Background
Shane Michael Power was convicted in Linn County District Court of driving while barred, an aggravated misdemeanor under Iowa Code sections 321.560 and 321.561.
At trial, video showed Power driving, and certified records established that his license was barred at the time. Power appealed, contending that a deputy’s testimony was too unbelievable to support the conviction and urging a different standard for offenses he characterized as malum prohibitum.
The Court’s Holding
The Iowa Court of Appeals affirmed. It held that the video evidence and certified license records proved the two elements of driving while barred: that Power was driving and that he was barred from driving because his license was suspended.
The court declined to reassess the deputy’s credibility, explaining that appellate courts ordinarily do not substitute their own credibility determinations for those of the fact-finder. It also rejected Power’s proposed malum-in-se/malum-prohibitum distinction because he cited no supporting authority.
Key Takeaways
- Video evidence and certified licensing records were sufficient to support the conviction.
- Appellate sufficiency review ordinarily does not permit the court to reweigh witness credibility.
- An unsupported request for a different legal standard does not establish reversible error.
Why It Matters
The decision underscores that a driving-while-barred conviction may rest on straightforward proof of driving and a barred license status. It also reinforces the limited role of appellate courts in revisiting credibility disputes resolved by the fact-finder.