iowa.
Lloyd moved to dismiss the gun charge, asserting a violation of his speedy trial rights. He argued that police could have located him in another Iowa county for medical treatment following August 2019, but he presented no evidence to support this claim.
The Court’s Holding
The Iowa Court of Appeals affirmed the district court’s decision, finding no abuse of discretion in the district court’s determination of “good cause” for the delay in bringing Lloyd to trial. The district court had found that Waterloo police “made efforts to locate [Lloyd] during the intervening time” between the July 2022 trial information and his July 2024 extradition, and that Lloyd was aware of the investigation against him.
The appellate court emphasized that the State’s duty to provide a speedy trial “does not require that it play a game of hide-and-go-seek” with a defendant. It deferred to the district court’s factual findings, including the credibility of police testimony regarding their search efforts. The court rejected Lloyd’s argument regarding the county attorney’s “misunderstanding of the law” on the statute of limitations, finding that this argument was not preserved for appeal as it was not raised and ruled upon below.
Additionally, the court noted that even if establishing fault was required for a good-cause finding, Lloyd’s act of absconding from the State while knowing he was under investigation for felonies clearly contributed to the delay. The court distinguished a prior unpublished case, *State v. Castillo-Alvarez*, noting that in that case, police knew the defendant’s location for years, which was not the situation here where police actively sought Lloyd but could not find him until he was apprehended in Arizona.
Key Takeaways
- The “good cause” exception to speedy trial rights may apply when a defendant is a fugitive and police demonstrate diligent, though unsuccessful, efforts to locate them.
- Appellate courts afford deference to district court findings on factual matters, such as the credibility of witnesses and the diligence of law enforcement.
- Arguments not properly raised and ruled upon at the trial court level are generally considered unpreserved and cannot be challenged on appeal.
- A defendant’s deliberate actions to avoid apprehension while aware of an investigation can be considered in determining whether there was good cause for trial delays.
Why It Matters
This decision reinforces the established legal principle that the State is not obligated to ceaselessly pursue a defendant who actively evades law enforcement while knowing they are under investigation. It clarifies the boundaries of the “good cause” exception to speedy trial rules, particularly in cases involving defendants who become fugitives.
For attorneys, this opinion underscores the critical importance of preserving all legal arguments at the district court level to ensure they can be reviewed on appeal. It also provides insight into the type of police efforts considered diligent enough to establish good cause for speedy trial delays when a defendant’s location is unknown, thereby guiding both prosecutorial strategies and defense challenges in similar cases.