L AW U PDATE HIGHWAY SAFETY May 15, 2012 Office of the Prosecuting Attorneys Training Coordinator “Failure to control” legislation expands scope of statute The legislature made significant changes to Iowa Code section 321.288, the “failure to control” law. The changes contained in HF 2228 will be effective July 1. Currently, the statute requires that a driver control a vehicle “at all times and reduce speed” when encountering one of six specific situations: approaching and passing a pedestrian on the highway, approaching and passing an animal on the highway, approaching “and traversing a crossing or intersection. . .or a bridge, sharp turn, curve, or steep descent. . .”, approaching and passing an emergency warning device or emergency vehicle with lights activated, approaching and passing a vehicle with a slow moving vehicle sign, and approaching and passing through a work zone. See Iowa Code section 321.288, subsections 1-6. The new statute makes the duty to control a vehicle independent of any of the six situations described above. Failure to control a vehicle is a traffic offense on its own. Failure to reduce speed in one of the six specific situations is a separate traffic offense. A portion of the “enrolled bill” version of HF 2288 (with strikethroughs showing language which is deleted, and underlining showing new language) reads as follows: “Sec. 2. Section 321.288, Code 2011, is amended to read as follows: 321.288 Control of vehicle == reduced speed. 1. A person operating a motor vehicle shall have the vehicle under control at all times and. 2. A person operating a motor vehicle shall reduce the speed to a reasonable and proper rate: 1. a. When approaching and passing a person walking in the traveled portion of the public highway. 2. b. When approaching and passing an animal which is being led, ridden, or driven upon a public highway. 3. c. When approaching and traversing a crossing or intersection of public highways, or a bridge, sharp turn, curve, or steep descent, in a public highway. 4. d. When approaching and passing an April/May, 2012 emergency warning device displayed in accordance with rules adopted under section 321.449, or an emergency vehicle displaying a revolving or flashing light. 5. e. When approaching and passing a slow moving vehicle displaying a reflective device or alternative reflective device as provided by section 321.383. 6. f. When approaching and passing through a sign=posted road work zone upon the public highway.” In another section of HF 2288, punishment is increased for persons who violate Iowa Code section 321.323A by improperly approaching and passing stationary emergency vehicles which are displaying flashing lights. A new subsection to 321.323A increases the fine for violations resulting in personal injury or death, and the bill also increases license sanctions for violations resulting in property damage or personal injury or death. INSIDE THIS ISSUE 1 “Failure to control” legislation expands scope of statute 2 “K-2/Spice/Bath Salts” 2 Registration form: Iowa Acts of Interest for Law Enforcement Workshops 2 Published Opinion of the Iowa Supreme Court 3 Published Iowa Cases of Interest 4 Recent Unpublished Opinions Involving Alcohol & Traffic Safety 7 HSL Update 1 Citations from previous issue of the HSLU “K-2/Spice/Bath Salts” Synthetics list increased, ‘effective immediately’ In the closing days of the session, the legislature added several new synthetic controlled substances to Chapter 124 in a bill to be effective upon Governor Branstad’s signature. The bill adds to the list of bath salts and synthetic cannabinoids first outlawed in legislation passed in 2011. The 2011 bill (found at 2011 Iowa Acts, Chapter 134, section 18) added two synthetics known as “bath salts”, two natural substances (salvia divinorum and slavinorin A), and six identified synthetic cannabinoids (with many “brand” names, but generically called “K-2” or “Spice”). The 2012 bill, SF 2343, maintains the substances outlawed in 2011, adds a definition for the term “cannabimimetic agent”, and includes in that definition a phenol, an indole, a pyrrole, an indene, and 3-phenylacetylindole or 3benzoylindole (and in all cases qualifies the substance by commenting on whether certain atomic substitutions were or were not made during manufacture). In addition, the 2012 bill adds eleven more specifically named synthetic cannabinoids to the 2011 list. The 2012 bill also increases the number of “bath salts” from those outlawed in 2011. The two “bath salts” identified in 2011 (mephedrone, also known as 4-methylmethcathinone,(RS)-2-methylamino-l-(4-methylphenyl) propan-1-one, and methylene-dioxypyrovalerone(MDPV)[(1-(1,3-Benzodioxol-5-yl)-2-(1-pyrrolidinyl)-1- pentanone) are maintained on this year’s list. In addition, 24 new “cathinones” are identified as illegal. REGISTER NOW! 2012 Iowa Acts of Interest for Law Enforcement Workshops June 20th Holiday Inn Coralville June 22nd Gateway Center Ames REGISTRATION FORM