Mark Becker Trial

Key Points of Interest

  1. “He was evaluated on June 21, and the next day he was diagnosed with paranoid schizophrenia and given medication. On June 23, Becker requested he be released as he felt that he was better. A nurse indicated to Becker’s doctor “that he seem[ed] to be doing much better,” and following this conversation, Becker’s doctor agreed to discharge him. Becker’s service coordinator with Cedar Valley Community Support Services agreed to pick Becker up, and the doctor discharged him with prescriptions for medication. The sheriff was not notified.”
  2. “He then left the weight room screaming that he had killed Satan and telling people to go get his carcass. Thomas died from his injuries.”
  3. Becker appealed his conviction, claiming the district court improperly instructed the jury when it submitted the Iowa State Bar Association’s jury instructions defining the elements of the insanity defense instead of the instruction Becker requested. He also claimed the district court violated his due process rights under the Iowa Constitution when it refused to instruct the jury as to the consequences of a notguilty-by-reason-of-insanity verdict. Finally, Becker claims the restitution order, including the expert witness fees paid to Becker’s expert witnesses, exceeded the maximum amount allowed by the statute. The court of appeals affirmed the district court’s rulings on all three issues.
  4. Definition of Insanity Defense:   A person shall not be convicted of a crime if at the time the crime is committed the person suffers from such a diseased or deranged condition of the mind as to render the person incapable of knowing the nature and quality of the act the person is committing or incapable of distinguishing between right and wrong in relation to that act. Insanity need not exist for any specific length of time before or after the commission of the alleged criminal act. If the defense of insanity is raised, the defendant must prove by a preponderance of the evidence that the defendant at the time of the crime suffered from such a deranged condition of the mind as to render the defendant incapable of knowing the nature and quality of the act the defendant was committing or was incapable of distinguishing between right and wrong in relation to the act.
  5. Compares to the Kehoe case.
  6. “Having determined there is no historical basis for the instruction, we now address whether there is a contemporary consensus as to whether such an instruction is required.”
  7. “Twenty-four jurisdictions require an instruction like the one Becker requested be given.
  8. “We concluded that placing the insanity instruction before the instructions regarding guilt and innocence, though erroneous, did not shift the burden of proof to the defendant and therefore did not violate due process. Id. Thus our determination of whether a due process violation occurred was based on all of the instructions given at trial, as opposed to whether a single faulty instruction was given.”
  9. “We might come to a different conclusion if prosecutors had given the inaccurate impression that Becker would go free if he was found guilty by reason of insanity.”
  10. “The instructions given by the district court, when read as a whole, fairly and accurately advised the jury of the legal standard it was to apply to Becker’s insanity defense. Becker’s appeal on this ground is without merit. Also, due process under article I, section 9 of the Iowa Constitution does not require the district court inform the jury of the consequences of a not-guilty-by-reason-of-insanity verdict under the facts of this case. Becker’s conviction is affirmed.”
  11. “On three occasions, Becker was hospitalized for mental health treatment after episodes of violent behavior against both family members and a stranger. The episodes of violence were accompanied by statements revealing Becker had an attenuated connection with reality, including persistent delusional claims that Coach Ed Thomas controlled him and others through extrasensory powers. Despite his recurring inpatient psychiatric treatment, Becker’s 55 severe mental illness was not controlled. “
  12. “Given Becker’s history of violent, delusional, and homicidal conduct consistent with severe mental derangement, the jurors were justifiably unwilling, without the requested information about the consequences, to risk the possibility that Becker would again be released without proper psychiatric assessment and management. Deprived of a meaningful opportunity to assert his only defense, Becker’s right to a fair jury trial was abridged. I would grant him a new trial.”

http://www.iowacourts.gov/About_the_Courts/Supreme_Court/Supreme_Court_Opinions/Recent_Opinions/20120720/10-0631.pdf

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