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State v. Beck

Court of Appeals of Iowa

February 19, 2014

STATE OF IOWA, Plaintiff-Appellant,
v.
TRAVIS HOWARD RICHARD BECK, Defendant-Appellee

As Amended August 12, 2014.

Page 57

Appeal from the Iowa District Court for Muscatine County, Thomas G. Reidel, Judge. The State appeals from the district court's ruling on its motion to adjudicate law points.

Thomas J. Miller, Attorney General, Tyler J. Buller and Kevin Cmelik, Assistant Attorneys General, Alan Ostergren, County Attorney, and Korie Shippee, Assistant County Attorney, for appellant.

Mark C. Smith, State Appellate Defender, for appellee.

Heard by Vogel, P.J., and Mullins and McDonald, JJ.

OPINION

Page 58

McDONALD, J.

This case presents the deceptively simple question of whether a criminal defendant charged with assault may assert the defense of diminished responsibility. In ruling on the State's motion to adjudicate law points, the district court concluded the defendant could assert the defense. The supreme court granted the State's application for discretionary review of the district court's ruling, stayed further proceedings in the district court, and transferred the matter to this court.

I.

This appeal involves three separate criminal proceedings involving the same defendant. In October 2011, Travis Beck was charged with attempted murder and willful injury, both charges arising out of an incident in which he allegedly stabbed his girlfriend's brother four times. In July 2012, the State charged Beck with willful injury arising out of an incident in which he allegedly stabbed his girlfriend in the chest. The State filed an amended trial information in each case in January 2013, charging Beck in each case with one count of assault causing serious injury, in violation of Iowa Code section 708.2(4) (2011). The third case arises out of events occurring on May 5, 2012--when Beck allegedly beat his girlfriend with a skateboard--and May 9, 2012--when Beck allegedly punched his girlfriend in the forehead. For the conduct occurring in May 2012, the State charged Beck with two counts of domestic abuse assault, third offense, in violation of Iowa Code section 708.2A(2).

In June 2012, Beck sought leave from the district court to obtain a mental health evaluation for the purpose of exploring mental health defenses. The district court granted the request, and Beck was examined by his expert and the State's expert. Beck's expert and the State's expert each concluded that Beck " displays characteristics [that] would support a defense of diminished responsibility." In September 2012, Beck provided notice of his intent to rely on the defenses of self-defense and diminished capacity. The State subsequently filed its motion to adjudicate law points, asking, " Is diminished responsibility a defense available to a defendant charged with assault?" The court held the defense was available.

II.

We review " a trial court's ruling on a motion to adjudicate law points for correction of legal error. The appropriateness of the district court's action turns on the correctness of its interpretation of the relevant statutes, which are reviewable for correction of errors at law as well." State v. Muhlenbruch, 728 N.W.2d 212, 214 (Iowa 2007) (internal citation omitted); see State v. Tong, 805 N.W.2d 599, 601 (Iowa 2011); Iowa R. App. P. 6.907.

III.

A.

We first discuss the defense of diminished responsibility. Iowa Rule of Criminal Procedure 2.11(11)(b) provides, " If a defendant intends to rely upon the defense of insanity or diminished responsibility at the time of the alleged crime, the defendant shall, within the time provided for the filing of pretrial motions, file written notice of such intention." The diminished responsibility

Page 59

defense is not codified. The legislature has thus not explicitly delineated the parameters of the defense. Cf. Iowa Code § 701.4 (codifying defense of insanity); Iowa Code § 701.5 (codifying defense of intoxication); Iowa Code § 701.6 (codifying defense of ignorance or mistake). Although not codified, the defense has long been recognized at common law. See State v. Gramenz, 256 Iowa 134, 126 N.W.2d 285, 288 (1964).

" The common law defense of diminished responsibility permits proof of defendant's mental condition on the issue of defendant's capacity to form a specific intent in those instances in which the State must prove defendant's specific intent as an element of the crime charged." Lamasters v. State, 821 N.W.2d 856, 869 (Iowa 2012). The defense " allows a defendant to negate the specific intent element of a crime by demonstrating due to some mental defect she did not have the capacity to form that specific intent." Anfinson v. State, 758 N.W.2d 496, 502 (Iowa 2008). " Specific intent is present when from the circumstances the offender must have subjectively desired the prohibited result." State v. Redmon, 244 N.W.2d 792, 797 (Iowa 1976). In addition, " [w]hen the definition refers to defendant's intent to do some further act or achieve some additional consequence, the crime is deemed to be one of specific intent." State v. Heard, 636 N.W.2d 227, 231 (Iowa 2001).

The common law limitations of the defense are well established. " Evidence of diminished responsibility may not . . . negate general criminal intent, and is therefore not a defense to crimes which do not require proof of specific intent." Anfinson, 758 N.W.2d at 502. " General intent exists when from the circumstances the prohibited result may reasonably be expected to follow from the offender's voluntary act, irrespective of any subjective desire to have accomplished such result." Redmon, 244 N.W.2d at 797. Our supreme court reached the conclusion that diminished responsibility is not a defense to those crimes not requiring proof of specific intent after the court compared the defense of diminished responsibility to the defense of insanity. See State v. McVey, 376 N.W.2d 585, 587 (Iowa 1985). The court explained that mens rea, insanity, and diminished responsibility are legal concepts without medical counterparts. Id. " As legal concepts they are used to establish limits to legal culpability. The extent to which evidence of mental impairment will be permitted to affect criminal responsibility is therefore a legal question." Id. The codification of the insanity defense and failure to codify the diminished responsibility defense evidenced legislative intent, the supreme court reasoned, to limit the assertion of the defense of diminished responsibility only to those crimes requiring proof of specific intent:

In view of the fact the Iowa common law recognized mental impairment other than legal insanity as a defense only to specific intent crimes at the time the insanity defense was codified, we believe the General Assembly drew the line at that point. The legislature thus established the applicable legal standard for deciding culpability upon evidence of mental impairment in cases requiring proof only of guilty knowledge or general criminal intent accompanying a prohibited act. The mens rea of those crimes is not affected by evidence of mental impairment that ...

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