ATTACHED Published Opinion: Iowa Supreme Court Public interest/public ‘need’ in traffic situation too insubstantial to support community caretaking; stop not justified State v. Kurth, ___ N.W.2d ___ (Iowa, 5/11/12) (No. 11-0525, Iowa Supreme Court, filed May 11, 2012.) Justice Mansfield. Officers heard a crash and saw a car “enveloped in a cloud of dust or smoke” driving on the roadway. Officers then saw a road sign in the traveled portion of the roadway, and determined that the car they had observed had probably hit the sign while it rested in the roadway but not been responsible for knocking it down. An officer followed the car and observed no traffic violations and observed no problems with the car’s “drivability.” The car Continued on page 3 HSL Update 2 Back to page 1 • pulled into a parking lot and parked, and the officer followed the car into the parking lot and observed some minor damage to the front of the car. The officer then pulled up behind the car, blocked it, and turned on his emergency lights. The officer approached the driver and told him of the damage to the car, and then observed signs of intoxication on the driver, who was ultimately arrested for OWI. He filed a motion to suppress, arguing that the officer had no grounds to stop him (the officer’s actions of blocking the car and turning on the emergency lights were a show of authority—a “stop”—which triggered search and seizure analysis). The State resisted the motion, arguing that the officer’s actions were permitted under the “community caretaking” exception to the warrant requirement. The trial court agreed with the State’s position and denied the motion to suppress. The defendant was found guilty of OWI and appealed. The Iowa Supreme Court reversed. When an officer seizes someone in this type of presumptively non-criminal situation, courts must ask if the police conduct was “bona fide community caretaker activity” and if so, whether the public need and interest outweighed the intrusion upon the privacy of the citizen. In the context of an automobile stop or search, cases have identified three bona fide community caretaking activities undertaken by police: impoundment and inventory of a vehicle, providing emergency aid, and acting as a “public servant”—engaging in activity “totally divorced from the detection, investigation, or acquisition of evidence” of a crime. In this case, because officers had determined that the defendant had not hit the road sign and had determined (by following the car) that the car was drivable, the officer’s action in blocking the car and turning on emergency lights “exceeded the scope of bona fide community caretaking activity.” The Court reversed the conviction. Note: Three practice pointers from this case: 1) any time an officer activates emergency lights/sirens or blocks a car from moving, a “stop” has occurred which must be justified under search and seizure analysis; 2) if the officer had simply walked up to the car in the parking lot and engaged the driver in a conversation, without using lights or blocking the car, no “stop” would have occurred; and 3) community caretaking remains a viable legal theory for justifying police activity, but there are cases where the public need/interest is not weighty enough to justify stopping a citizen. Published Iowa Cases of Interest Ethics Iowa Supreme Court Attorney Disciplinary Bd.v. Kallsen, ___ N.W.2d ___ (Iowa, 4/27/12) Lawyer suspended for one year for procuring forged guilty plea documents to OWI 2nd offense, and then filing those documents on behalf of a client (interestingly, the client did not contact an attorney but instead reported to jail, served seven days and only then protested the procedure by filing a post conviction relief action.) Speedy indictment Ennenga v. State, ___ N.W.2d ___ (Iowa, 5/4/12) Defendant’s right to be charged by trial information which was “found” within 45 days of arrest violated where, although the State provided defendant and counsel with a copy of a trial information signed by a judge within 45 days of arrest, the State failed to file the document with the clerk until after the 45 days had expired (and therefore, the trial information was not “found” within 45 days); defense counsel was ineffective for failing to file a motion to dismiss but instead allowing the defendant to plead guilty to a negotiated plea; the Court determined that if a motion to dismiss for failure to honor the 45 day rule had been filed, the motion would have been granted, and therefore the guilty plea which was ultimately entered was not voluntary or intelligent because the defendant “would not have pled guilty. . .if he had known that the court would have been required to dismiss the charges. . .” Note: when a concern arises as to whether a trial information was timely filed/”found”, a prosecutor should review Iowa Code section 4.1(34), and consider whether shortened hours in the offices of clerks of court may be a basis for arguing that a filing deadline should