Michael Paul Eaton v. State of Iowa

IN THE COURT OF APPEALS OF IOWA
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No. 25-0417
Filed April 15, 2026
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Michael Paul Eaton,
Applicant–Appellant,
v.
State of Iowa,
Respondent–Appellee.
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Appeal from the Iowa District Court for Black Hawk County,
The Honorable Kellyann M. Lekar, Judge.
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AFFIRMED
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Alexander Smith of Parrish Kruidenier, L.L.P., Des Moines,
attorney for appellant.

Brenna Bird, Attorney General, and Zachary Miller, Assistant Attorney
General, attorneys for appellee.
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Considered without oral argument
by Greer, P.J., and Schumacher and Chicchelly, JJ.
Opinion by Schumacher, J.

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SCHUMACHER, Judge.

Michael Eaton appeals the district court’s denial of his application for
postconviction relief (PCR) following his 2021 convictions for escape as a
habitual offender, driving while barred, and interference with official acts
resulting in bodily injury. Eaton raises claims of ineffective assistance of
counsel. Upon our review, we affirm.

I. Background Facts and Proceedings

In its opinion affirming Eaton’s convictions on direct appeal, this court
set forth the following facts:
Sheriff Deputy Chad Chase was patrolling in Waterloo when he
saw a driver in a white Charger cover his face while Chase drove by. He
followed and determined the vehicle belonged to a person whose son,
Eaton, had an active warrant for his arrest because of a probation violation
on a felony conviction. He confirmed the photograph of Eaton matched the
person he saw trying to hide his face in the Charger. Eaton’s Charger was
stopped in the small parking lot of a collectibles shop and, after circling a
few times, Chase pulled in after him, blocking the entrance with his patrol
vehicle.

Chase testified he exited his vehicle as Eaton was walking toward
the shop. He said, “Michael, stop,” and Eaton changed direction and
walked toward the back of the building. Chase pulled out his taser and
followed Eaton behind the building. Eaton told Chase that he was “not
Michael.” Chase said he would shoot if he did not stop. At the point of his
taser, Chase walked Eaton backed to the Charger and had him sit in the
front seat with the door open, which he “figured . . . was the safest spot at
that point.” Eaton’s girlfriend, Heather Glaspie, was in the passenger seat
of the Charger, and Chase asked for her identification. Standing so the car
door remained open, Chase testified Eaton “was detained at that point. He
was not going to leave.” While Chase intended to place Eaton in handcuffs,
he wanted to wait for another officer to arrive to do so safely.

Radioing with dispatch, Chase took a few steps toward the back of
the car to get the license plate number. In that short time, Eaton closed and

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locked the driver door. The window was about half down, and Chase began
“yelling through the window, telling him to unlock the door, open the
door.” But Eaton put the Charger in reverse and backed out of his parking
spot while Chase yelled at him to stop. Chase stood right outside the
driver’s door, pointed his taser at Eaton, threatened to shoot him, and
yelled at him to stop and turn the car off. When Eaton did not comply,
Chase shot him with the taser, which caused Eaton to “stomp on the gas,”
reversing and crashing into Chase’s patrol vehicle. The taser stopped
working after a few seconds. Eaton then put the car in drive and pulled
forward into the parking lot but had no space to exit. Chase followed and
shot the taser again but missed this time. Eaton quickly reversed, driving
over the lawn to get out of the parking lot. Chase followed, this time
pointing his gun. Glaspie was screaming from the passenger seat “don’t
shoot.” Chase had to jump out of the way as Eaton then drove off. Video
of most of the event was captured on Chase’s dashboard camera, but no
audio of the incident was recorded. The next day, officers located the
Charger with a broken taillight in a garage and Eaton hiding in Glaspie’s
apartment under a pile of clothing. Taser wires were found on the floor of
the Charger.

At trial, Glaspie testified both she and Eaton knew he was wanted
on the warrant. She was waiting in the Charger outside the shop and saw
Chase circling the parking lot. She called Eaton, who was inside the shop,
and told him about it, which is when he came out. When asked whether
she believed Eaton was “free to leave that area,” Glaspie testified, “He was
obviously being under—put under arrest for an officer to stop, and he had
a warrant . . . .” Another witness from inside the collectibles shop testified
Eaton received a phone call from someone labeled “Heather” who said,
“cops have gone by a couple times, that [Eaton] needed to get out of
there.”

State v. Eaton, No. 21-1405, 2023 WL 152654, at *1–2 (Iowa Ct. App. Jan. 11,
2023). The court rejected Eaton’s challenges to the jury instruction on appeal
and the sufficiency of the evidence supporting his escape conviction. Id. at
*2–5.

