State of Iowa v. Rafael Shay Ramirez
CourtCourt of Appeals of Iowa
Date FiledAugust 19, 2026
Docket25-0099
StatusPublished
📰 News Coverage: Read the LAWS.com news report on this case
Full Opinion
IN THE COURT OF APPEALS OF IOWA
_______________
No. 25-0099
Filed August 19, 2026
_______________
State of Iowa,
Plaintiff–Appellee,
v.
Rafael Shay Ramirez,
Defendant–Appellant.
_______________
Appeal from the Iowa District Court for Wapello County,
The Honorable Susan Cole, Judge.
_______________
AFFIRMED
_______________
Austin Jungblut of Parrish Kruidenier L.L.P., Des Moines,
attorney for appellant.
Brenna Bird, Attorney General, and Genevieve Reinkoester, Assistant
Attorney General, attorneys for appellee.
_______________
Considered without oral argument
by Ahlers, P.J., and Buller and Sandy, JJ.
Opinion by Ahlers, P.J.
1
AHLERS, Presiding Judge.
A jury found Rafael Ramirez guilty of possession of
methamphetamine.1 Ramirez filed a motion for new trial claiming the district
court erred in giving a verdict-urging instruction. The court denied the
motion and sentenced Ramirez.
Ramirez appeals, reprising his challenge to the instruction. We review
for abuse of discretion. See State v. Davis, 975 N.W.2d 1, 8, 21 (Iowa 2022)
(noting that the standard of review is for an abuse of discretion if a jury
instruction is discretionary and then concluding that “[t]he trial court did not
abuse its discretion in providing [the] verdict-urging instruction”).
We only grant a new trial based on the decision to give a verdict-urging
instruction when the instruction “coerced or helped coerce the jury’s
verdict.” State v. Church, 997 N.W.2d 16, 19 (Iowa 2023). To determine
whether coercion occurred, we look at the totality of the circumstances,
including (1) the content of the instruction; (2) the timing related to the
verdict; and (3) the polling responses of jurors. Id.
As to the content of the challenged instruction, Ramirez lodges no
complaint. Nor could he persuasively do so, as the verdict-urging instruction
here is nearly identical to that found proper in Church. See id. at 20. We
conclude the content of the instruction was not coercive.
As to the polling responses of jurors, Ramirez declined the court’s
invitation to poll the jurors, so we have no responses to review that could
reveal potential coercion.
That leaves us with the timing of the challenged instruction and the
1
Ramirez later stipulated to prior offenses, making this charge a third offense.
2
verdict. “[T]he essence of the inquiry is whether the length of the jury’s
post-instruction deliberations evidenced the jury engaged in new, real, and
worthwhile deliberation that terminated the disagreement.” Id. at 21.
There is no significant disagreement between the parties about the
timing of events. Once the case was submitted to the jury, the jurors
deliberated for about one hour and twenty-five minutes before reporting an
inability to reach a unanimous verdict. The court then gave the challenged
verdict-urging instruction, the jury deliberated for an additional forty
minutes, and the jury returned a guilty verdict.
In determining whether the jury engaged in new, real, and worthwhile
deliberation during those forty minutes, we note that this was a short trial,
taking little more than half a day for the entire trial prior to jury deliberations.
It was also a trial with a simple fact pattern. Police arrested Ramirez on an
unrelated charge. While searching him incident to that arrest, officers found
a baggie of methamphetamine in his pocket. Given the shortness and lack of
complexity of the trial, the length of the original deliberations, and the length
of the deliberations after the verdict-urging instruction, we find nothing
coercive about the timing of the verdict. See State v. Myers, 140 N.W.2d 891,
898 (Iowa 1966) (finding forty-one minutes of post-instruction deliberation
sufficient to show new, real deliberations that terminated the jury’s prior
disagreement).
Based on the totality of the circumstances and consideration of the
relevant factors, we find no abuse of discretion in the court’s decision to give
the verdict-urging instruction.
AFFIRMED.
Sandy, J., concurs; Buller, J., specially concurs.
3
BULLER, Judge (specially concurring).
I join the majority in full and write separately only to explain why I
believe a litigant’s failure to poll the jury affirmatively weighs against granting
relief when reviewing an Allen charge2 on appeal. Under our case law, the
party challenging an Allen charge bears the burden to prove the instruction
coerced the verdict. See State v. Campbell, 294 N.W.2d 803, 808–09
(Iowa 1980). And on appeal, we assess coercion by focusing on the content of
the instruction, the timing surrounding the verdict, and the responses from
juror polling. State v. Church, 997 N.W.2d 16, 19 (Iowa 2023).
Jury polling is the best and typically only direct evidence of whether
any individual jurors were actually coerced. Polling tests each juror’s assent
in open court and is uniquely capable of exposing a coerced verdict.
See Middle States Utils. Co. v. Inc. Tel. Co., 271 N.W. 180, 184 (Iowa 1937)
(finding coercion when juror asked “Is that your verdict?” responded:
“No—I had to”). Conversely, a clean poll revealing no hesitation or
qualification is strong affirmative evidence there was no coercion. See State v.
Davis, 975 N.W.2d 1, 21 (Iowa 2022).
So what should courts do when an appellant asserts error in an Allen
charge after expressly declining the trial court’s invitation to poll the jury? In
my view, when a party affirmatively chooses not to develop the best evidence
on an issue, the evidentiary void weighs against the appellant. It should be
exceedingly difficult to satisfy the burden to prove coercion after declining to
develop the evidence that would best answer the question. I specially concur
because I would affirm for this additional reason.
2
An Allen charge is the common term for a verdict-urging instruction. See Allen v.
United States, 164 U.S. 492, 500–02 (1896).
4