The Iowa Court of Appeals recently upheld a ruling regarding Curtis Lloyd, who faced charges related to being a felon in possession of a firearm. This decision, filed on July 22, 2026, affects how defendants in similar situations can argue their right to a speedy trial. The court's ruling confirmed that the state made sufficient efforts to locate Lloyd, which played a crucial role in the timeline of his case.
Curtis Lloyd was under investigation by Waterloo police for multiple offenses in 2019. The police had previously taken DNA samples from him as part of an unrelated sex-abuse investigation. Later that year, while Lloyd was receiving medical treatment after a shooting, police questioned him regarding a separate investigation into his possession of a firearm. The DNA results from the earlier case led to arrest warrants for both the sex-abuse case and the gun charge.
After his release from the hospital, police attempted to locate Lloyd but were unsuccessful. They labeled him a “most wanted” suspect and listed him on Cedar Valley Crimestoppers. Despite these efforts, the police did not receive any actionable tips. It wasn't until 2022 that authorities learned through social media that Lloyd might be in Wisconsin. A joint operation with federal marshals aimed to apprehend him, but they could not find him until 2024 when he was arrested in Arizona.
The Black Hawk County attorney filed charges against Lloyd in July 2022, believing the statute of limitations would run out soon. Lloyd was extradited back to Iowa after waiving his extradition rights. He then moved to dismiss the gun charge, claiming his right to a speedy trial had been violated. Lloyd's attorney argued that police could have found him in another county, asserting that the delay in the case was unjustified.
The district court, however, found “good cause” for the delay between the filing of charges and Lloyd’s extradition. The court noted that police had made credible efforts to locate him and that Lloyd was aware of the investigation against him. The court’s findings indicated that the delay was not solely the fault of the state.
In his appeal, Lloyd raised three main arguments: that there was no good cause for the delay, that the state misunderstood the law regarding the statute of limitations, and that he was not responsible for the delay. The court reviewed these claims, focusing on the interpretation of procedural rules governing speedy trials and the discretion exercised by the district court.
The court ruled that there was no abuse of discretion regarding the good-cause determination. It emphasized that the state does not have to engage in a “game of hide-and-go-seek” with defendants. The court also stated, “the State’s duty to provide a defendant a speedy trial does not require that it play a game of hide-and-go-seek with him.” This statement reinforced the idea that the police had made reasonable efforts to locate Lloyd.
Regarding Lloyd's argument about the county attorney's misunderstanding of the law on the statute of limitations, the court found that this claim was not preserved for appeal. The state argued that nobody had identified this supposed mistake during the trial, and the court agreed, stating, “the record supports this argument.”
Furthermore, the court noted that good cause could be shown without establishing fault on the part of the defendant. It pointed out that Lloyd's decision to leave the state while knowing he was under investigation contributed to the delay. The court stated, “we are hard-pressed to see how Lloyd absconding from the State while he knew he was under investigation for one or more felonies was not delay attributable to him.”
The court also distinguished Lloyd’s case from a previous unpublished decision, State v. Castillo-Alvarez, where police had known the defendant's location for an extended period. In Lloyd's case, the police did not know where he was and acted promptly once they located him. The court concluded that the efforts made by the police were sufficient to justify the delay.
The ruling in this case has significant implications for defendants facing similar charges. It reinforces the idea that law enforcement must make reasonable efforts to locate suspects but also emphasizes that defendants have a responsibility to remain available to law enforcement. This ruling may affect how future cases regarding the right to a speedy trial are handled in Iowa.
Looking ahead, it is unclear whether Curtis Lloyd will appeal this decision further. The court's ruling is final unless a higher court decides to take up the case. There are no related cases pending that were mentioned in the court's opinion.