be extended by one day. HSL Update 3 Back to page 1 • (Recent Unpublished Decisions Arranged by County) RECENT UNPUBLISHED DECISIONS INVOLVING ALCOHOL AND TRAFFIC SAFETY Citation of unpublished cases is governed by I.R.App.Pro. 6.904(2)(c), which provides that unpublished opinions do not constitute binding authority and requires that when citing an unpublished opinion, a party include an electronic citation where the opinion can be readily accessed on-line. (Note: all opinions may be accessed online in the Archives section of Opinions of the Iowa Court of Appeals or Supreme Court, at http://www.iowacourts.gov/). Peter J. Grady [email protected] Office of the Prosecuting Attorneys Training Coordinator st 1 Floor, Hoover Bldg. Des Moines, Iowa 50319 Phone: (515) 281-5428 Bremer County State v. Linda Sue Miller, (No. 2-059 / 11-0610, Iowa Court of Appeals, filed February 29, 2012.) In supplying alcohol cases, State must show affirmative delivery or transfer. State must show actual delivery or transfer of alcohol to minors; allowing or permitting consumption on the premises is not enough for culpability; here, trial counsel was ineffective for agreeing to a jury instruction which “permitted the jury to find (the defendant) guilty for any act causing serious injury (to the victim), not specifically the act of supplying alcohol. . .”; the objectionable instruction allowed a conviction on the basis of the defendant permitting a drinking party at her home and leaving the party without supervision; conviction reversed. Buena Vista County State v. Scott Dwayne Banks, (No. 2-016 / 11-0429, Iowa Court of Appeals, filed February 29, 2012.) Smell of marijuana supports Terry stop. The smell of burnt marijuana coming from the defendant and from an apartment the defendant had just vacated, as well as the action of an unknown person shutting the door behind the defendant supported a Terry stop/detention (including handcuffing of the defendant) for purposes of further investigation. Buena Vista County State v. Scott Dwayne Banks, (No. 2-016 / 11-0429, Iowa Court of Appeals, filed February 29, 2012.) Terry weapons pat down justified. Officer’s recollection of past instances where defendant had used a weapon (not corroborated by another testifying officer) together with third officer’s testimony that in his experience, “weapons go hand in hand with drug use” (the smell of marijuana had been detected) and the fact that someone had locked the door to the apartment the defendant had just vacated, could be heard moving around, and refused officers’ request to open the door provided sufficient suspicion to believe the defendant was armed and supported Terry pat down. (Note: Judge Danilson dissented, finding insufficient facts of dangerousness to support the pat down.) Buena Vista County State v. Scott Dwayne Banks, (No. 2-016 / 11-0429, Iowa Court of Appeals, filed February 29, 2012.) Terry search led to probable cause search. Officer’s Terry pat down of defendant revealed “the crunch or crinkle of plastic”; officer could smell burnt marijuana from the defendant’s person as well as from the apartment the defendant had just vacated, and officer knew from experience that marijuana is routinely packaged in plastic baggies; although the officer could have been wrong, “absolute certainty is not required” for a probable cause search, and probable cause supported the officer’s seizure of marijuana from the defendant. (Note: Judge Danilson dissented, arguing that even if the pat down was permissible, the officer needed to have immediately concluded that the defendant had marijuana in his pocket in order to justify the pocket search and seizure of the marijuana.) Clinton County State v. Maurice M. Fort and Ethan S. Nissen, (No. 1-850 / 10-1706, Iowa Court of Appeals, filed February 29, 2012.) Use of incorrect search warrant form. Search warrant form which required specific credibility finding did not account for a 1998 law change which no longer requires such a separate finding; “the district court focused on the form completed by the (issuing magistrate) rather than the information ‘supplied in support of the application’” as now required by amended Iowa Code section 808.3; case remanded to district court for consideration using the proper legal standard. Johnson County State v. Aaron Brewington, No. 2-239 / 11-1477 (Iowa Court of Appeals, filed April 25, 2012.) First offense OWI sentence affirmed; trial court exercised its discretion. Sentence of 365 days with all but 90 suspended affirmed; trial court considered all relevant factors in deciding upon the sentence; court’s suggestion it might reconsider the sentence if correctional services determined that residential placement would be appropriate was not evidence that the trial court was unaware of its sentencing options. Continued on page 5 HSL Update 4 Back to page 1 • RECENT UNPUBLISHED DECISIONS INVOLVING ALCOHOL AND TRAFFIC SAFETY Citation of unpublished cases is governed by I.R.App.Pro. 