State of Iowa v. Jason Allen Wing

Summary

The Supreme Court of Iowa held that Jason Allen Wing’s encounter with law enforcement constituted an arrest for purposes of Iowa’s speedy-indictment rule. Because the State filed the criminal complaint and trial information more than forty-five days after the arrest, the court reversed the district court’s judgment and remanded the case.

Holdings

1. Wing was arrested on July 7, 2007, for purposes of Iowa Rule of Criminal Procedure 2.33(2)(a).
2. The State violated Iowa Rule of Criminal Procedure 2.33(2)(a) because it did not file a timely indictment or trial information within forty-five days after Wing's arrest.

Questions Presented

1. Whether Wing's encounter with law enforcement constituted an arrest for purposes of Iowa Rule of Criminal Procedure 2.33(2)(a).
2. Whether the trial information filed approximately six months after the July 7, 2007 encounter was untimely under the forty-five-day speedy-indictment rule.
3. Whether later transportation to Wing's home and discussion of cooperation prevented the speedy-indictment clock from beginning when Wing was handcuffed, Mirandized, searched, and placed in the patrol car.

Disposition

reversed_and_remanded