Iowa Supreme Court Affirms Decision in Mark Becker Case

The Iowa Supreme Court issued their ruling on Mark Becker’s appeal. Becker was sentenced to life in prison after the District Court found him guilty of murdering Applington-Parkersburg’s beloved football coach, Ed Thomas. Becker appealed the decision and the case made it all of the way to the Iowa Supreme Court, where the Justices affirmed the decision made by the District Court.

Coach Thomas became the head football coach at Applington-Parkersburg in 1975. He amassed 292 wins, including two state titles, and was named national high school football coach of the year in 2005. But more than just being a coach, Thomas was known for turning generations of boys into men, and molding them into more than they thought they could be. After a tornado hit in May of 2008, Thomas led the relief effort and “guided Parkersburg out of the wreckage”. The 2008 football season, he guided the Falcons to an 11-1 record, a feat that seemed impossible after the tornado had destroyed so much. In 2010, he was honored at the ESPY awards with the Arthur Ashe award for courage which his family accepted on his behalf. “The three things that mattered to Ed Thomas the most were: faith, family, and Falcon football”.

On June 24,2009, Mark Becker, a native of Parkersburg and former football player under Coach Thomas, went to the high school weight room where the players were doing their summer workouts and shot his former coach. Earlier that day, Becker had practiced using the .22 caliber gun on a birdhouse. He later revealed to the police that he “knew he would have to get close to Thomas in order to be sure that he hit him”. Becker spent a good amount of time searching for Thomas. He went to where he thought the Thomas’ lived only to find out that he was at the wrong house. He then went to the elementary school before finally finding him at the high school. Becker “entered the weight room, approached Thomas, took out the gun, and shot Thomas six times in the head, chest and leg. He proceeded to kick and stomp on Thomas, yelling, “Fuck you, old man.” 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”. Becker admitted to police that he shot Thomas while he was in custody and the prosecution had multiple witnesses that identified him as the shooter.

In the original trial, Becker used an insanity defense. After a number of violent outbursts (including a nasty incident with a baseball bat), he was diagnosed with paranoid schizophrenia on June 21, just three days before walking into that weight room and shooting Coach Thomas. Becker’s lawyers claimed that because of his mental state, he did not understand the consequences of his actions. The defense used two psychiatrists as expert witnesses who testified that as a paranoid schizophrenic, “Becker did not know and understand the nature or consequences of his actions and was incapable of distinguishing right from wrong in relation to those actions”. Interestingly, the state had two of their own psychiatrists as expert witnesses. They testified that even though Becker was a paranoid schizophrenic, he still “understood the nature and consequences of his action and knew right from wrong in relation to the acts he committed”.

The state argued that the attack was premeditated and Becker acted with malice and forethought and the jury rejected Becker’s insanity defense. They found him guilty of first degree murder and therefore Becker was sentenced to life in prison without the possibility of parole. He was also ordered by the court to pay restitution to Thomas’ estate. After the guilty verdict, Becker tried to get a new trial but the motion was denied. He appealed his conviction and presented three reasons for doing so. He claimed that “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 not- guilty-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”.

Becker’s first complaint is that the instructions given to the jury did not properly define insanity and that his own instructions should have been given instead. The instructions given to the jury that even if the defendant has shown that he is mentally ill, he still must convincingly prove that he didn’t have “sufficient mental capacity” to understand his actions and the consequences or there has to be proof that he can’t tell the difference between right and wrong in terms of his actions. However, if neither of these elements are proved, the defendant is considered guilty. The Supreme Court concluded that the district court was not in the wrong when it gave the instructions (34 & 35) to the jury and that they “did not abuse its discretion by not giving Becker’s requested instruction in place of instruction 35”. The Supreme Court felt that, taken as a whole, instructions 34 & 35 was accurate in the instructions of how to apply legal standards for an insanity defense.

Becker’s second complaint is that his due process rights were violated because the district court failed to give his requested instruction to the jury. His claim is that “failure to provide a consequence instruction implicates his constitutionally based due process rights”. He also claimed that the consequence instruction was necessary for him to protect his right to have a fair trial. The Supreme Court then, had the decision to decide whether or not the refusal to provide the jury with the consequence instruction denied Becker’s right to a fair trial. They concluded that there was no error in the trial court’s refusal to grant defendant’s requested instruction on a defendant’s disposition after acquittal on the ground of insanity. Due process does not require a district court to give a consequence instruction simply because the defendant requests it”. The Supreme Court decided that the “district court did not not err by refusing to provide the jury with the proposed consequence instruction”.

To wrap up this case, the Supreme Court concluded that Mark Becker did not make a case for a violation of due process rights and that the instructions given to the jury, when taken together, “accurately advised the jury of the legal standard it was to apply to Becker’s insanity defense”. They stated that according to the Iowa Constitution, there is no requirement for the district court to inform the jury of the consequences of an insanity defense and therefore Becker’s appeal did not have merit. His conviction was affirmed by the Supreme Court with all justices concurring except one.

 

Sources:

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

ESPY’s video: https://www.youtube.com/watch?v=ukodLTOTens

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