6.904(2)(c), which provides that unpublished opinions do not constitute binding authority and requires that when citing an unpublished opinion, a party include an electronic citation where the opinion can be readily accessed on-line. (Note: all opinions may be accessed online in the Archives section of Opinions of the Iowa Court of Appeals or Supreme Court, at http://www.iowacourts.gov/). Peter J. Grady [email protected] Office of the Prosecuting Attorneys Training Coordinator st 1 Floor, Hoover Bldg. Des Moines, Iowa 50319 Phone: (515) 281-5428 Johnson County State v. Myron Javon Richardson-Rivers, No. 2-205 / 11-1220 (Iowa Court of Appeals, filed April 25, 2012.) Possession of alcohol charges for those under 18 must be brought in juvenile court. State cannot delay filing possession under the legal age until a person reaches 18 (and thereby bypass juvenile court); “adult” court sanctions are for persons 18, 19, and 20, and there is no “adult” court sanction for a person under the age of 18; those charges are to be handled exclusively in juvenile court. Johnson County State v. Charles Renardo Woods, No. 2-295 / 11-1021 (Iowa Court of Appeals, filed May 9, 2012.) Counsel ineffective for failure to object to breach of plea agreement. Defense counsel was ineffective for failing to object to the State’s breach of plea agreement (State agreed to recommend 180 days, all but 7 suspended for OWI 2nd but at sentencing recommended two years with all but 7 suspended.) Johnson County State v. Charles Renardo Woods, No. 2-295 / 11-1021 (Iowa Court of Appeals, filed May 9, 2012.) Resentencing ordered despite receipt of sentence that was less than originally bargained for. Where the State agreed to recommend 180 days, all but 7 suspended on an OWI 2nd but actually recommended two years, with all but 7 days suspended, the defendant was entitled to resentencing even though the court ultimately ordered 90 days with all but 7 suspended; (“we cannot know what sentence the court would have imposed had the State fulfilled its obligation. . . (t)hus, in an abundance of caution, we remand for resentencing.”) Lee County State v. Donnie Ray Rose, (No. 2-010 / 11-0243, Iowa Court of Appeals, filed February 29, 2012.) “Furtive movements” by passenger and suspicious circumstances support Terry car pat down. Officer observed van parked by the side of the road “in a remote, unusual place at an unusual time, on a Sunday” and had non-verbal communication with the driver; officer later observed a passenger (who may have been hiding earlier) place something between the front seats; Terry pat down of the area between the front seats was limited in scope and supported by reasonable articulable suspicion (court does not reach issue of whether furtive movements alone would have supported the search; defendant did not challenge the validity of the stop, which was based upon a failure to stop at a stop sign.) Madison County State v. Matthew Dee Butcher, No. 2-201 / 11-0928 (Iowa Court of Appeals, filed April 25, 2012.) Habitual offender status must appear in the record. A defendant’s habitual offender status is “an essential element of the crime” (citing State v. Cook, 565 N.W.2d 611 (Iowa, 1997)); notation that investigating officer learned that the defendant was “barred” and defendant’s statement in written plea “I drove while barred” are not sufficient to support a guilty plea; case remanded to allow the State an opportunity to provide evidence of the habitual offender status. Madison County State v. Matthew Dee Butcher, No. 2-201 / 11-0928 (Iowa Court of Appeals, filed April 25, 2012.) Eluding requires proof that pursuing officers were operating marked police vehicles and wearing police uniforms. The crime of eluding requires, as essential elements of the offense, that the State prove that pursuing officers were operating marked police vehicles and wearing police uniforms (see Iowa Code section 321.279); defendant’s statement in written plea that he did not stop when “ordered to do so” and the written minutes of testimony were not sufficient to support these elements; case remanded to allow the State an opportunity to provide evidence of the vehicles and uniforms. Madison County State v. Matthew Dee Butcher, No. 2-201 / 11-0928 (Iowa Court of Appeals, filed April 25, 2012.) Ineffective assistance of counsel-factual basis. Trial counsel ineffective for allowing defendant to plead guilty to driving while barred without proof that the defendant was an “habitual offender” and for allowing defendant to plead guilty to eluding without proof that the pursuing officers were in uniform and driving marked vehicles. Continued on page 6 HSL Update 5 Back to page 1 • RECENT UNPUBLISHED DECISIONS INVOLVING ALCOHOL AND TRAFFIC SAFETY Citation of unpublished cases is governed by I.R.App.Pro. 6.904(2)(c), which provides that unpublished opinions do not constitute binding authority and requires that when citing an unpublished opinion, a party include an electronic citation