Eaton filed a PCR application several months later, raising claims of
ineffective assistance of counsel. His application was amended later by

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counsel. Following a hearing, the district court denied the application. Eaton
now appeals.

II. Standard of Review

“We review de novo PCR claims of ineffective assistance of counsel.”
Trane v. State, 16 N.W.3d 683, 692 (Iowa 2025). “On de novo review, ʻwe give
weight to the lower court’s findings concerning witness credibility.’ But we
are not bound by the lower court’s determination.” Sothman v. State, 967
N.W.2d 512, 522 (Iowa 2021) (citation omitted).

III. Analysis

Eaton claims his counsel was ineffective by failing to challenge the
escape marshalling instruction “based on the correct definition of ʻarrest’
under Iowa Code § 804.14 [(2020)]” and by failing “to ask for a pretrial
determination of the jury instructions, undermining the knowing, intelligent,
and voluntary nature of Eaton’s decision whether to plead guilty.” To prevail
on either claim, Eaton must prove (1) counsel’s performance fell below
objectively reasonable standards and (2) if counsel had acted differently,
there would have been a reasonable probability of a different outcome at trial.
Strickland v. Washington, 466 U.S. 668, 687–88, 694 (1984).

Turning to Eaton’s first claim, he has the burden to show both that the
instruction provided was “in error” and that the escape “did not occur as a
matter of law.” See Briggs v. State, No. 0-147, 2000 WL 700311, at *4 (Iowa
Ct. App May 31, 2000).

Our court has already determined “the arrest instruction conveyed a
clear understanding of the arrest issue.” Eaton, 2023 WL 152654, at *2–4.
Specifically, on direct appeal, Eaton challenged the escape instruction based
on the definition of arrest, and this court rejected his claim. See id. at *4

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(finding no error in the court giving the instruction to the jury). Accordingly,
Eaton’s claim fails on the first prong. Briggs, 2000 WL 700311, at *4; see also
State v. Dudley, 766 N.W.2d 606, 620 (Iowa 2009) (“[C]ounsel has no duty
to raise an issue that has no merit.”); Anfinson v. State, 758 N.W.2d 496, 499
(Iowa 2008) (“We may affirm the district court’s rejection of an ineffective-
assistance-of-counsel claim if either element is lacking.”).

Turning to Eaton’s second claim, at the PCR hearing, Eaton agreed
that he rejected a plea offer before trial. But Eaton testified that his trial
counsel “should have sought some relief on [how the definition of the jury
instructions should work] before trial so that [he] understood what was going
to happen at trial.” Trial counsel testified that she “spent quite a bit of time
talking about the strategy in the case” with Eaton. Trial counsel explained
that they “agreed” their defense strategy would focus on arguing that Eaton
“wasn’t yet in custody to have escaped from it.”

Trial counsel explained why she did not attempt to obtain a pretrial
ruling “on the definition” of “the parameters of custody and arrest”:
[T]here’s a couple of reasons. I can’t think of—I probably couldn’t count
on more than five fingers the number of times I’ve filed for pretrial
determinations or adjudication of law points, but normally my strategy
would not be to highlight the issues to the State of what we’re going to be
arguing at trial, and that would have done that, and I guess to have the issue
foreclosed upon before trial could have changed every count.

....

I think it would have put [the prosecutor] on notice of what our
issues were going to be, and he might have been more prepared to address
them at trial.

Trial counsel also recalled that Eaton “did not want the plea offer of
the 30 years with the mandatory six because he was already getting probably

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15 on the other case he had pending,” and “our entire goal” “was beat the
felonies.” She further testified that Eaton “was pretty adamant that we were
going to take this one to trial,” so she did not believe a pretrial ruling “would
change anything.” Trial counsel reflected that even “[k]nowing how trial
played out,” she did not believe she would have done anything differently
than she did at the time. We note that Eaton was found not guilty on several
counts.

“The benchmark for judging any claim of ineffectiveness must be
whether counsel’s conduct so undermined the proper functioning of the
adversarial process that the trial cannot be relied on as having produced a just
result.” Strickland, 466 U.S. at 686. We review counsel’s strategy and tactical
decisions to determine whether they were “reasonable under the
circumstances.” See Ledezma v. State, 626 N.W.2d 134, 143 (Iowa 2001).

Here, we concur with the PCR court’s determination that trial counsel
“made a reasonable strategic decision not to pursue a pretrial determination
so that the defense did not alert the State to intended trial strategy and also
to allow the defense to remain nimble at the time of trial to respon[d] to the
State’s evidence.” Eaton’s claim on this basis fails.

Because Eaton failed to establish ineffective assistance of counsel, we
affirm the denial of his PCR application.

AFFIRMED.

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