where the opinion can be readily accessed on-line. (Note: all opinions may be accessed online in the Archives section of Opinions of the Iowa Court of Appeals or Supreme Court, at http://www.iowacourts.gov/). Madison County State v. Matthew Dee Butcher, No. 2-201 / 11-0928 (Iowa Court of Appeals, filed April 25, 2012.) State’s remedy when sentence vacated for incomplete factual basis for plea. “(I)f it is possible for the State to still establish a factual basis to support the guilty plea, we vacate the sentence and remand to the district court to give the State an opportunity to establish a factual basis.” Marion County Justin Ricardo Franklin v. Iowa Department of Transportation, No. 2131 / 11-0599 (Iowa Court of Appeals, filed May 9, 2012.) Substantial evidence supports “operation”; license revocation affirmed. Substantial evidence in the record supported the DOT’s determination that an intoxicated passenger who grabbed the wheel and caused the vehicle to cross the center line “operated” the vehicle within the meaning of the OWI law; license revocation for OWI affirmed. Palo Alto County In Re: the Estate of Addison Fischer, etc. v. Dyno Oil, Inc., a Duly Registered Corporation d/b/a/ Dyno’s Amoco, (No. 1-963 / 11-0452, Iowa Court of Appeals, filed February 29, 2012.) No dram shop coverage for death of teen where alcohol sold, not served. Gas station employee knowingly sold and gave alcohol to a person known to be underage who died in a crash with an alcohol level of .177; gas station was properly granted summary judgment as not liable to the teen’s estate; the station sold, but did not serve the alcohol, and Iowa dram shop law does not cover sales for off-premises consumption; previous cases have rejected constitutional challenges to the dram shop law and have determined that the legislature has limited recovery in these cases to statutory recovery; therefore, no common law cause of action can proceed. Polk County Steven Elliott and Diane Elliott v. Hughbis & The Kernal, Inc. d/b/a/ Hugh’s Jungle Room, (No. 2-098 / 11-0983, Iowa Court of Appeals, filed February 29, 2012.) Dram shop default judgment upheld. Where defendant corporation had identified an agent for service of process and the plaintiffs (injured by an intoxicated driver) had properly served the agent and, at a later hearing, proved up their damages, a default judgment of $1,133,776.81 was properly entered against the corporation and the trial court did not abuse its discretion in denying the corporation’s motion to set aside the default judgment. Peter J. Grady [email protected] Office of the Prosecuting Attorneys Training Coordinator st 1 Floor, Hoover Bldg. Des Moines, Iowa 50319 Phone: (515) 281-5428 Polk County Casey J. Rooker v. Flanagan Corporation d/b/a/ Tim Flanagan’s Restaurant & Lounge and Timothy J. Flanagan, No. 2-147 / 11-1291 (Iowa Court of Appeals, filed April 25, 2012.) Common law claim by injured, drinking minor permitted against individual who provided the alcohol. An injured underage drinker may state a common law cause of action against an individual who, although the owner of a bar where the drinking occurred, conceded that he was a nonlicensee/social host for summary judgment purposes. Polk County State v. David Gonzales-Vera, No. 2-266 / 11-1233 (Iowa Court of Appeals, filed May 9, 2012.) Reasonable suspicion for stop based on burglary investigation. An officer who, within minutes of the report of a silent alarm at a business arrived and observed no vehicles in or around the location but shortly thereafter saw the defendant’s vehicle pull out from behind the business, had a reasonable basis for believing that “a burglary was occurring and (the defendant) was involved”; trial court properly denied motion to suppress, OWI conviction affirmed. Polk County State v. Tommy Tyler Jr., No. 2-231 / 11-1065 (Iowa Court of Appeals, filed May 9, 2012.) Tinted license plate cover provides basis for stop. Officer who observed a tinted plate cover which obscured viewing of the plate had probable cause to believe the defendant was violating Iowa Code section 321.37(3) (“. . . unlawful for the owner of a vehicle to place any frame around or over the registration plate which does not permit full view of all numerals and letters printed on the registration plate”); motion to suppress properly denied, and OWI 2nd conviction affirmed. Continued on page 7 HSL Update 6 Back to page 1 • RECENT UNPUBLISHED DECISIONS INVOLVING ALCOHOL AND TRAFFIC SAFETY Citation of unpublished cases is governed by I.R.App.Pro. 6.904(2)(c), which provides that unpublished opinions do not constitute binding authority and requires that when citing an unpublished opinion, a party include an electronic citation where the opinion can be readily accessed on-line. (Note: all opinions may be accessed online in the Archives section of Opinions of the Iowa Court of Appeals or Supreme Court, at http://www.iowacourts.gov/). Poweshiek County State v. John Paul Thompson, No. 2-026 / 11-0860 (Iowa Court of Appeals, filed April 11, 2012.) PBT calibration log was in substantial compliance with regulations; implied consent properly invoked. Where defendant failed sobriety testing and the PBT, and where the calibration log for the PBT was up to date in all respects except that it did not contain information on the “value and type of standard used” for calibration, reliance on the failed PBT to invoke implied consent was proper; suppression ruling reversed, and case remanded for further proceedings. Story County State v. Chao Zhang, (No. 2-070 / 11-1367, Iowa Court of Appeals, filed February 29, 2012.) Immigration notice in guilty plea which does not track language of the rule may be ineffective assistance of counsel. Guilty plea for a foreign national which stated “I understand that a criminal conviction, deferred judgment or deferred sentence may affect my status under federal immigration law” did not properly track the statement required by I.R.Crim.Pro. 2.8(2)(b)(5) which provides that such pleas must contain a statement “that conviction of a crime may result in the defendant’s deportation or other adverse immigration consequences”; except for the written plea, the record did not provide evidence that counsel advised the defendant of potential immigration consequences, nor did it show that the defendant suffered any adverse consequences, or show that, if counsel had advised the defendant differently, he would not have pleaded guilty; conviction affirmed and issue of possible ineffective assistance of counsel preserved for post-conviction relief. Citations from previous issue of the Highway Safety Law Update State v. Tanksley, 809 N.W.2d 706 (Minn., 2/8/12) State v. Adams, 810 N.W.2d 609 (Iowa, 1/20/12) State v. Breuer, 808 N.W.2d 195 (Iowa, 1/6/12) Peter J. Grady [email protected] Office of the Prosecuting Attorneys Training Coordinator st 1 Floor, Hoover Bldg. Des Moines, Iowa 50319 Phone: (515) 281-5428 Prepared by the Prosecuting Attorneys Training Coordinator (PATC) Under a project approved by the Governor’s Traffic Safety Bureau (GTSB), in cooperation with the National Highway Traffic Safety Administration (NHTSA). The opinions, findings, and conclusions expressed in this publication are those of the author and not necessarily those of the PATC, GTSB, NHTSA, or the Iowa Department of Justice. Readers with too much time on their hands will note that this issue reports cases decided February 29, 2012, but does not include any cases decided in March 2012. What gives? Well, in the last newsletter, published at the end of March, all of the March cases (as well as most of the February cases) were included in the issue. However, the cases from February 29, 2012 were left out because the editor did not proofread his final draft before publication. And in fact, not only did he not proofread the final draft before publication, he didn’t even bother read it after publication and wasn’t even aware of the omission until 2 or 3 weeks later, when a reader with too much time on his hands called the editor and complained. On the one hand, it is nice to have faithful readers. On the other hand—give me a break! Submissions and / or comments may be sent to: Peter Grady, PATC Iowa Dept. of Justice 1st Floor, Hoover State Office Building Des Moines, IA 50319 Phone: 515-281-5428 ~ Fax: 515-281-4313 E-mail: [email protected] HSL Update 7 2012 Iowa Acts of Interest to Law Enforcement Sponsored by Office of the Prosecuting Attorneys Training Coordinator Iowa County Attorneys Association Iowa Department of Public Safety The Wednesday, June 20th workshop will be at the Holiday Inn and Conference Center in Coralville. The Holiday Inn is located north of I80 at Exit 242. The Friday, June 22nd workshop will be at the Gateway Center in Ames. The Gateway Center is located at 2100 Green Hills Drive in Ames. The workshops will provide an overview of 2012 legislation, as well as new issues in Criminal Law. Registration begins at 8:30 a.m. and the Workshop starts at 9:30 a.m. Refreshments and lunch will be provided. Registration Fee: $60.00 Payable to Iowa County Attorneys Association (ICAA) Mail/Fax to: Peg Bowman Phone: 515-281-5428 Prosecuting Attorneys Training Coordinator Fax: 515-281-4313 Hoover Building, 1st Fl., Des Moines, IA 50319 E-Mail: [email protected] Name:_________________________________________________ Agency:________________________________________________ Address:_______________________________________________ City:___________________________________________________ Zip: ___________Phone:_______________Fax:________________ E-Mail:_________________________________________________ Workshop Location ____June 20 Coralville ____ June 22 Ames There will be a $25.00 fee applied to cancellations received after June 8, 2012 and for any registrants who fail to attend without cancellation prior to June 8th. The workshops are expected to qualify for CLE credits.
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